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Senedd Cymru | Welsh Parliament
Pwyllgor Diwylliant, Cyfathrebu, y Gymraeg, Chwaraeon, a Chysylltiadau Rhyngwladol | Culture, Communications, Welsh Language, Sport, and International Relations Committee
Bil Gwahardd Rasio Milgwn (Cymru) | Prohibition of Greyhound Racing (Wales) Bill
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The stated policy intention of the Bill is to ban greyhound racing in Wales. As the Racecourse Promoters’ Association (RCPA), we remain firmly opposed to the stated policy intention and general principles of the Bill on the basis that they will only risk harming greyhound welfare. The Bill focuses wholly on banning greyhound racing, instead of prioritising ways to promote and protect greyhound welfare, which would additionally lead to the unnecessary loss of jobs, livelihoods and other economic, cultural and social value for the community.
For background, the RCPA represents almost all licensed greyhound racecourses in Great Britain. Founded in 1988, the RCPA provides a platform to ensure the voices of racecourses are heard by the industry regulator. Members of the RCPA are all licensed greyhound racecourses, regulated under the Greyhound Board of Great Britain (GBGB), which currently offers a system in which greyhound welfare can be protected and promoted. We refer to GBGB’s welfare strategy, ‘A Good Life for Every Greyhound’, which ensures that under GBGB regulation greyhounds’ welfare needs are met, across the Five Domains of animal welfare, across their lifetimes. We assert that effective regulation under GBGB offers the best way to safeguard greyhounds, rather than a ban through this proposed Bill.
The stated policy intention is to ban greyhound racing. We do not agree with this nor do we think this Bill provides anything to protect and promote greyhound welfare. As a group of racecourses licensed by the Greyhound Board of Great Britain (GBGB), we have a thorough understanding of the extensive processes in place to ensure the highest standards of greyhound welfare under the robust regulatory system GBGB offers. In contrast, we believe greyhound welfare would be least well protected were the sport to be banned in Wales instead of effectively regulated.
Indeed, the public consultation launched by the Welsh Government prior to the introduction of this Bill, on the Licensing of Animal Activities asked for views on what a licensing system for those involved in greyhound racing – such as trainers and owners of racing greyhounds – could offer. We remain of the opinion that such a licensing approach, rather than a ban, would support greyhound welfare.
Currently, the only greyhound racing track operating in Wales is the Valley Greyhound Stadium, one of our members, which is now licensed by GBGB – having successfully achieved its GBGB licence in August 2023 following considerable investment to upgrade its kennelling and veterinary facilities to meet the required standard. Were a ban to come into place, the protections offered by GBGB regulation would be removed; we have set out below just some examples of the ways GBGB-licensed racecourses, such as the Valley Greyhound Stadium, are currently able to safeguard greyhound welfare.
We do not believe it is in the interests of greyhounds should this Bill proceed and instead it appears to have been driven by the influence of a small but vocal proportion of animal rights activist groups, including those who are known to disseminate misinformation. If the Welsh Government is concerned with animal welfare, instead of ethical arguments about animal ‘rights’, we believe that they should legislate for a licensing scheme such as the one offered by GBGB instead of pursuing this misguided Bill.
Examples of the ways greyhound welfare is optimised under GBGB regulation:
As regulator, GBGB ensures that the welfare of racing greyhounds is of paramount importance within licensed racing. Through its Greyhound Commitment and over 200 Rules of Racing, GBGB seeks to ensure that the health and wellbeing of all registered greyhounds are promoted and protected at all times. GBGB’s welfare strategy, ‘A Good Life for Every Greyhound’, was led by Independent Director Professor Madeleine Campbell (an EBVS® European Veterinary Specialist and a RCVS Specialist in Animal Welfare Science, Ethics and Law), seeking to further optimise the care and protection that racing greyhounds receive throughout their lives – not just the period they are racing. The strategy has been externally peer-reviewed by respected veterinarians in the field of animal welfare.
The strategy makes clear the ways in which, as the sport’s regulator, GBGB expects and requires all such stakeholders to fully engage in protecting and optimising the welfare of the greyhounds under their care across all stages of a greyhound’s life: breeding, rearing, racing years and retirement.
Implementation of the strategy is well underway. Key elements include:
· Expanding veterinary expertise within the sport through the appointment of an Executive Veterinarian, who plays a pivotal part in directing the implementation of the strategy;
· Introducing a new field force of Regional Regulatory Veterinary Surgeons to work alongside the Executive Veterinarian and who now run the independent kennelling inspections of trainers;
· Providing a comprehensive continuing education programme on greyhound welfare for everyone in the sport, to optimise the care they are able to provide greyhounds;
· Engaging with expert independent academic partners to design, deliver and analyse data gathering and research programmes into areas such as genetics, nutrition and prevention and early detection of injuries;
· Leading an effort by international greyhound regulators to develop harmonised welfare policies and strategies.
GBGB is the only UK sports regulator to be accredited by UKAS. This UKAS standard, which covers both licensed tracks and greyhound trainers’ residential kennels, exists alongside the BSI PAS 251:2017 technical specification and GBGB’s Code of Practice for Residential Kennels.
GBGB has a zero-tolerance approach to any mistreatment of greyhounds and does not hesitate to take the strongest action against any form of animal mistreatment. Through its investigations team, GBGB explores any concerns regarding welfare and integrity and follows a strict disciplinary process to address any breaches of the Rules of Racing, which is overseen by an independent disciplinary panel. GBGB is prepared to impose the necessary sanctions including a lifetime ban from the sport.
Through GBGB’s Rules of Racing and welfare strategy, welfare standards and protections afforded to racing greyhounds far exceed those that exist for the pet dog population where there is no monitoring in place to demonstrate welfare standards.
In practice, this means:
Breeding
· Whilst GBGB’s regulatory remit does not extend to the breeding and rearing of greyhound pups in Britain, GBGB believes it shares responsibility to ensure that all racing greyhounds have the best possible start to their lives. Through the welfare strategy, GBGB committed to furthering its support of high-welfare British breeding.
· In 2024, 15.5% of the greyhounds registered with GBGB were from British-bred litters (up from 13.1% in 2021), with the remainder originating from either Northern Ireland or the Republic of Ireland. The overall number of Irish greyhounds entering racing in Britain has decreased by 26% since 2021. These changes are in alignment with GBGB’s welfare strategy which sought to increase the number of British-bred greyhounds and minimise the potential welfare and biosecurity risks associated with international transportation of greyhounds. GBGB continues to work closely with Greyhound Racing Ireland (GRI) to ensure the traceability of greyhounds entering GBGB racing from Ireland or returning to Ireland for racing or breeding.
· In August 2025, GBGB announced that it is developing a registration system for British-bred greyhounds. This move is intended to streamline the process, support British breeding and ensure greater oversight by GBGB from a greyhound’s birth.
· GBGB provides education opportunities on breeding and rearing, including a recent live webinar series delivered by Professor Gary England, a leading expert in canine reproduction.
· GBGB will shortly be publishing a new comprehensive Code of Practice for Breeders and Rearers of Racing Greyhounds, informed by research field visits to established greyhound breeders and rearers and developed with expert welfare and veterinary input. This will provide advice and guidance for raising healthy and well-socialised greyhounds and will be shared with our international regulator colleagues to promote best practice.
During their racing career – at the track
· Under the Rules of Racing, the vehicles trainers use to transport their greyhounds to and from the track must be adequately air-conditioned; since June 2021, when it became a requirement for vehicles to be air-conditioned, over £2 million has been spent within the industry on replacement vehicles or upgrading existing air-conditioning units.
· There must be at least one veterinary surgeon in attendance at GBGB-licensed racecourses for any races or trials. Their role is to check each greyhound before, during and after they race, monitor disease control and administer emergency care in the event that this becomes necessary.
· GBGB-licensed racecourses benefit from GBGB’s multi-year collaboration with internationally recognised experts STRI. Each stadium receives four STRI inspections a year which allows experts to assess the track in all seasons. Through these regular visits, STRI consultants make recommendations designed to optimise the safety of the running surface. In 2024, STRI conducted 80 visits to GBGB-licensed racecourses.
· GBGB also has a national Track Liaison Officer who provides assistance to track staff and makes regular visits to stadia during the year.
· Track staff have access to a regular programme of continuing professional development which covers track preparation and maintenance as well as how to care for greyhounds whilst at the track.
· In 2024, GBGB published its Track Maintenance Guide – a substantial resource developed through a collaboration between Dr Christian Spring, Group Principal Scientist for STRI, GBGB’s Track Liaison Officer and the GBGB Track sub-committee. The Guide provides an invaluable continuing education and reference resource for all racecourse stakeholders. Importantly, it not only provides clear guidance on all stages of the track maintenance process – construction and layout, infrastructure, preparation and troubleshooting – but also provides information on where stakeholders can seek expert help and emphasises the need for an evidence-based, scientifically informed and flexible, proactive approach.
· The continuous improvements in track safety and the provision of veterinary treatment at the track have led to significant improvements in the track injury and fatality rates. Most notably, between 2018 and 2024, the track fatality rate decreased by 50%, from 0.06% to 0.03% and in 2024, licensed racing saw its lowest ever injury rate of 1.07% – down from 1.21% in 2021. It is important to note that, according to the British Horseracing Authority’s own data, the fatality rate in British horseracing (including flat and jump racing) is noticeably higher at 0.25%.
· GBGB meticulously and accurately records all injuries sustained at licensed tracks – going beyond what has been requested by Defra. Not only does this show GBGB’s commitment to transparency and accountability it also allows our Track Liaison Officer and Track Safety Committee to identify any concerning trends and take immediate action to prevent any further injuries.
· If a greyhound sustains a career-ending injury on a licensed track, they are eligible for financial assistance through our Injury Retirement Scheme (IRS). Through the IRS, funding is provided towards corrective veterinary treatment for orthopaedic injuries so that, wherever possible, greyhounds can go on to enjoy a full and active life in retirement. Since the scheme was introduced in 2018, GBGB has paid out over £1.4 million to support the veterinary treatment of registered greyhounds. Many stadia also offer their own injury retirement schemes to ensure all greyhounds receive whatever veterinary treatment they require and this will shortly become a requirement for all stadia under the Rules of Racing. As a result of the IRS, we have seen a dramatic fall in the number of greyhounds put to sleep for economic reasons following an injury sustained while racing. This figure has fallen from 175 in 2018 to just three in 2024 – a decrease of 98%. GBGB believes that it is unacceptable for a dog to sleep for economic reasons and remains committed to reducing this number to zero.
· To see further improvements in this area, GBGB is currently funding two academic research projects at the University of Nottingham specifically looking at injury prevention. These projects are looking at the causes of injuries in racing greyhounds and how modern technologies could be used to help detect sub-clinical injuries and inform decisions about early treatment and rest.
· Each GBGB-licensed racecourse is subject to annual inspections as part of GBGB’s wider regulatory programme. Stadia also receive regular visits throughout the year from GBGB’s Stipendiary Stewards.
· Each racecourse has access to GBGB’s Track Safety Committee Fund which funds investments into track equipment and safety infrastructure. In 2024, grants totalling £168,000 were issued for equipment and infrastructure improvements.
· Tracks must adhere to GBGB’s Hot and Cold Weather Policies, which seek to optimise the comfort and wellbeing of greyhounds during periods of very hot or very cold weather. Within the policies, which are reviewed annually, GBGB has set out at which temperatures racing must be cancelled. These limits are based on the latest veterinary advice on maintaining a greyhound’s thermo-neutral zone of between 10°C and 26°C. The policies also set out the measures that must be taken to keep greyhounds comfortable at the track (e.g. cooling baths, reducing parade times) and when travelling to and from it.
· To safeguard greyhound welfare and the integrity of the sport, thousands of regulatory samples are taken each year to ensure that greyhound racing is a drug-free sport. Working alongside LGC, a world-leading independent drug surveillance laboratory, and other international regulators, GBGB has developed an effective and modern testing and intelligence programme which acts as a deterrent against the use of prohibited substances. Since 2017, all greyhounds registered by GBGB must have a ‘Point of Registration’ sample to ensure that each greyhound begins its GBGB career free of any long-acting prohibited substances, whilst a mixture of random or intelligence-led race day samples are taken throughout the year across all racecourses.
During their racing career – at their trainers’ kennels
· Each year, licensed trainers’ residential kennels must receive:
o A veterinary inspection which examines all aspects of the greyhounds’ care, health and wellbeing;
o An audit by independent auditors SCI to ensure they meet the standards required by the British Standards Institute’s (BSI) Publicly Available Specification (PAS) for greyhound trainers’ residential kennels – PAS 251: 2017.
· All trainers also receive separate visits to their residential kennels during the year from GBGB Stipendiary Stewards and GBGB Regional Regulatory Vets (RRVs).
· In January 2025, GBGB’s team of RRVs began conducting their trainers’ Annual Veterinary Kennel Inspection, which was previously carried out by either a veterinarian from the trainer’s local practice or a track veterinarian. The new RRV annual veterinary kennel inspections are in a more thorough format than previously used and include, for example, an inspection of every greyhound accommodated within the kennels – whether or not they are actively racing.
· Since the launch of the welfare strategy in 2022, there has been a 73.2% increase in the total number of routine GBGB visits to residential kennels. In 2024, on average, each licensed trainer received three visits to their kennels by GBGB field staff as well as an audit inspection by SCI and an external veterinary kennel inspection. In addition to routine visits, GBGB carries out risk-led more frequent monitoring visits of specific kennels if it is deemed necessary.
· Any failures of compliance with the UKAS accredited standards result in improvement notices, and failure to make required improvements means that a trainer does not have their GBGB licence renewed.
· Licensed trainers have access to the Trainers’ Assistance Fund, which provides grants for trainers to upgrade and improve their residential kennel facilities. In 2024, £503,910 was awarded via the Trainers’ Assistance Fund for trainers to upgrade their kennel and paddock facilities.
· In 2020, GBGB introduced – in consultation with animal welfare charities and veterinary professionals – a comprehensive Code of Practice for Residential Kennelswhich sets out clear rules and guidelines on how greyhounds should be looked after at their trainer’s kennels. This includes specific requirements around diet, bedding, kennel construction and size, dental care, environmental enrichment as well as daily exercise routines.
· Licensed trainers have access to continuous professional development, which leverages the latest in scientific research and innovations, in the form of a regular programme of workshops and webinars involving leading veterinarians and academics, including on nutrition and understanding kennel sickness. To maximise engagement, these courses are delivered free of charge. Trainers also benefit from the support and expertise of GBGB’s Executive Veterinarian and a team of RRVs who are available to give advice and guidance on any aspect of greyhound welfare as required.
Into Retirement
· GBGB has full traceability of every racing greyhound throughout their careers. Upon a greyhound’s eventual retirement, all greyhound owners must adhere to GBGB’s Responsible Homing Policy and inform GBGB of the retirement destination of their greyhound. The microchip of retired greyhounds is registered in a pet canine database, ensuring that traceability is maintained after greyhounds retire from racing.
· Through our Greyhound Retirement Scheme (GRS), GBGB ensures that the financial costs associated with a greyhound’s eventual retirement are secure before their racing career even begins. At the point of a racing greyhound’s registration with GBGB, the owner must pay £210 towards the GRS Bond. This sum is kept and then matched by GBGB when the greyhound enters an approved homing centre. This creates a £420 bond which will help to cover the costs of a greyhound’s stay in a homing centre whilst they await their forever home.
· Since the launch of the GRS in 2020, almost £6 million has been paid in matched funding to GBGB’s network of over 100 approved homing centres.
· In 2024, GBGB strengthened its follow-up procedures to check that retired greyhounds are settling well into their new placements. All greyhounds homed privately now receive multiple follow-up communications from GBGB at two, six and twelve months after welcoming their greyhound into their home.
· To enhance the welfare of those greyhounds remaining at their trainers’ residential kennels while they await homing, with input from the Greyhound Forum, GBGB developed a Guide to Enhancing the Welfare of Retired Greyhounds in Residential Kennels. These greyhounds also receive visits from GBGB’s Regional Regulatory Vets who have a specific responsibility to check on their welfare.
· GBGB’s regulatory remit means it has no legal powers to stop a greyhound being exported once they have retired. Nonetheless, GBGB has worked to strengthen the systems and enforcement which it is able to use to safeguard the welfare of greyhounds during exportation. In January 2025, new stakeholder guidance around the export of retired greyhounds outside of Great Britain was issued. This was accompanied by the introduction of a new procedure whereby owners must inform GBGB before the greyhound’s movement abroad using a newly developed form and review system to ensure the necessary due diligence has been carried out regarding the ongoing care of their greyhound. Since the process began, the majority of applications have been submitted for greyhounds to retire with an existing racing owner, or a new private owner who lives abroad and GBGB has been satisfied that the required due diligence has been carried out.
· In most cases, greyhounds retiring from the sport go on to make excellent pets and can transition successfully from a kennel environment to life in a domestic setting. As part of the strategy, Dr Sarah Heath FRCVS, an RCVS and European Veterinary Specialist in Behavioural Medicine, has been providing educational opportunities about how this can best be done for national and international stakeholders within the sport of greyhound racing. GBGB already supports trainers to enlist the assistance of specialist homing centres who can offer help with these individual greyhounds, but to further this, GBGB is working with Dr Heath to develop a standardised behavioural assessment for racing greyhounds to ensure these greyhounds are given the correct support.
· As a result of these measures, licensed racing has seen the successful retirement rate improve from 88% in 2018 to 94% in 2024. This is a significant improvement particularly in the context of the current rehoming crisis affected all breeds of dog.
The Bill is intended to prohibit greyhound racing in Wales. Under Section (1) of the Bill a person commits an offence if he/she/they ‘(a) is an operator of a stadium or similar venue in Wales and uses it, or knowingly permits it to be used, for greyhound racing, or (b) is involved in organising greyhound racing in Wales’.
As we have already set out in our answers to Question 1 and Question 2 of this consultation, the RCPA believes that these provisions as set out will not improve greyhound welfare and will instead greatly increase the risks to greyhound welfare in Wales. This is because greyhound welfare is currently protected and promoted by the robust regulatory system of GBGB, under which the Valley Greyhound Stadium operates. We would refer to the detailed examples of the ways in which GBGB regulation supports greyhound welfare at the Valley Greyhound Stadium, as set out in our response to Question 2 of this consultation.
Under Section 2 of the Bill, ‘“Greyhound racing” means setting greyhounds to run around a track in pursuit of a lure activated by mechanical means (and this includes timing or training a greyhound as it runs around a track)’.
We are of the same view as GBGB that Section 2 of the Bill would inevitably also risk greyhound welfare because it would mean either that trainers would have to transport their greyhounds longer distances in order to train or race them across the border, or that activity would be driven underground by a ban.
As per our responses to other questions in the consultation, the RCPA does not support the Bill nor the stated policy intention. We believe that greyhound welfare is currently well protected and promoted by the GBGB regulation of the Valley Greyhound Stadium, the only greyhound racing track in operation in Wales at present. To ban the sport would be to remove these protections, which would therefore be detrimental to greyhound welfare.
As per our responses to other questions in the consultation, the RCPA does not support the Bill nor the stated policy intention. We believe that greyhound welfare is currently well protected and promoted by GBGB regulation of the Valley Greyhound Stadium, the only greyhound racing track in operation in Wales at present. To ban the sport would be to remove these protections, which would therefore be detrimental to greyhound welfare.
Section 5 sets out that ‘the […] provisions of this Act (other than Sections 5 and 6) come into force on a day appointed by the Welsh Ministers in an order made by Welsh statutory instrument, but they must be brought into force on a day that is— (a) no sooner than 1 April 2027, and (b) no later than 1 April 2030’.
We have been clear that a phased ban would be akin to an immediate one, as it would be in almost any sector or area of business. Our regulatory system of assuring and delivering on high standards of greyhound welfare relies on interdependent elements – including the work of veterinary surgeons, trainers and kennel staff, breeders, owners, racing officials, stipendiary stewards and a wider network of suppliers and dependents. Without confidence in its future, individuals and organisations involved in the sport would have no choice but to rapidly cease operations; livelihoods and all associated income would be lost with potentially catastrophic consequences for the lives of racing greyhounds because of the immediate pressures this would cause on homing centres.
As the British Veterinary Association (BVA) stated in its response to the Welsh Government’s consultation on the licensing of animal welfare establishments (page 63) this would have negative impacts on the welfare of huge numbers of animals. Since the announcement of the intention to ban greyhound racing in Wales the BVA has reiterated its concern about the lack of planning by Welsh Government for homing of greyhounds who will exit racing as a result of the ban (for example, https://www.vettimes.com/news/vets/small-animal-vets/greyhound-race-ban-needs-robust-transition-bva-says-after-bill-draft ).
The RCPA, along with GBGB and those within the licensed sector of our sport, share these concerns that the provisions of this Bill, if enacted, would jeopardise greyhound welfare because of the pressures caused by overwhelming homing centres, at a time when they are already struggling and at capacity.
We feel it important to note that under GBGB, there is an existing scheme to support racing greyhounds into their retirement – the Greyhound Retirement Scheme. Likewise, many GBGB-licensed racecourses supplement this with their own retirement support to help address the costs of homing racing greyhounds and safeguard their welfare long after their racing careers.
As per our responses to other questions in the consultation, the RCPA does not support the Bill nor the stated policy intention. We believe that greyhound welfare is currently well protected and promoted by GBGB regulation of the Valley Greyhound Stadium, the only greyhound racing track in operation in Wales at present. To ban the sport would be to remove these protections, which would therefore be detrimental to greyhound welfare.
There is no provision for the welfare of racing greyhounds, should this Bill be enacted, nor sufficient consideration of what support would be available to look after greyhounds and appropriately home them, especially given the job and livelihood losses which will result from this Bill for those currently caring for racing greyhounds.
The RCPA has no view on Chapter 5 of Part 1 of the Explanatory Memorandum.
As explained in our responses to the previous questions in this consultation, the RCPA does not agree with the Bill nor the stated policy intention and the Bill, which focus exclusively on banning greyhound racing; we are firmly of the believe that this will only be harmful to greyhound welfare.
To ban the sport would be to remove the significant protections currently in place due to the GBGB regulation of the Valley Greyhound Stadium, the only greyhound racing track in operation in Wales at present; this would be greatly detrimental to greyhound welfare to say nothing of the losses to economic, social and cultural value within the local community.
The RCPA share the concerns of GBGB that the provisions of this Bill, if enacted, would also further jeopardise greyhound welfare because of the pressures caused by overwhelming homing centres, at a time when they are already, by their own admission, struggling and at capacity.
We do not believe that the Welsh Government has carried out the necessary consultation or adequately worked with the RCPA, the Valley Greyhound Stadium or those impacted directly by this Bill. Whilst the Valley Greyhound Stadium has been represented on the Implementation Group, this Group has not yet had a chance to report back and so we question the decision to introduce this Bill at this point in time. We have concerns that the economic impact of this Bill have not yet been sufficiently explored or worked through, despite the Valley Greyhound Stadium providing information to support this work.
On behalf of those directly or indirectly employed by the Valley Greyhound Stadium, we feel it would be wholly inappropriate for this Bill to proceed without this due consideration and due diligence.
85 individuals are directly or indirectly employed as a result of the Valley, with the majority looking to lose their source of employment and income. These include the trainers, of which there are 21 GBGB-licence-holders based in Wales, as well as kennelhands, maintenance, camera and hospitality staff. Moreover, the assessment of SIS Limited, the media rights company with which the Valley Greyhound Stadium holds its contract, is that the economic loss of a ban would be a minimum of £15 million over the next five years. Further losses can be extrapolated from GBGB’s Economic Impact of Greyhound Racing in the UK (2022) report. This highlights that UK-wide owners of greyhounds contribute around £24.2 million annually into the sport, which would be circa £1.27 million on an individual track basis.
GBGB regulation is offered at no cost to the Welsh Government and offers evidence-based, robust protections for greyhound welfare. In contrast, the Welsh Government proposes introducing a ban through this Bill which would only be detrimental to greyhound welfare and lead to employment, financial, cultural and social losses in an area of the country where it has been much needed and valued.
The RCPA shares the belief of the Greyhound Board of Great Britain (GBGB) that this Bill will be extremely detrimental to greyhound welfare. We wish to join GBGB in urging the Welsh Government and Senedd to demonstrate a genuine commitment to animal welfare rather than to animal rights and to withdraw this Bill and legislate instead to safeguard animal welfare by maintaining greyhound racing as a legal activity and insisting that in future all greyhound racing in Wales be regulated by GBGB.