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Veterinary medicines records: the compliance most likely to be found wanting

Five-year retention, seven fields per transaction, a recorded reason every time a POM-V goes out without a written prescription, and an audit at least once a year that most practices have never minuted. This is what the Veterinary Medicines Regulations actually ask for.

Guide · Updated August 2026

UK veterinary practice

The legislation you are actually working to

In Great Britain the rules are the Veterinary Medicines Regulations 2013 (SI 2013/2033), in force since 1 October 2013, as amended. The most recent amendment is The Veterinary Medicines (Amendment etc.) Regulations 2024, in force 17 May 2024, with transitional provisions in its Part 10.

One honest caveat, because it is better than a confident error: we are not citing a statutory instrument number for the 2024 amendment. Two candidate numbers appear in search results and neither could be confirmed against legislation.gov.uk during our research. If you need to cite the SI number in a standard operating procedure, take it from legislation.gov.uk directly rather than from anybody's summary, including ours.

Northern Ireland runs on a different rulebook

This is the single most consequential thing on this page for a practice with a Northern Ireland site. Under the Windsor Framework, EU Regulation 2019/6 on veterinary medicinal products applies in Northern Ireland, not the GB Veterinary Medicines Regulations 2013. EU Regulation 2019/4 covers medicated feed. Both jurisdictions also apply Regulation (EC) No 470/2009 on residue limits.

The difference that will catch a practice out is prescription validity. In Northern Ireland a prescription for an antimicrobial or antibiotic is valid for only five days from the date of issue. In Great Britain the same prescription can run for up to six months. A template, a practice management system default or a written protocol built for a GB site is wrong the moment it is used in Northern Ireland.

Illustrative example — the same prescription, two jurisdictions. A veterinary surgeon signs an antibiotic prescription on 1 June.

In Great Britain, unless a shorter period is specified, it is valid for up to six months — to 1 December. In Northern Ireland it is valid for five days from issue — to 6 June. If the same medicine were a controlled drug, the GB validity would be 28 days from the date of signing: June has 30 days, so 1 June plus 28 days is 29 June.

Same signature, same drug, three different expiry dates depending on the jurisdiction and the schedule. Figures are illustrative; the periods are not.

The four distribution categories, and who may do what

CategoryPrescribingSupply
POM-VVeterinary surgeon only. Requires a clinical assessment and the animal must be under their careA veterinary surgeon or a pharmacist
POM-VPSAny registered qualified person — veterinary surgeon, pharmacist or suitably qualified person. A clinical assessment does not have to be carried out and the animal does not have to be under the prescriber's careAny registered qualified person
NFA-VPSNo prescription requiredA veterinary surgeon, pharmacist or suitably qualified person, from authorised premises
AVM-GSLNo legal restrictions on retail supply

The POM-V / POM-VPS distinction is where compliance failures cluster, because the two look alike on a dispensing screen and are quite different in law. POM-V carries two separate conditions — a clinical assessment, and the animal under the prescriber's care. POM-VPS carries neither.

Veterinary surgeons must supply from premises registered with the RCVS as veterinary practice premises; pharmacists must use a pharmacy registered with the GPhC or the PSNI, or authorised veterinary practice premises. That is the same registration covered in our RCVS compliance guide, and it is the reason the premises register sits under the VMD rather than under professional regulation.

“Under their care” and “clinical assessment”: a guidance change, not a change in the law

Here is the point that gets written up wrongly more often than anything else in this area. The Veterinary Medicines Regulations do not define either term. VMD guidance expressly defers to the RCVS interpretation. So when the RCVS changed its interpretation, the effect on prescribing was immediate even though no legislation changed at all. Any copy — a supplier's briefing, a webinar slide, a policy note — that describes this as a change to the law is wrong.

The change was approved by RCVS Council on 19 January 2023, by 20 votes to 3, and took effect on 1 September 2023. What it actually says:

  • An animal is under a veterinary surgeon's care when they are given, and accept, responsibility for the health of that animal. A physical examination is no longer required to take an animal under care.
  • A clinical assessment is any assessment which provides the veterinary surgeon with enough information to diagnose and prescribe safely and effectively. It may include a physical examination; it need not.
  • A physical examination is still required in three situations, each except in exceptional circumstances: suspected notifiable disease; antimicrobials for non-agricultural animals; and controlled drugs on first prescription.
  • A veterinary surgeon with an animal under their care must be able, on a 24/7 basis, to physically examine that animal — either themselves or through another provider under a written agreement. For production animals, equines, farmed aquatic animals and game the obligation is to be able to visit the premises.

The 24/7 limb is the one with commercial consequences. It attaches to the veterinary surgeon who accepted responsibility, not to the practice, and it can only be discharged through someone else on the strength of a written agreement. That makes the out-of-hours contract a prescribing document as well as a rota document — and the CMA's draft Order reaches into out-of-hours contract terms from the day it is made, as set out in our CMA remedies guide.

Prescription validity

  • Six months as standard from the date of signing, unless the prescriber specifies a shorter period.
  • 28 days if the medicine is a controlled drug.
  • Five days in Northern Ireland for an antimicrobial or antibiotic.

A prescriber can always specify shorter. Nobody can specify longer.

The five-year records, field by field

For documents relating to the receipt or supply of POM-V and POM-VPS products, you keep the record for five years, and the record has to carry:

  • the date;
  • the name of the veterinary medicine;
  • the batch number;
  • the quantity;
  • the name and address of the supplier or recipient;
  • the name and address of the prescriber;
  • a copy of the prescription, where there was a written one.

Two further records sit alongside those, and both are commonly missing:

  • The reason for prescribing without a written prescription. Where a POM-V or POM-VPS is prescribed and no written prescription is issued, the prescriber must record the reason for prescribing, and keep it five years. Most in-practice dispensing happens without a written prescription, so this is not an edge case — it is the default path, and it needs a field in the practice management system rather than a habit.
  • Antibiotic prescribing. A veterinary surgeon prescribing an antibiotic veterinary medicine must record the details of fulfilling the conditions, and keep that record at least five years.

Batch number is the field that most often defeats a retrospective reconstruction. If it is not captured at the point of dispensing it generally cannot be recovered later, and a five-year retention obligation on a record that was never complete is not satisfied by keeping the incomplete version.

The annual audit almost nobody has minuted

Anyone involved in the retail or wholesale supply of POM-V and POM-VPS veterinary medicines must carry out an audit at least once a year. That is every practice that dispenses.

It is a short obligation with a long tail, because an audit that has not been written down did not happen as far as an inspection is concerned. Give it a date in the practice year, a named owner, and a one-page output that records: stock reconciled against receipt and supply records, discrepancies identified and explained, expired stock accounted for, controlled drug records checked, and the actions taken. Then keep it. A practice accredited under the Practice Standards Scheme is exempt from a separate VMD inspection because the PSS assessment includes a medicines module — but exemption from the inspection is not exemption from the audit.

Food-producing animals

Where the animal is food-producing, the veterinary surgeon must either enter the required information in the keeper's own records personally, or give it to the keeper in writing. The keeper then keeps those records for at least five years. For a mixed small-animal and farm practice this is a second, parallel record trail, and the practical failure is assuming the practice's own five-year record discharges the keeper's.

The Register of Online Retailers, and the scheme that is closing

The VMD publishes and maintains a Register of Online Retailers of veterinary medicines. This is not a background detail: the CMA's draft Article 8 requires first opinion practices to publish a parasiticide price list and link to that register. So the register moves from being something a practice can ignore to something it has to point its own clients at.

The older Accredited Internet Retailer Scheme — voluntary and free, open to registered veterinary practice premises, registered pharmacies and approved suitably qualified person retailers — continues to exist in parallel, but the VMD will not consider further applications to be added to it. If your practice sells online and is not already accredited, the AIRS route is not available; the Register of Online Retailers is where you belong.

Getting the record straight without adding a system

  • Make the seven fields mandatory in the dispensing screen, especially batch number. A field that can be skipped will be skipped on a busy Saturday.
  • Add a “reason for prescribing” field that fires whenever a POM-V or POM-VPS goes out without a written prescription. This is the most commonly missing record in the whole regime.
  • Diarise the annual audit with a named owner and a one-page written output, and keep the outputs together so five years of them can be produced in one go.
  • Separate your Northern Ireland protocols if you operate there. Five days for antimicrobials, and EU Regulation 2019/6 rather than the GB Regulations.
  • Write the 24/7 physical-examination arrangement down. If another provider discharges it, the RCVS interpretation requires a written agreement.
  • Reconcile the premises list to the RCVS register each March, before the 1 April renewal, so no dispensing point is unregistered.

What we do with this. We do not write your clinical protocols and we do not advise on prescribing. What we do is make the money side of the dispensary legible: stock and dispensing reconciled to the ledger so the annual audit has something to reconcile to, margin visible by product group rather than buried in one purchases figure, and the parasiticide and prescription lines separated out so the CMA publication duties can be costed before they are published. That runs through our practice accounts and tax service and, on the systems side, Xero alongside your practice management system.

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Quick answers

Frequently asked

How long must a veterinary practice keep medicines records?

Five years. Documents relating to the receipt or supply of POM-V and POM-VPS veterinary medicines must be kept for five years and must record the date, the name of the medicine, the batch number, the quantity, the name and address of the supplier or recipient, the name and address of the prescriber, and a copy of the prescription where one was written. Two further five-year records sit alongside that: the reason for prescribing where a POM-V or POM-VPS is supplied without a written prescription, and the details of fulfilling the conditions when a veterinary surgeon prescribes an antibiotic. Batch number is the field most often missing, and it usually cannot be reconstructed later.

Did the law on “under my care” change?

No. The Veterinary Medicines Regulations do not define either “under their care” or “clinical assessment”, and VMD guidance defers to the RCVS interpretation of both. That interpretation changed with effect from 1 September 2023, after RCVS Council approved it on 19 January 2023, but the legislation did not change. Under the current interpretation a physical examination is no longer required to take an animal under care, and a clinical assessment is any assessment giving the veterinary surgeon enough information to diagnose and prescribe safely and effectively. Anything describing this as a statutory change is wrong, which matters if you are drafting a practice protocol from someone else's summary.

When is a physical examination still required before prescribing?

Under the RCVS interpretation in force since 1 September 2023, three situations still require a physical examination, each except in exceptional circumstances: suspected notifiable disease; antimicrobials prescribed for non-agricultural animals; and controlled drugs on first prescription. Separately, a veterinary surgeon who has an animal under their care must be able, on a 24 hours a day and seven days a week basis, to physically examine that animal, either personally or through another provider under a written agreement. For production animals, equines, farmed aquatic animals and game the equivalent obligation is to be able to visit the premises where the animal is kept.

How long is a veterinary prescription valid for?

In Great Britain a written prescription is valid from the date of signing for up to six months as standard, or up to 28 days if the medicine is a controlled drug, unless the prescriber specifies a shorter period. The prescriber can always shorten the validity but never extend it. Northern Ireland is different because EU Regulation 2019/6 applies there under the Windsor Framework rather than the Veterinary Medicines Regulations 2013: a prescription for an antimicrobial or an antibiotic is valid for only five days from the date of issue. Any prescribing template or practice management system default built for a GB site will be wrong if used in Northern Ireland.

Does a dispensing practice have to carry out an annual medicines audit?

Yes. Anyone involved in the retail or wholesale supply of POM-V and POM-VPS veterinary medicines must carry out an audit at least once a year, which covers every practice that dispenses. The obligation is short but easy to fail, because an audit that was not written down cannot be evidenced. Give it a fixed date in the practice year, a named owner and a one-page written output covering stock reconciled to receipt and supply records, discrepancies explained, expired stock accounted for and actions taken. Practice Standards Scheme accreditation exempts a premises from a separate VMD inspection because the assessment includes a medicines module, but it does not remove the audit.

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