The UK roadmap: will it work?
On November 11th 2025, the UK Government published its long-awaited strategy, ‘Replacing animals in science’. Addressing both regulatory and ‘discovery’ research, it includes a range of measures to help embed non-animal methods across the research system and commits to targets for phasing out a number of outdated animal tests. With substantial funding, a ministerial committee and cross departmental working to ensure delivery, as well as key performance indicators to monitor progress in delivering objectives, the roadmap signals a shift in UK animal research policy, with the government recognising that the benefits of the strategy include scientific advances as well as economic impact.
The commitments to immediately commence phasing-out a number of specific animal tests (e.g. the rabbit pyrogen test, adventitious agent testing in animals, in vivo skin irritation testing, eye irritation testing, skin sensitisation testing, botulinum toxin and batch potency testing) are positive and to be welcomed. However, most of the tests destined for phase-out are within the regulatory sphere, with fewer in the basic research context destined for phase-out (e.g. the forced swim test), despite this being where most animals are used. The problem is that replacing animals with new technologies at one end of the pipeline – the regulatory end – doesn’t prevent them from being fed in at the other end – the basic research end. Scientists are constantly developing new animal models, or modifying existing ones, and unless there are specific phase-out measures in basic research, animals will continue to enter the research pipeline, meaning that human biology-based technologies will be used alongside, rather than instead of, animal research.
So what does the roadmap have to say about phasing-out animal use in the basic sciences? Does it contain any measures to disincentivise animal use in this context? In the section ‘Driving alternative method development and uptake in discovery research’ the government sets out eight measures, most of which are explicit phase-in measures, i.e. the creation of a preclinical translational models hub, increased governmental funding for ‘alternative methods’ in ‘discovery research’, foundational training in ‘alternative methods’ for early career researchers, the biennial publication of a list of ‘alternative methods research and development priorities’, and increased scope for the NC3Rs gateway.
Then there are measures which appear to be phase-out measures but which on closer examination also turn out to be phase-in measures. For example, ‘Enable funders to thoroughly scrutinise animal research submissions’ sounds like a measure for weeding out applications to conduct animal research. However, it turns out to consist solely of incentives for adopting human biology-based methods, with no disincentives to using animal experiments. UKRI’s new Policy on Research and Innovation Involving Animals is referred to, but UKRI’s policy does nothing to compel applicants to reduce or cease animal use. And the government ‘expects’, rather than ‘requires’ UKRI to prioritise applications proposing human-relevant research. The government also states that it will work with funders (e.g. medical research charities, UKRI, and NC3Rs) to ‘empower’ reviewers and panels to support the phasing-in of scientifically robust ‘alternative’ methods, with training, guidance and resources provided. But no support for phasing-out animal experiments, such as training in animal methods bias, is mentioned. And, if the government is working with medical research charities to support phasing-in new methodologies, they will surely need to ask the Association of Medical Research Charities (AMRC) to drop the requirement that all their member charities support the principle of using animals in research.
The commitment to reform regulation by fully implementing the Rawle report recommendations, likewise sounds like a phase-out measure, raising hopes for a tightening up of the approval process. In practice, however, most of the Rawle report’s recommendations are phase-in measures, heavily reliant on the 3Rs. In reality, only one of the eight measures listed in the roadmap’s section on discovery research appears to take a phase-out approach and that is the measure to strengthen the commitment of journal editors to publishing research using ‘alternative’ methods. This relies on new policies that discourage comparison with animal model data, and includes monitoring of the number of animal and non-animal articles published. It is to be welcomed, although training in animal methods bias will also be necessary.
The proposed phase-in measures will undoubtedly increase the development and uptake of human biology-based methodologies and this is hugely positive. However, there is very little to prevent animal researchers from continuing to conduct animal experiments at the same time. A transformative governance approach introduces measures to drive innovation as well as measures to disrupt the current system. Unfortunately, this roadmap contains too few measures to disrupt the current system within the basic sciences. Moreover, it explicitly endorses the current system and neglects to acknowledge that the roadmap has become necessary because the limitations of preclinical animal research have been recently laid bare. Undoubtedly the government has taken this position in order to avoid alienating the animal research community, but the consequence is a roadmap that continues to condone animal research and present it as scientifically legitimate. This position is underlined by extensive use of the term ‘alternatives’ as well as many unsubstantiated claims about the benefits of animal research. Consequently, despite appearances, the roadmap fails to signal a clear paradigm change; indeed the Ministerial Foreword asserts that the government ‘will continue to support and enable well justified and designed animal research where alternatives do not exist,’ a statement that can hardly be regarded as progressive.
Unsurprisingly then, scientists using animals and their representatives are fully supportive of the roadmap, happily foreseeing a future in which animal research and human biology-based research continue in tandem:
‘(…) the reality is that animal research will remain important for many years to come. The government strategy recognises this, acknowledging the need for animal research in parallel with the drive, coordination and funding required to achieve the ethical, scientific and economic benefits that innovations in animal alternatives can bring.’ Vicky Robinson, NC3Rs.
‘The strategy recognises, as with any transition, that this is not an ‘either or approach’. Both animal research and non-animal methods must go hand-in-hand to achieve advances in biomedical science.’ Professor Sarah Bailey, Department of Life Sciences, University of Bath.
So will the roadmap work? It depends. If the aim is to phase-in human biology-based technologies, then it is likely to work. But if the aim is to replace animal experiments with these technologies, then it will not work without much more attention to phase-out measures, particularly in the basic sciences. Consequently, we ask the government to:
- Implement phase-out measures within the basic sciences, including the following:
- divert funding away from animal studies,
- instigate training in animal methods bias for funders (medical charities, UKRI, NC3Rs), funding panel members, reviewers of grant applications, journal editors, peer reviewers, and members of Animal Welfare and Ethical Review Boards (AWERBs), the Animals in Science Committee (ASC) and the Animals in Science Regulation Unit (ASRU),
- ask the AMRC to drop their requirement for all their member charities to support the principle of using animals in research,
- place experts in human-biology-based methodologies on funding panels, journal editorial boards, AWERBs, ASRU and the ASC,
- create disincentives to conducting animal studies, such as raising Project Licence fees,
- tighten the approvals process to encourage ASRU to reject unjustifiable applications to conduct animal studies,
- phase-out the use of animals throughout the entire education system, from schools to postgraduate degrees, and
- create an ambition for a total phase-out of animal use in science, with a target date.
- ‘Require’, rather than ‘expect’ UKRI to prioritise applications proposing human-relevant research.
- Involve a wide range of stakeholders going forward, with all actors being enabled to contribute equally, so that those favouring the status quo do not have the loudest voice.
