Draft Dogs Law (Jersey) Amendment Regulations 202- (P.63/2025): comments

STATES OF JERSEY

DRAFT DOGS LAW (JERSEY) AMENDMENT REGULATIONS 202- (P.63/2025):COMMENTS

Presented to the States on 7th November 2025

by the Environment, Housing and Infrastructure Scrutiny Panel

STATES GREFFE

2025  P.63 Com.(2)

COMMENTS

The Environment, Housing and Infrastructure Scrutiny Panel (hereafter the Panel') previously lodged Comments on 3rd October 2025 (P.63/2025.Com) regarding the Draft Dogs Law (Jersey) Amendment Regulations 202- (P.63/2025) (the Proposition'). Following the publication of those Comments, the Comité des Connétable s deferred the debate to the States sitting of 11th November 2025 to allow for further consideration of matters raised by the Panel and other stakeholders.

The Panel subsequently held a public hearing with representatives of the Comité des Connétable s, Parish Secretaries, and the States Veterinary Officer on 24th October 2025 (the Public Hearing'). The  Panel convened this hearing after noting that several proposed amendments affecting all dog owners had not been made explicit during previous briefings or communications. The Panel considered it important to bring these matters to light and to provide an opportunity for the Comité and officers to explain, in a public forum, the rationale behind the proposed changes.

This Comments Paper should be read in conjunction with the Panel's initial Comments (P.63/2025.Com) to gain a complete picture of the Panel's scrutiny of the Proposition. The Panel's primary commentary on its support for the provisions relating to dangerous dogs and the new registration scheme is contained within that earlier paper, while this paper focuses on the developments, clarifications, and commitments made during the Public  Hearing  and  as  reflected  in  the  Comité's  subsequent  amendment  to  the Proposition.

Public Hearing Findings

During the Public Hearing, the Panel heard that the revisions to Regulation 6 – Wearing of Collars by Dogs to substitute the owner's name, address and telephone number with the dog's name, licence number and owner's telephone number was to address potential data protection concerns, while ensuring each dog remains identifiable through the parish licensing database, which holds the relevant ownership and contact details.

However, the Comité and its representatives noted their intention to bring forward an amendment so that owners would not be required to replace or update all existing dog tags by 1st February 2026. The Panel welcomed this clarification, recognising that the original proposal could have created unnecessary financial costs for dog owners and placed an avoidable administrative burden on parishes, increasing the risk of non- compliance or delayed implementation.

The Panel also raised concerns with the Proposition's revisions to Regulation 9 – Worrying of Livestock by Dogs during the Public Hearing, with the Comité agreeing that the inclusion of "damage to agricultural land" had not been robustly consulted upon nor defined. It was clarified by the Comité that the original intent of the amendment had been to address the risk of disease transmission between dogs and livestock, rather than physical damage to land.

As such, the Comité confirmed its intention to remove the amendments to Regulation 9 and to undertake a consultation-led review of livestock worrying provisions within the Dogs  (Jersey)  Law  1961  and  Animal Welfare  (Jersey)  Law 2004, engaging with

stakeholders from the farming community to ensure that any future amendments are evidence-based.

The Panel also questioned the existing provisions for dealing with dogs dangerously out of control. The Comité acknowledged that, while Regulation 11 of the Dogs (Jersey) Law 1961 provides a route through the Magistrate's Court, this process may not be easily accessible to the public. The Comité acknowledged that some lower-level cases could be better addressed locally through the Parish system, and the Panel welcomed the Comite's confirmation that it would review the current provisions to ensure there is a clear and practical process for managing such cases in future.

Outcomes Since the Public Hearing

Following the public hearing, an amendment was lodged by the Comité des Connétable s on  28th  October  2025  (P.63/2025.Amd.)  (the  Amendment')  which  amends  the following provisions of the Proposition:

• Regulation  6:  From  the  date  the  amendments  come  into  force,  new  or replacement  dog  collars,  plates,  or  badges,  and  all  first  licences  issued thereafter, must display the dog's name, licence number, and owner's telephone number, instead of the owner's name, address, and telephone number. Existing collars, plates, or badges will only need to be updated if the information displayed changes or a replacement is required.

• Regulation 9: Removing the proposed amendments to the livestock worrying provisions and reverting to the original wording contained in the Dogs (Jersey) Law 1961.

• Regulations 15 and 16: Consequential removals of references to the Regulation 9 amendments.

The Panel is satisfied that the Amendment lodged by the Comité des Connétable s (P.63/2025.Amd.) reflects the assurances given during the Public Hearing and directly address the key issues previously raised.

In respect of Regulation 6, the Panel agrees that the revised approach provides a balanced and proportionate solution, addressing potential data protection concerns while maintaining clear mechanisms for dog identification. By linking the licence number on the collar to the parish licensing database, the change ensures that authorised officers  can  access  the  necessary  ownership  details  without  requiring  personal information to be publicly displayed. Existing tags will only need to be updated if the information changes or a replacement is required, and the Panel welcomes the decision not to require all tags to be replaced by February 2026, recognising that this will minimise unnecessary costs for owners and reduce administrative burden for parishes. The Panel further notes that the Amendment sets out a minimum requirement for the information to be displayed, and that owners may still include additional details, such as their address, should they wish to do so.

Regarding Regulation 9, the Panel welcomes the Comité's Amendment, which returns the provision to the original wording of the Dogs (Jersey) Law 1961, removing the expanded definition of "damage to agricultural land" that had been proposed in the

Proposition.  This  reflects  recognition  that  the  revised  definition  requires  further consultation  and  clearer  drafting.  The  Panel  considers  this  a  responsible  and proportionate response to the feedback provided by farmers, the States Veterinary Officer, and the Panel itself.

The Panel also supports the consequential amendments to Regulations 15 and 16, which appropriately remove references to the withdrawn Regulation 9 amendment.

Remaining Considerations

The Panel recognises that the Amendment lodged by the Comité des Connétable s (P.63/2025.Amd.) has addressed a number of the immediate issues raised through the scrutiny  process.  However,  the  Panel  remains  concerned  about  the  adequacy  of consultation and that several changes were not made sufficiently clear to the Panel or States Members during the initial briefing stages.

Furthermore, on 6th November 2025, the Panel received a submission from the Jersey Society for the Prevention of Cruelty to Animals (JSPCA) regarding the apparent lack of consultation on matters relating to dangerous dogs. While the Panel's previous Comments highlighted consultation issues more broadly, it considers appropriate to clarify that consultation with the JSPCA did not take place in the development of the relevant provisions. The Panel recognises that the JSPCA's role as both an enforcement and welfare organisation provides a distinct operational perspective that could have informed the drafting of these amendments.

The JSPCA's submission also states that the States of Jersey Police were also not consulted with on the Proposition. In respect of consultation with the States of Jersey Police, the Panel sought clarification during the Public Hearing and was informed that the Comité had met with two senior officers to discuss the proposed amendments. The Comité stated that the Police were aware of the changes, had expressed some practical concerns about managing cases involving dangerously out-of-control dogs, but were generally  supportive  of  the  dangerous  dog  provisions.  The  Panel  welcomes  this clarification but considers that the engagement described was limited in scope and should have been more formally structured given the enforcement implications of the proposed changes.

The Panel also notes the JSPCA's concerns that the proposed approach to regulating dangerous dogs appears to focus on breed-specific restrictions rather than on the behaviour of the individual dog or the actions of the owner. During the Public Hearing, the Panel questioned the Comité des Connétable s and the Chief States Veterinary Officer on this matter, seeking clarification on why a breed-specific approach had been pursued rather than one focused on owner responsibility or dog behaviour. The Chief States Veterinary Officer acknowledged that the issue was contentious and that there may be no definitive "right" answer, but stated that, based on the evidence currently available, the proposed approach was considered the most pragmatic means of reducing risk.

However, no clear justification was provided by the Comité as to why this approach had been  chosen,  nor  whether  alternative,  behaviour-focused  frameworks  had  been considered during the policy development process. The Panel considers that this issue

warrants  careful  justification,  given  the  JSPCA's  reference  to  the  evidence  base indicating that behaviour and ownership practices are more reliable predictors of risk than breed alone. The Panel therefore recommends that the Comité set out the evidence base and reasoning underpinning its chosen approach and clarify the extent to which other frameworks were assessed.

The Panel also urges the Comité to proceed with its stated commitment to review Regulation 9 – Livestock Worrying by Dogs and the general control of dogs, including the  consistency  of  enforcement  and  public  education  across  parishes.  The  Panel considers  this  review  essential  to  addressing  long-standing  gaps  in  practical enforcement and ensuring that the Dogs (Jersey) Law 1961 remains clear, enforceable, and fit for purpose.

Finally, during the Public Hearing, it was acknowledged by the Comité that the legal framework governing dogs has become increasingly complex: spanning multiple pieces of legislation including the Dogs (Jersey) Law 1961, Animal Welfare (Jersey) Law 2004, Policing  of  Beaches  (Jersey)  Regulations  1959,  and  Policing  of  Parks  (Jersey) Regulations 2005. The Panel emphasises that any future amendments or reforms in this area should ensure a joined-up approach across all related laws to avoid creating gaps, overlaps, or inconsistencies in how dog ownership and control are regulated.

Conclusion

While the Panel welcomes the corrective steps taken through the lodged Amendment (P.63/2025.Amd.) and the clarification provided during the Public Hearing, it remains concerned that the  process  underpinning the  development of the  Proposition was insufficiently consultative and evidence led.

As such, the Panel expects the Comité des Connétable s to address the concerns raised by the JSPCA, to provide a clear justification for the policy direction taken on dangerous dogs, including the emphasis on breed-specific restrictions, and to confirm the extent and nature of consultation undertaken with relevant enforcement and welfare bodies, including the States of Jersey Police and the JSPCA.