REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the evaluation of Regulation (EU) 2016/429 on transmissible animal diseases and amending and repealing certain acts in the area of animal health ('Animal Health Law')
Date: 2026-07-06
Institutions: Directorate-General for Health and Food Safety, European Commission
Subjects: animal disease, disease prevention, epidemic, health risk, protection of animal life, veterinary inspection, veterinary medicine

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 6.7.2026  COM(2026) 352 final  REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the evaluation of Regulation (EU) 2016/429 on transmissible animal diseases and amending and repealing certain acts in the area of animal health ('Animal Health Law') {SWD(2026) 179 final}  
 
 
INTRODUCTION 

Under  Article  282  of  Regulation  (EU)  2016/429  on  transmissible  animal  diseases  ('Animal 
Health Law')1 the European Commission (‘The Commission’) must carry out an evaluation of 
that Regulation and delegated acts referred to in Article 264 of that Regulation and submit the 
results of the evaluation in a report to the European Parliament and the Council. This present 
document is intended to comply with this legal obligation and to serve as a report. 

Accordingly, this report draws from the conclusions and lessons learnt and obtained throughout 
the evaluation process. It builds on the results presented in Staff Working Document on the 
evaluation of the Animal Health Law (AHL) and further outlining specific areas of particular 
attention and certain future actions to be taken by the Commission and Member States.  

2. BACKGROUND, SOURCES AND POLICY CONTEXT  

Transmissible animal diseases do not respect borders, and even if they mainly affect animals 
and  cause  economic  losses,  some  of  them  may  also  affect  humans.  Harmonised  rules  with 
measures to control such animal diseases are regulated in the EU for decades, e.g. some of the 
first acts on animal health were adopted as far back as in 1964. With the introduction of the EU 
Single market, these rules were further expanded and reinforced in the 90’s of the last century. 

The AHL was adopted in 2016, entered into force on 21 April 2016 and applies from 21 April 
2021. It aims to provide for a simpler and more flexible regulatory framework, ensuring a risk-
based  approach  to  set  out  animal  health  requirements,  enhanced  disease  preparedness, 
prevention and control for listed transmissible animal diseases. 

In addition, it reduces the administrative burden for farmers, other operators and competent 
authorities without compromising animal health status in the Union. Furthermore, it provides 
more suitable tools to deal with sanitary crises (e.g. emerging diseases) or to address specific 
circumstances and contributes to less economic losses due to disease outbreaks. 

This  regulatory  framework  was  adopted  as  a  result  of  the  EU  Animal  Health  Strategy: 
‘Prevention is better than cure’2 which followed a comprehensive evaluation of the EU Animal 
Health Policy (CAHP) 1995-2004 and alternatives for the future3. 

The AHL replaced 39 separate legal acts and introduced a single, harmonised and risk-based 
framework for animal health across the European Union. The reform introduced a modernised 
system  of  risk-based  measures  (e.g.  disease  categorisation),  clearer  allocation  of 
responsibilities  among  competent  authorities  and  operators,  enhancing  prevention,  most 
particularly with strengthened biosecurity, reinforced preparedness, enabling vaccination and 
upgrading contingency planning requirements. These are the core tools for disease control and 
the structured use of regionalisation to ensure trade continuity. 

1  

2  
3  

Regulation  (EU)  2016/429  of  the  European  Parliament  and  of  the  Council  of  9  March  2016  on 
transmissible  animal  diseases  and  amending  and  repealing  certain  acts  in  the  area  of  animal  health 
(Animal Health Law), OJ L 084 31.3.2016, p. 1. 
EU Animal Health Strategy 2007-2013 - Food Safety - European Commission. 
CAHP evaluation Final Report-Part I final.doc. 

1 

 
 
This  architecture  enables  the  AHL  to  implement  the  principle  of  ‘prevention  is  better  than 
cure’, as set out in the 2007 EU Animal Health Strategy4. It represents a transition from reactive 
crisis  management  to  a  proactive,  risk-based  approach  that  incorporates  surveillance, 
preparedness,  prevention,  early  detection,  rapid  response,  and  recovery  measures  within  a 
unified legislative framework. 

The  AHL  also  contributes  to  broader  Union  policy  objectives.  It  supports  the  One  Health 
approach by addressing the link between animal health, public health and the environment. It 
aligns with the broader EU objectives by promoting sustainable and resilient agri-food systems. 
Furthermore, it promotes sustainable competitiveness of the agri-food sector and strengthens 
crisis resilience within the internal market by ensuring harmonised standards and coordinated 
responses to transboundary animal diseases. 

The Commission evaluated the Regulation (EU) 2016/429 in accordance with the EU Better 
Regulation  Principles  and  presented  the  results  in  the  Staff  Working  Document  on  the 
evaluation of the AHL and its supporting study5. The evaluation assesses the extent to which 
the  AHL  has  achieved  its  objectives  since  its  entry  into  force  on  21  April  2016,  and  more 
specifically after becoming applicable on 21 April 2021. The study covered the period until 31 
December 2023, while the Staff Working Document includes some more recent experiences 
including until early 2026. Both documents draw on extensive evidence, including monitoring 
data and stakeholder input collected through multiple consultations conducted as part of the 
study and beyond, notably the CVO forum, Animal Health Advisory Committees, and other 
expert  groups.  The  evaluation  also  relies  on  Member  State  implementation  reports  and 
notifications, Commission audits, data from the Animal Disease Information System (ADIS), 
European  Food  Safety  Authority  (EFSA)  scientific  opinions,  and  findings  from  the  EU 
Veterinary Emergency Team (EUVET). 

Overall, the results indicate that the AHL has mostly reached its main objectives, although with 
a certain level of variation. The regulation is viewed by all key stakeholders as creating a strong 
foundation for a harmonised animal health policy in the EU. 

3. SUMMARY OF THE MAIN FINDINGS, LIMITATIONS 

During the evaluation period, stakeholders and Member States faced several implementation 
challenges. Although the AHL establishes a harmonised framework, its application across the 
Union has not been uniform. As described in the SWD the consultation performed through the 
supporting study indicates that differences in administrative capacity, governance structures, 
and  resources  have  affected  the  pace  and  extent  of  national  alignment,  with  some  Member 
States  still  to  finalise  the  necessary  adjustments.  The  complexity  of  the  legal  framework, 
including its delegated and implementing acts, has been highlighted as demanding, particularly 
for  smaller  operators.  Differences  in  interpretation  and  enforcement  practices  influence  the 
perception of equal treatment among stakeholders. These findings must be interpreted in light 
of  important  limitations.  The  AHL  has  been  applicable  only  since  April  2021,  providing  a 
relatively  short  timeframe  to  assess  structural  and  long-term  impacts.  National  alignment 

4  

5  

https://food.ec.europa.eu/document/download/7820a76d-d19d-4a35-b223-
caae0f7143da_en?filename=ah_policy_strategy_2007-13_en.pdf. 
https://data.europa.eu/doi/10.2875/0446681 

2 

 
 
progressed  at  varying  speeds,  and  in  several  cases  pre-existing  rules  continued  to  apply 
alongside AHL requirements, making attribution of impacts difficult.  

The evaluation period also coincided with the COVID-19 pandemic, geopolitical disruptions, 
increased costs and significant disease outbreaks, including highly pathogenic avian influenza 
and African swine fever. These factors make it difficult to attribute impacts and limit drawing 
definitive conclusions. The evaluation still provides early, indicative insights although a more 
robust assessment will require additional time and data. 

3.1 EFFECTIVENESS 

The AHL has been widely acknowledged as a significant step forward in harmonising the EU’s 
approach  to  animal  health,  moving  from  a  reactive  to  a  preventive  system.  The  current 
effectiveness  of  the  AHL  must  be  assessed  in  light  of  its  ongoing  implementation.  Most 
Member  States  have  not  yet  completed  the  alignment  of  their  national  legislation  with  the 
Regulation, with some showing substantial progress. For example, the Commission analysis of 
Member States’ transposition of penalties according to the AHL shows that by June 2023 only 
10 Member States reported that they have adopted, or were working on, rules which include 
penalties applicable to infringements of the AHL. Delays are due to the complexity of national 
legal  systems  and  administrative  structures.  In  addition,  adapting  to  the  new  approach 
introduced by the AHL will take time for all actors to master and therefore affects stakeholders´ 
perception of its effectiveness. This also explains the progressive transition.  

The  AHL  has  introduced  a  structured  and  science-based  system  for  disease  categorisation. 
Transmissible  animal  diseases  are  listed  under  five  categories  (A  to  E)  based  on  their 
epidemiological profile, impact, and type of measures to be implemented to address them. This 
categorisation enables proportional responses and prioritisation of resources, allowing Member 
States to tailor their surveillance and control strategies to national contexts. This approach is 
broadly supported but concerns remain about the system's responsiveness to emerging threats 
and  the  need  for  more  frequent  updates,  particularly  considering  climate-driven  changes  in 
disease dynamics.  

The  AHL  emphasises  prevention  through  enhanced  biosecurity.  The  regulation  establishes 
clear responsibilities for operators and competent authorities, requiring the implementation of 
biosecurity measures at the farm level and across the production chain. While this has improved 
awareness and risk mitigation, implementation remains uneven between different operations 
(e.g.  large  vs.  small  scale).  The  lack  of  harmonised  guidance  and  training  has  further 
complicated the uptake in some Member States. 

The reinforcement of stakeholder roles and shared responsibilities is another key feature. The 
regulation clarifies the duties of farmers, veterinarians, competent authorities, and other actors 
in the animal health chain. This has improved coordination and accountability, particularly in 
disease  notification,  surveillance,  and  outbreak  response.  However,  the  evaluation  study 
highlights6  the need for broader awareness on the responsibilities of each actor and capacity-
building, especially among smaller operators and non-authority stakeholders. Despite EU-level 
training initiatives as part of the Better Training for Safer Food initiative, dissemination at the 
national level remains limited, and many stakeholders report difficulties in navigating the legal 

6  

External study, p 84. 

3 

 
 
framework  and  understanding  their  obligations.  In  this  regard,  contingency  planning  and 
simulation exercises can also play a role in involving operators and increasing awareness.  

Delays  in  the  alignment  of  national  legislation  have  led  to  differences  in  the  application  of 
certain new provisions, such as those on  risk-based animal health visits. These visits are an 
important  tool  for disease prevention and early detection.  While some Member States have 
integrated  these  visits  into  existing  programmes,  the  extent  to  which  this  provision  is 
implemented remains difficult to assess due to a lack of data. In addition, a lack of enforcement 
mechanisms  and  shortages  in  veterinary  personnel,  particularly  in  rural  and  remote  areas, 
further undermine full implementation. 

The AHL strengthens the EU’s capacity to control and eradicate diseases through structured 
eradication  programmes  and  the  recognition  of  disease-free  areas7,  which  are  essential  to 
maintain  safe  trade  and  reduce  the  burden  of  endemic  diseases.  However,  uneven  national 
implementation  has  limited  their  full  potential.  Importantly,  the  use  of  regionalisation  has 
avoided major disruption of trade flows during outbreaks. The AHL allowed Member States to 
apply targeted restrictions rather than blanket bans, enabling the safe movement of animals and 
products from disease-free zones.  

The evaluation recognised and welcomed the paradigm shift of the AHL which provides for a 
wider and more flexible use of vaccination against animal diseases. The AHL has clarified the 
conditions under which vaccination can be used as a preventive or emergency measure. This 
has enabled more strategic deployment of vaccines, such as in the case of Highly Pathogenic 
Avian  Influenza  (HPAI)8,  where  targeted  vaccination  campaigns  have  helped  to  reduce 
outbreak  severity  and  limit  economic  losses.  This  new  policy  contributed  importantly  to 
limiting negative effects of several animal diseases. Most often mentioned examples are HPAI, 
with recent preventive vaccination in France since 2024, bluetongue virus (BTV) in several 
Member States, lumpy skin diseases (LSD) in Italy, France and Spain in 2025-2026 as well as 
foot and mouth diseases (FMD) in Slovakia, Hungary (2025) and Cyprus (2026). However, 
some called for broader  support  for vaccination,  such as  expanded EU antigen and vaccine 
banks  beyond  only  Category  A  diseases  and  called  for  a  more  structured  and  coordinated 
vaccination plan against animal diseases in the EU. 

The upgrade of digital tools such as TRACES for traceability and animal movements and ADIS 
for reporting and notification are seen as an improvement and have been recognised as a step 
forward in simplifying procedures, although technical and interoperability issues persist9. 

While  the  implementation  of  the  AHL  has  aimed  to  harmonise  and  simplify  animal  health 
requirements  across  the  EU,  some  unintended  effects  have  been  observed,  particularly  for 
small-scale operators, such as hobby keepers. In particular, in certain cases, the requirements 
introduced at the national level, which sometimes go beyond what is set by the AHL, have 
resulted in increased administrative and financial burdens. Additionally, while the AHL does 
not regulate financial support, the lack of adequate compensation mechanisms has been noted 
by stakeholders as a barrier to effective implementation. 

7  
8  
9  

External study, p 111. 
SWD, point 2.3.3. 
External study, Point 4.12. page 69. 

4 

 
 
The AHL effectiveness is evident in areas where implementation has progressed, particularly 
in  disease  categorisation,  risk-based  surveillance,  biosecurity,  and  eradication  efforts. 
However,  overall  the  implementation  is  still  in  a  transition  phase.  Continued  support  for 
Member States, simplification of legal instruments, and broader stakeholder engagement will 
be essential to fully  realise the regulation’s potential. As national systems continue to  align 
with the AHL, a more comprehensive assessment of its long-term impact will become possible. 

3.2 EFFICIENCY 

The evaluation of the AHL efficiency examines whether the costs incurred by Member States, 
stakeholders, and the Commission have been proportionate to the benefits achieved since its 
implementation. However, a significant limitation of the evaluation is that Member States have 
not yet fully aligned their national legislation with the AHL, nor fully utilised the flexibility 
offered by the AHL. As a result, it remains challenging to disentangle the impact of the AHL 
from that of not fully aligned national legislation. Additionally, several years may be required 
before the effects of the AHL are reflected in actual changes to animal health status, especially 
considering that external factors markedly influence the epidemiological landscape.  

Overall, the cost-benefit balance of the AHL is expected to be positive in the long term, though 
with important qualifications. In the short to medium term, the AHL has entailed substantial 
costs and administrative efforts for various stakeholders, and these upfront costs have in some 
cases been higher than initially expected. These costs and efforts are investments expected to 
yield  clear  future  benefits  in  disease  prevention  and  control,  regulatory  harmonisation,  and 
trade  facilitation.  Such  benefits  are  expected  to  grow  over  time.  The  AHL’s  emphasis  on 
prevention (e.g. biosecurity measures and surveillance) is  expected  to  reduce costly disease 
outbreaks in future years, leading to savings that justify the current expenditures. Nonetheless, 
the efficiency gains are not yet fully achieved, as the regulatory transition is still ongoing. In 
this early implementation phase, the AHL’s benefits have materialised unevenly, while certain 
costs are front-loaded. 

Some  National  Competent  Authorities  have  borne  substantial  one-off  and  ongoing  costs  to 
align national systems with the AHL. These include efforts to update or consolidate national 
legislation, upgrade IT systems (e.g. for disease notification and traceability), recruit or train 
staff, and communicate  new requirements to  stakeholders. Many national  authorities had to 
redirect significant resources to adapt their surveillance and reporting infrastructure.  

New  compliance  costs  for  operators  also  appeared.  These  stem  from  obligations  such  as 
enhanced disease surveillance and biosecurity, record-keeping for animal movements, and, in 
some cases, requirements such as animal health visits and registrations of new establishments. 
However, depending on the specific measures, they were not entirely new to all operators. For 
instance, some farmers in particular sectors and countries were already subject to animal health 
visits  prior  to  the  implementation  of  the  AHL,  either  due  to  national  legislation  or  to 
participation in private certification schemes. Consequently, the extent to which the AHL has 
introduced new costs varies across operators, sectors, and Member States. 

According to the study, the benefits observed or anticipated under the AHL include a more 
effective  and  efficient  disease  control  and  a  more  coherent  regulatory  environment.  By 
replacing 39 legal acts with a single regulation, the AHL was designed to streamline rules and 
reduce legal fragmentation. In principle, this consolidation has given more legal certainty and 
should  improve  clarity  and  save  administrative  effort  in  the  long  term.  Indeed,  many 

5 

 
stakeholders  report  that  having  a  unified  framework  has  improved  coordination  between 
authorities and stakeholders and facilitated a quicker, more unified response to transboundary 
disease threats. There is  evidence that the AHL’s measures  (such as risk-based surveillance 
and regionalisation) have helped contain recent animal disease incursions (e.g. avian influenza, 
African swine fever) more efficiently, thereby reducing the scale of culling, trade bans, and 
other  costly  emergency  measures.  Trade  data  and  stakeholder  feedback  indicate  that  the 
internal market has remained resilient. Intra-Union trade recovered strongly after 2021 despite 
ongoing outbreaks of animal diseases, suggesting that the AHL framework has supported trade 
continuity10. By harmonising standards and approaches across the EU, the AHL helps maintain 
trust in intra-EU trade of animals and animal products and prevents unjustified trade barriers 
during  disease  events  (use  of  disease  zoning/regionalisation  rather  than  nationwide  bans). 
These  benefits,  while  harder  to  quantify  immediately,  contribute  to  a  more  stable  and 
predictable operating environment for businesses and authorities. Taken together, the above 
elements  suggest  that  the  AHL  is  delivering  value  that  should,  over  time,  balance  out  the 
investments made. 

Despite  its  long-term  advantages,  certain  operators  claim  that  the  implementation  has 
introduced administrative burdens, particularly in the initial stage. They have raised concerns 
about  increased  paperwork,  the  complexity  of  new  procedures,  such  as  establishments 
registration,  record  keeping,  animal  health  visits,  and  overlapping  requirements  between 
national  and  EU  requirements.  Certain  target  groups  have  been  especially  affected.  In 
particular, small-scale farmers and hobby animal keepers have reported that complying with 
the AHL’s requirements (such as obtaining animal health certificates for animal movements, 
or  meeting  new  record-keeping  and  biosecurity  rules)  is,  in  their  view,  onerous  and 
disproportionate to the scale of their operations. Larger commercial operators also note some 
increased compliance costs, but these tend to be more easily absorbed in bigger businesses. 

The efficiency and cost-benefit experience of the AHL varies significantly between Member 
States  and  groups  of  operators.  Member  States  that  entered  the  AHL  era  with  a  developed 
veterinary  infrastructure,  advanced  IT  systems,  and  well-resourced  administrations  have 
generally  managed  the  transition  more  smoothly  and  even  capitalised  on  it.  For  example, 
countries that introduced a national computerised database for animal traceability ahead of the 
AHL  have  built  up  on  this  system  and  reported  improvements  in  surveillance  and  early 
detection  capacity.  This  example  highlights  that  where  investment  has  been  made  in 
infrastructure and capacity-building,  the AHL’s  operational  efficiency  can be  realised more 
effectively. By contrast, Member States with more limited resources or less developed systems 
have faced steeper challenges and higher relative costs. Such disparities also affect stakeholders 
like  farmers;  for  instance,  if  a  country  delays  rolling  out  updated  guidance,  farmers  and 
veterinarians in that country might struggle for longer with confusing procedures. 

Moreover,  the  distribution  of  costs  and  benefits  among  stakeholder  categories  also  varies 
depending on the extent Member States use the flexibility granted by the AHL11 12. In Member 
States that did not fully embrace a risk-based approach, the farming community felt a heavier 
burden. In other Member States that applied the flexibilities of the AHL to tailor measures to 
local risk (for example, exempting very small keepers from certain duties), the private sector’s 
burden was relatively lighter. These policy choices, along with differing economic structures 

10  
11  
12  

SWD, Point 4.1.1, page 44. 
External study, Annex 3, p. L 
SWD, point 4.1.2, p 46. 

6 

 
 
(large  commercial  farms  vs.  many  smallholders),  mean  that  the  AHL’s  efficiency  can  be 
viewed differently from one country or sector to another. 

3.3 COHERENCE 

The  evaluation  shows  that  the  AHL  is  internally  coherent.  Union  disease  listing  and 
categorisation determine the level of surveillance, movement conditions and control measures, 
creating  a  structured  link  between  risk  assessment  and  operational  response.  In  practice, 
however,  differences  remain  in  how  Member  States  design  surveillance  systems,  manage 
wildlife interfaces and apply derogations during outbreaks. As several Member States are still 
completing national alignment, full operational consistency has not yet been achieved. 

Externally, the AHL operates alongside other Union legislation in a complementary manner. 
The  Official  Controls  Regulation  provides  the  horizontal  framework  for  verification  and 
enforcement in the  EU  along  the  agri-food  chain.  The  AHL  acts  upstream  of  General  Food 
Law13  and  zoonoses  legislation14  by  addressing  animal  health  risks  before  they  affect  food 
safety or public health. It also aligns with the EU legislation on veterinary medicinal products15 
especially where vaccination or treatment forms part of disease control strategies. The AHL 
seeks  to  provide  a  coherent  application  of  ‘One  health’  concept,  addressing  the 
interconnections between animal and public health, wildlife, the environment, food and feed 
safety,  animal  welfare  and  taking  other  external  factors,  such  as  food  security,  economic 
factors, social issues into consideration16. 

Consistency with food safety and animal welfare legislation is overall assessed as strong  17, 
although stakeholder views on practical alignment with animal welfare legislation are mixed, 
particularly where disease-control measures under the AHL may have implications for animal 
welfare. 

The AHL applies to wildlife only where it is epidemiologically relevant for the prevention or 
spongiform 
control  of 
encephalopathies and most rules on animal by-products, continue to be regulated under specific 
legal frameworks outside the AHL.  

listed  diseases.  Certain  areas,  particularly 

transmissible 

3.4. RELEVANCE  

The  AHL  remains  highly  relevant  in  light  of  evolving  epidemiological  pressures,  including 
recurrence  of  certain  diseases,  the  continued  spread  of  others  such  as  African  Swine  Fever 
(ASF), highly pathogenic avian influenza (HPAI) and the expansion of vector-borne diseases. 

13  

14  

15  

16  
17  

and 

down 

 Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January 2002 laying 
down  the  general  principles  and  requirements  of  food  law,  establishing  the  European  Food  Safety 
Authority 
safety, 
procedures 
laying 
http://data.europa.eu/eli/reg/2002/178/2026-01-01. 
Directive  2003/99/EC  of  the  European  Parliament  and  of  the  Council  of  17  November  2003  on  the 
monitoring  of  zoonoses  and  zoonotic  agents,  amending  Council  Decision  90/424/EEC  and  repealing 
Council Directive 92/117/EEC, http://data.europa.eu/eli/dir/2003/99/oj. 
Regulation  (EU)  2019/6  of  the  European  Parliament  and  of  the  Council  of  11  December  2018  on 
2001/82/EC, 
veterinary 
http://data.europa.eu/eli/reg/2019/6/oj. 
External study, p.78. 
SWD, p59. 

medicinal 

repealing 

Directive 

products 

matters 

food 

and 

of 

in 

7 

 
 
Its  preventive  orientation,  use  of  regionalisation  and  other  tools  as  vaccination  provide 
appropriate tools to address increasingly complex disease dynamics. 

Overall,  the AHL  is  considered  fit  for  current  needs  and  sufficiently  adaptable  to  emerging 
threats through uniform minimum requirements for diseases categorised as category A and B 
and more flexible approaches for diseases categorised as category C, D and E. However, the 
operators  indicate  several  challenges  in  this  regard.  The  flexibility  provided  for  diseases 
categorised as C, D and E enables Member States to tailor measures to national circumstances 
but may also lead to heterogeneous application of measures (for example, vaccination against 
bluetongue),  which  are  beneficial  for  controlling  the  disease  in  the  Member  States  but  can 
impact intra-EU trade and market predictability. In addition, biosecurity obligations and animal 
health visit requirements, while clearly defined in principle, were identified by stakeholders as 
areas where more detailed and harmonised operational guidance would support more consistent 
implementation. 

3.5 EU ADDED VALUE  

The evaluation confirms clear EU added value. By establishing harmonised rules for animal 
health  and  in  particular  for  disease  surveillance,  prevention  and  control,  the  framework 
supports  coordinated  action  across  Member  States  and  contributes  to  a  level  playing  field 
within the internal market. Union-level tools, such as disease listing and categorisation, antigen 
and vaccine banks, EU disease notification and reporting system, network of EU animal health 
laboratories,  regionalisation  and  common  rules  for  movements  and  entry  into  the  Union, 
underpin predictable cross-border coordination and facilitate safe trade. Moreover, the AHL 
framework ensures that requirements for entry into the Union are as stringent as those applying 
in the EU, creating an equal level playing field for the EU operators. These entry requirements 
in line with the international standards of WOAH permit international trade in accordance with 
WTO/SPS  principles.  These  outcomes  could  not  have  been  achieved  to  the  same  extent  by 
Member States acting alone 1819. 

The balance between EU and national action is broadly proportionate. However, the outcomes 
show some limitations affecting the extent to which EU added value is fully realised in practice. 
Differences  in  national  implementation  and  the  use  of  flexibility  provisions  can  affect  the 
predictability of animal movements and create uneven conditions for certain operators. On that 
the consultation pointed out that further coordination at Union level could improve consistency 
and market predictability while maintaining necessary flexibility. 

4. LESSONS LEARNED AND NEXT STEPS  

As  indicated,  although  the  AHL  has  only  been  fully  applicable  since  2021,  the  evaluation 
confirms an overall positive assessment and widespread appreciation among stakeholders. The 
AHL is widely regarded as a significant improvement on the previous fragmented framework, 
providing a modernised, risk-based legal architecture and is considered to provide a strong and 
coherent foundation for a harmonised, preventive, and risk-based animal health policy in the 
EU. It supports a shift in focus from eradication to prevention, preparedness and proportionate 

18  
19  

External study, p139. 
SWD, p 69. 

8 

 
 
long-term disease management, thereby strengthening the predictability and sustainability of 
EU animal health policy. 

Despite  positive  overall  feed-back  and  appreciation,  the  complexity  of  tertiary  legislation, 
uneven implementation and delays in national alignment have limited the full realisation of the 
framework’s  potential.  The  Commission  identified  certain  areas  where  further  attention  is 
needed. These areas, identified across the evaluation criteria and requiring further attention by 
the Commission and Member States have crystalised in the points presented below.  

4.1 Strengthening the single policy and legal framework 

The evaluation recognises the AHL as a clearer, modernised legal structure that ensures more 
consistent  application  of  animal  health  rules  across  the  EU.  The  AHL  is  widely  seen  as  a 
structural improvement compared with the previous framework. It further reduces reliance on 
emergency  eradication  measures  alone  and  supports  more  sustainable,  predictable,  flexible 
long-term disease management.  

On the other hand, the evaluation points towards complexity of tertiary legislation, unevenly 
implemented or not yet enforced rules across Member States. These also report that alignment 
with national legislation was more complex than anticipated. The study also identified a certain 
level of frustration as regards the time needed for the adoption Delegated Acts, which is longer 
than initially assumed by certain stakeholders. 

To address  these issues, the Commission  should continue aligning  and  streamlining  tertiary 
legislation to make it easier to navigate and more user friendly. In addition, the Commission 
should increase the user friendliness and updates of the Commission website with explanations 
on integration and operation  of different  pieces of legislation and  their inter-connections.  If 
necessary,  the  Commission  can  develop  Guidance  on  various  elements  of  the  legislation, 
adopted in the format of “Commission notice” when relevant. Better Training for Safer Food 
(BTSF) training must continue and reinforce the transfer of knowledge across Member States. 

Member States must accelerate and ensure full transposition of the AHL by removing obsolete 
national  legislation.  Where  needed,  they  should  develop  national  or  sectorial  guidance  as 
relevant for the topic to complement the Commission Guidance, especially to address specific 
circumstances  and  situations.  Moreover,  Member  States  must  distribute  downstream  the 
knowledge  obtained  through  BTSF  training  more  effectively  and  efficiently  in  the  official 
services and operators.  

4.2 Clarifying responsibilities of different actors and strengthening compliance 

The evaluation showed a clearer allocation of obligations and reduced uncertainty about who 
is  responsible for prevention, notification, control and  recovery measures.  It  shows that the 
AHL  introduced  a  shared-responsibility  principle,  increased  awareness  among  stakeholder 
groups,  particularly  veterinarians  and  the  competent  authorities,  which  has  facilitated  more 
organised  cooperation  during  disease  outbreaks.    This  has  also  contributed  to  improved 
compliance. 

However,  responsibilities  can  still  be  unclear  at  local  operational  level,  particularly  during 
outbreak  situations.  The  evaluation  showed  shortcomings  in  local  operational  planning, 
stemming from  lack of training and coordination, rather than from  deficiencies in  the AHL 

9 

 
framework. Practical application of the framework is further complicated by layered delegated 
and implementing acts. Moreover, there is a legal obligation for Member States to report to the 
Commission on the penalties applicable to infringements of the provisions of the AHL. Few 
Member States reported about their acts providing for penalties 20.  

To address these issues, in addition to the elements mentioned under point 4.4, the Commission 
aims to adopt an implementing regulation on contingency plans. 

Regular publication of comparable information on national penalties and enforcement practices 
can be envisaged in order to enhance transparency regarding national sanctioning systems and 
to promote accountability and mutual trust. In light of this reflection, the Commission could 
initiate a discussion in  the framework of  Animal Health Advisory Committee (AHAC) and 
Standing  Committee  for  Plants,  Animals,  Food  and  Feed  (PAFF)  on  the  added  value  of 
establishing requirements on minimum level of sanctions or other guidance to Member States 
on how to apply sanctions.  

Member  States  must  reinforce  their  efforts  in  transposing  rules  and  develop  the  necessary 
sanctions to  ensure  a  proper implementation  of the AHL nationally and give  the competent 
authorities the necessary tools to enforce the legislation.   

4.3. Ensuring adaptability of disease categorisation/prioritisation 

The  evaluation  concludes  that  disease  prioritisation  and  categorisation  is  a  valuable  key 
measure which supports proportionate, science-based EU measures. However, concerns remain 
about adaptability and the timeliness of updates and adaptability to emerging risks and diseases 
posing specific challenges such as vector-borne diseases.  

The Commission will therefore review and verify whether the current categorisation system 
still  fits  the  current  circumstances.  It  will  also  review  if  categorisation  criteria  adequately 
address specific challenges (e.g. vector borne diseases, where a request for an EFSA opinion 
has already been launched) and may propose changes to legislation, if needed. The Commission 
will  further  mandate  EFSA  and  consider  launching  a  more  comprehensive  assessment  and 
where relevant, re-assessment of animal diseases for their listing for Union intervention and 
categorisation under the AHL. 

4.4. Improving the response to animal diseases and contingency plans 

The evaluation concluded that the adoption of the AHL has led to better coordinated responses 
to animal diseases. In addition, rules for contingency plans will further contribute to improved 
response to disease outbreaks.  

However, implementation of disease control measures across Member States remains uneven. 
On the contingency plans, stakeholders note the absence of implementing rules and the Study21 
concluded that contingency plans are outdated in several Member States. 

20  
21  

SWD, p.27. 
External study, p 66. 

10 

 
 
To strengthen the disease control measures in the EU, the Commission will continue to revise 
and amend delegated regulations22 to adjust them to the most recent scientific developments 
and  Member  States’  needs.  To  ensure  uniform  implementation  of  contingency  plans,  the 
Commission  will  adopt  an  implementing  regulation.  The  Commission  will  further  support 
Member  States  by  continuous  BTSF  training,  focussing  on  continued  support  provided  on 
animal health. The Commission will launch a specific series of Commission audits in Member 
States  to  monitor  Member  States’  States  implementation  of  simulation  exercises  and  the 
implementation of the rules on contingency plans. 

4.5. Enhancing regionalisation and compartmentalisation 

The evaluation indicated that the disease control measures introduced by the AHL that have 
helped minimise the impact of disease outbreaks, support the recognition of disease-free areas 
in the EU and enable continued intra-EU trade and exports. This has been achieved using EU 
regionalisation, and to a lesser extent also newly introduced concepts of compartmentalisation, 
enabling the continued trade within the EU and exports to non-EU countries.  

However, an uneven recognition by third countries of regionalisation and related tools reduced 
expected benefits for international trade continuity.  Several stakeholders call for more practical 
guidance, knowledge and capacity building. 

To address these issues, the Commission will further support Member  States by developing 
Guidance  on  the  application  of  regionalisation  and  compartmentalisation,  to  improve 
understanding.  A  user-friendly  Commission  website  will  provide  explanations  of  different 
pieces of legislation and visualisation of regionalisation through innovative IT mapping tools.  

The Commission and Member States will also continue advocating for the recognition of EU 
regionalisation  with  the  trading  partners  at  bilateral  and  multilateral  meetings,  within  trade 
agreements, SPS negotiations and international standard setting bodies.  

4.6.  Addressing  uneven  implementation  in  Member  States,  risk-based  measures  and 
flexibility 

Weak and uneven implementation of the AHL in the Member States is amongst the most often 
mentioned  findings  of  the  evaluation  and  perceived  as  a  weak  point.  At  the  same  time,  the 
measures in the AHL are based on risk.  In that respect, the legal framework offers opportunities 
to provide flexibility through more detailed rules i.e. delegated and implementing acts adopted 
on  the  basis  of  the  AHL.  The  AHL  also  gives  Member  States  the  possibility  to  implement 
stricter rules in  certain  areas.  Although some Member States have good  practices to  ensure 
proper  implementation  of  the  new  regulatory  framework,  and  the  added  value  of  BTSF 
trainings is clear, the implementation in many Member States remains only partial.  

With respect to flexibility, while the evaluation highlights the AHL’s added value, especially 
when  implementing  disease  control  measures,  it  also  stresses  that  this  leads  to  uneven 
enforcement and to different use of derogations in  Member States. This  was perceived as a 
factor affecting the single market and creating unequal conditions for certain sectors in different 
Member States and there was a call for more consistent implementation across the EU. 

22  

http://data.europa.eu/eli/reg_del/2020/687/oj. 

11 

 
 
To address this, the Commission can reinforce Commission audits in Member States to closely 
monitor and stimulate a better and more even level of implementation. If considered necessary, 
the  Commission  may  limit/frame  the  use  of  Member  States  derogations  through  the 
modification  of  delegated  and  implementing  acts  and  ensure  more  prescriptive  harmonised 
rules. The Commission and Member States could increase transparency by keeping up-to-date 
and  transparent  national  and  Commission  websites,  by  providing  information  at  Standing 
Committee  on  Plants,  Animals,  Food  and  Feed  (PAFF  Committee)  and  making  it  publicly 
available on the PAFF Committee website. Moreover, continued BTSF training will, by raising 
knowledge,  providing  information  and  conducting  practical  exercises,  continue  supporting 
Member States’ implementation.  

4.7. Emphasis on risk-based prevention, biosecurity and surveillance measures 

The evaluation noted an important progress in obtaining disease free statuses for several listed 
animal  diseases,  for  which  eradication  is  compulsory  in  the  Union,  such  as  tuberculosis, 
brucellosis or rabies, introducing a shift from an eradication-centric model to prevention and 
control23. The evaluation shows that surveillance is reinforced under this framework applying 
a risk-based approach. On the other hand, it observed a mixed application of basic operator’s 
surveillance  through  animal  health  visits  according  to  Article  25  of  the  AHL,  uneven 
enforcement  of  biosecurity,  and  pointed  to  resource  issues,  especially  a  shortage  of 
veterinarians.  Enhancing  national-level  surveillance  networks  and  ensuring  alignment  with 
EU-level  indicators  to  maintain  a  level  playing  field  across  Member  States,24  could  help  in 
implementing  a  flexible,  risk-based  approach  that  adapts  to  the  local  context  which  is  only 
justifiable if it is underpinned by robust surveillance systems. 

To address a request repeated in the evaluation, the Commission can develop rules with criteria 
and baseline frequency of animal health visits and develop guidance on biosecurity, where the 
Member States in their reflection explicitly preferred guidance to legislation.  

4.8. Optimising the use of vaccination across the EU 

As indicated in point 3.1, the evaluation recognised and welcomed the paradigm shift of the 
AHL which provides for a wider and more flexible use of vaccination against animal diseases 
and shows some good examples. More recently, an unprecedented volume of animals to be 
culled  due  to  the  spread  of  diseases  justifies  calls  for  broader  use  of  vaccination  also  as  a 
prevention tool where possible.  

In response, the Commission will verify whether the current vaccination rules and principles 
included  therein  are  fit  for  purpose  and  if  the  approach  for  different  Category  A  diseases 
addresses  the  needs,  taking  into  consideration  potential  impacts  of  such  changes  to  the 
economy,  society  and  trade.  This  work should be undertaken within a broader  international 
multilateral context, taking into account not only EU rules but also international standards and 
trade requirements. The Commission will therefore continue to engage with WOAH, trading 
partners  and  other  international  stakeholders  to  promote  science-based  approaches  to 
vaccination, contribute to the development of international standards and, reduce unjustified 
trade  related  barriers  associated  with  the  use  of  vaccination.  The  Commission  will  also 
regularly discuss with Member States and industry how to ensure better availability of vaccines 

23  
24  

Point 3.4. of Staff Working Document, p.26. 
Point 5.6. of External study. 

12 

 
 
for such animal diseases. The Commission will also ask for scientific advice supporting the 
decision-making  process  on  how  to  best  use  vaccination  under  different  scenarios  and  for 
different purposes, i.e. to support disease control measures with emergency vaccination or to 
use it as a disease prevention tool. 

4.9.  Reducing  administrative  burdens,  costs,  reporting  and  complexity  of  certain 
measures  

The  evaluation  study  perceived  the  introduced  risk-based  measures  as  more  cost-effective. 
Some  specific  benefits  are  already  visible,  for  example  improvements  in  early  detection  of 
avian influenza in certain regions25. However, these benefits are not yet widespread. Training 
and  the  implementation  of  new  obligations,  such  as  animal  health  visits,  also  generated 
increased costs.  

Moreover, in some cases, as for example for ASF, specific rules introducing additional zoning 
elements and movement restrictions on top of the general AHL framework provisions, were 
perceived  as  more  complex,  reintroducing  a  disease-by-disease  approach,  increasing 
documentation  requirements  and  creating  confusion  for  operators  and  trading  partners. 
Member States and operators also reported increased workloads related to early detection and 
surveillance of animal diseases. 

On  the  other  hand,  some  simplification  occurred  in  practice.  The  Commission  has  issued 
clarifications to distinguish low-risk movements (e.g. certain pets and captive birds), and some 
Member  States  have  introduced  national  measures  such  as  waiving  fees  for  hobbyist 
certificates.  Simplification  is  proved  to  be  possible  within  the  existing  legal  framework. 
However, the evaluation study also pointed towards diverging national obligations and top up 
EU rules, which many perceive as problematic.  

The  Commission  will  therefore  continue  pursuing  the  use  of  simplification  possibilities 
through amending the existing delegated and implementing acts, taking an evidence- and risk-
based approach. The Commission  can also  consider  limiting or better framing  the use of 
Member States’ derogations through the modification of delegated and implementing acts 
and ensuring more harmonised rules.  

4.10. Addressing funding concerns 

The evaluation study highlights several instances of the lack of adequate financial mechanisms, 
in particular to compensate farmers for their losses due to disease outbreaks and related costs. 
Although the study considered this was an unintended effect, it noted that the clarification of 
responsibilities shifted the financial obligations to farmers.  

Experience  as  regards  EU  co-financing  has  shown  that  the  unpredictability  of  large-scale 
outbreaks of certain animal diseases, leading to major crises, point to a need to ensure access 
to a crisis reserve fund suitable for financing animal diseases emergency measures.  

The  Commission  noted  these  concerns  which  will  be  also  addressed  through  the  Livestock 
Strategy and the new Multiannual Financial Framework.  

25  

SWD, Point 4.1.1., page 39-41. 

13 

 
 
4.11 Strengthening external coherence and links with other legislation: 

The evaluation confirms that the AHL is broadly aligned with other EU policy frameworks, 
including the One Health approach. Its objectives reinforce those of the single market, public 
health, food safety, and environmental protection. Nonetheless, some inconsistencies remain. 

4.11.1. One Health approach 

Meaningful alignment of the AHL with the One Health approach is observed. The AHL reflects 
a clear legislative commitment and remains relevant to its overarching objectives. However, 
the extent of its practical alignment and operational effectiveness is perceived differently by 
various  stakeholder  groups  and  is  characterised  by  both  notable  strengths  and  persistent 
challenges in implementation and integration26. Its effective application continues to face gaps, 
especially  in  the  integration  of  environmental  health  and  cross-sectoral  collaboration  and 
stronger coordination across animal, human and environmental health systems, particularly for 
zoonotic and wildlife-related risks.  

The  Commission  will  further  support  efforts  of  Member  States  to  enhance  coherence  and 
strengthen  multidisciplinary  integration  in  the  countries  with  emphasis  on  sharing  best 
practices.  

In the new implementing regulation on contingency plans (see also above), which is planned 
for adoption  in  2026, the Commission  will  require Member States to  clarify  procedures for 
cooperation of veterinary authorities with their public health counterparts, and when relevant 
environmental and other authorities. 

4.11.2.  AHL  and  the  link  with  rules  on  transmissible  spongiform  encephalopathies 
(TSE) and on zoonoses  

Despite  the  fact  that  AHL  has  introduced  a  well-structured,  risk-based  approach  for  animal 
disease  control,  its  coherence  with  pre-existing,  legislation  on  Transmissible  spongiform 
encephalopathies  (TSE)  Regulation27 -  remains  partial.  Stakeholder  input,  particularly  from 
competent  authorities, has highlighted that maintaining separate legal  frameworks for TSEs 
and  other  zoonotic  diseases  has  resulted  in  regulatory  fragmentation  and  implementation 
difficulties. The fact that TSEs are not included in the AHL's disease categorisation process 
results  in  confusion  among  operators  and  authorities,  it  complicates  disease  prioritisation, 
influences co-financing decisions and weakens communication of health risks28. According to 
the study, addressing these inconsistencies would support both legislative coherence and more 
efficient allocation of disease-related EU funding. 

26  
27  

28  

External study, point 4.3.7, p 143. 
Regulation (EC) No 999/2001 of the European Parliament and of the Council of 22 May 2001 laying 
down  rules  for  the  prevention,  control  and  eradication  of  certain  transmissible  spongiform 
encephalopathies, http://data.europa.eu/eli/reg/2001/999/oj. 
External study, point.4.4.2, p 151. 

14 

 
 
 
The Commission is already addressing certain aspects of the TSE rules in the ongoing Food 
and Feed Safety simplification omnibus29 adopted in December 2025. In addition, it will launch 
a comprehensive revision of the TSE rules and consider bringing them under the AHL.  

The Commission will also review, simplify and update the existing zoonosis directive and 
reflect how to incorporate other zoonotic agents under the AHL framework. 

4.11.3. Clarifying interfaces with animal welfare  

Although the evaluation study didn’t identify any direct legal contradiction/friction with animal 
welfare rules, perception of misalignment exists, especially in the areas of animal transport and 
culling  practices  during  outbreaks,  particularly  in  some  farming  systems.  Normally  such 
concerns  relate  more  to  the  specific  and  in  many  cases  local  implementation  of  certain 
temporary  disease  control  measures  and  broader  farming  practices  rather  than  to  the  legal 
provisions.  

The Commission can further address these through scientific advice provided by EFSA and in 
the Livestock Strategy. The Commission can also consider organising a dedicated BTSF for 
specific issues at the interface between animal health and animal welfare in different outbreak 
scenarios, particularly during emergency situations affecting transport, housing conditions or 
culling of animals during disease outbreaks.  

5. CONCLUSIONS 

In conclusion, the evaluation shows that the AHL presents a strong foundation for a harmonised 
animal health policy in the EU. Its shift towards prevention, risk-based decision-making, and 
integration with broader EU goals marks a substantial improvement over the previous system. 
However,  uneven  implementation,  perceived  complexity  in  legal  instruments,  and  limited 
stakeholder understanding continue to pose challenges.  

The  Commission  identified  areas  and  actions  that  could  address  these  issues,  for  instance 
through  simplification,  capacity  building,  enhanced  cooperation  between  operators,  and 
Member  States  and  the  European  Commission  aiming  at  introducing  a  more  preventive 
approach. These would help the AHL to fulfil its potential in safeguarding animal and public 
health, promoting resilience, and supporting the competitiveness of the EU’s agri-food sector. 
The  priority  at  this  stage  is  not  a  fundamental  reform,  but  consolidation,  clarification  and 
consistent implementation across the Union. Continued monitoring and evidence gathering will 
inform any future legislative adjustments. 

29  

Simplification of legislation - Food Safety - European Commission. 

15