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Joint Committee on Agriculture, Food and the Marine debate -
Wednesday, 30 Mar 2022

Regulations and Verification Systems of Online Sales of Pets: Discussion

Apologies have been received from Deputy Fitzmaurice. I remind members, witnesses and those in the Public Gallery to turn off their mobile phones.

In the first session of today's meeting, we will examine regulations and verification systems of online sales of pets. In the second session we will resume our examination of canine welfare, including artificial canine insemination, canine fertility clinics, ear cropping and microchipping. The committee will hear from representatives of Fido and in the first session and representatives from the Veterinary Council of Ireland and the Department of Agriculture, Food and Marine in the second session.

On 28 February, legal requirement for mask wearing in all settings was removed. However, it is still good practice to use face coverings, particularly in crowded areas. The service encourages all members of the parliamentary community to wear face masks when moving around the campus and in close proximity to others. While the easing of restrictions removed the general requirement of for 2 metre physical distancing, public health advice continues to state that maintaining a distance from other people is good practice. It is important that everybody in the parliamentary community continues to be respectful of other people's space.

Witnesses giving evidence from within the parliamentary precincts are protected by absolute privilege in respect of the evidence they give to the committee. This means that witnesses have full defence in any defamation action for anything said at a committee meeting. However, witnesses are expected not to abuse this privilege and may be directed by the Chair to cease giving evidence on an issue. Witnesses should follow the direction of the Chair in this regard and are reminded of the long-standing parliamentary practice to the effect that, as is reasonable, no adverse commentary should be made against an identifiable third person or entity. Witnesses who are giving evidence from a location outside the parliamentary precincts are asked to note they may not benefit from the same level of immunity from legal proceedings as witnesses giving evidence from within the parliamentary precincts and may consider it appropriate to take legal advice on this matter. Privilege against defamation does not apply to the publication by witnesses, outside the proceedings held by the committee, of any matter arising from the proceedings.

Members are reminded of the long-standing parliamentary practice to the effect that they should not comment on, criticise or make any charges against any person outside the Houses or an official, either by name or in such a way as to make him or her identifiable.

Parliamentary privilege is considered to apply to utterances of members participating online in this committee meeting when their participation is within the parliamentary precincts. There can be no assurance in relation to participation online from outside the parliamentary precincts and members should be mindful of this when they are contributing.

In the first session today, we are joined from by Mr. Paul Savage, founder, and Dr. Finbarr Heslin, chief executive officer, and from Fido by Mr. Timothy McMullen, chief operations officer. I welcome the witnesses and invite them to make their opening statements.

Mr. Paul Savage

It is my pleasure and honour to be here today to speak with members of the Joint Committee on Agriculture, Food and the Marine on the topic of the post-enactment scrutiny of the Animal Health and Welfare Act 2013 and the subsequent Microchipping of Dogs Regulations, MODR, 2015, and the Animal Health and Welfare (Sale or Supply of Pet Animals) Regulations 2019 with regards to activities around regulations and verification systems of online sales of pets, specifically pet dogs.

I am the founder of, an online classified ads marketplace. We specialise in listings for dogs for sale and dogs for stud. has been online since 2008 and was set up to cater for the Irish people’s great love of pet dogs. It is estimated that our island is home to over 450,000 pet dogs, while there are also nine native Irish breeds of dogs that are recognised around the world for their beauty and excellent character. Dogs rank as the number one pet in Irish households.

Since our foundation, the way Irish people have looked for pet dogs has undergone fundamental changes, including advertising moving primarily online. Meanwhile, more recently, pet ownership numbers have also increased substantially since the Covid-19 pandemic hit in 2020. Last month, February 2022, approximately 2,000 dogs and puppies were listed for sale on our site. These advertisements are from private individuals, registered sellers of pets and registered breeding establishments. Approximately 250,000 people visit our site each month. They are generally looking to get general information on owning a dog, find a new pet dog, sell their dog or find a new sire or dam for their next litter.

In order to sell on our platform, all advertisements for dogs for sale are required to contain certain information, as per the Animal Health and Welfare (Sale or Supply of Pet Animals) Regulations 2019. This includes the date of birth, country of birth and microchip number, which has to be registered with one of the four approved dog identification databases, namely, Animark, Fido, the Irish Kennel Club and MicroDogID. Advertisements must also include any relevant registrations or licence number, such as a registered seller ID from the Department of Agriculture, Food and the Marine or a registered breeding establishment licence number from one of the 31 local authorities.

At, we pride ourselves in bringing a high level of trust and transparency to online pet sales. We have some additional systems and rules that go beyond the legal requirement. For example, all users are verified by SMS and only one phone number can be linked to a single account. While it is possible to import dogs with cropped ears or doges that have been declawed, we do not accept these ads. Puppies have to be at least seven weeks old before they can be advertised for sale on our site. We limit certain payment methods from being used, such as virtual and prepaid credit cards and one-time credit card numbers. For registered breeding establishments, we also include the number of breeding bitches included on their licence, helping to share the scale of these operations.

Beyond these measures, since 2020, we have been working closely together with Fido on ways to provide more transparency and trust in the information presented in our ads. This work is largely based on a publication from Four Paws, entitled the Model Solution. Four Paws is a global animal welfare organisation based in Austria. One of its initiatives is to ensure that the owner of the dog is actually the person selling the dog, and that the details match the information contained on the microchip certificate. This is where the Europetnet’s Veripet system comes into play. It works as follows. Users enter the microchip number of the dog they would like to sell. They also add in a unique owner PIN that is printed on each certificate. The Europetnet’s Veripet system checks to see if the details match and if they do, it then sends the user a one-time passcode to the registered email address or phone number on the certificate in order to confirm ownership. The Veripet system can also send back information about the dog. Currently, we use this system to collect data on the sex of the dog, which avoids microchips being used for other dogs. Finally, the Veripet system also provides a verification link for potential buyers to see certain information about the dog. This link is added into the advertisement automatically and goes to the identification and registration database. It should be noted, in relation to data protection and information about a dog, that its breed, date of birth, sex and colouring, are not relevant in a GDPR setting. Since September 2021, when we launched this, over 5,000 of these verifications have been done. This is approximately 35% of the dogs listed for sale.

On our site, we have three types of sellers, private individual sellers, registered sellers and registered breeding establishments. Private individual sellers are people who sell fewer than six dogs a year. Registered sellers are people who are registered with the Department of Agriculture, Food and the Marine. They sell six or more dogs per calendar year, but have fewer than six breeding bitches. Their registered seller ID is included in the ad. There are approximately 1,400 individuals, charities and businesses currently registered with the Department of Agriculture, Food and the Marine, and over 950 of them have an account with Registered breeding establishments are those that are licensed by their local authority and have six or more breeding bitches. Their number if the registered breeding establishment and the maximum number of breeding bitches as per the breeding establishment's licence are s included in the ad. There are approximately 120 registered breeding establishments in Ireland, approximately 80 of which have an account with

We also offer a free dog buying contract template to make sure all the right information is captured and exchanged when a dog is sold. Trust, safety and transparency are paramount to us at We want to make selling and buying dogs online safer for everyone. Helping sellers to stay in compliance with their legal obligations is a critical component of this. Each ad is carefully reviewed before being published on our platform. Furthermore, we believe strongly in helping our pet rescues and charities around the country. To assist in the fantastic work these organisations do, we offer support for rehoming charities, providing free accounts for them to advertise dogs for which they need assistance finding new homes. With one in four households in Ireland estimated to be owners of dogs, we believe we can play a small role in helping the people of this island with their pets.

Mr. Finbarr Heslin

I thank the Chairman for the invitation to speak on the topic of verification systems used in online sales of pets, namely, pet dogs, subsequent to the introduction of the Animal Health and Welfare (Sale or Supply of Pet Animals) Regulations 2019. Fido is one of four databases approved by the Minister under the Microchipping of Dogs Regulations 2015 for the registration and storage of the details of dogs, their owners and the identifying microchips of those dogs in Ireland. Fido’s work in this area predates the 2015 regulations by over a decade, and in almost 20 years of work, we have registered and stored the details of almost 1 million pets.

MODR 2015 is viewed across Europe as an excellent example of how mandatory identification and registration can be legislated for. Several components of the regulations have made it a robust statute. The absence of self-certification, the requirement of the database to time-stamp each transaction and record the details of the person entering the details, the requirement for photo ID and proof of address, and the fact that most data are veterinary certified have all contributed to high-quality data being collected. Every year, thousands of dogs are reunited with their owners when they get lost because of microchips.

Fido has always worked extensively with animal welfare groups and charities. As far back as 2013, we wrote the IT code for a system to provide for independent verification of advertised pets, as we were aware of the massive issues associated with the illegal puppy trade. In the intervening years, and especially during Covid, these problems have got worse, with the cost of pups making puppy production incredibly lucrative. Our verification system was presented to the Irish Pet Advertising Advisory Group, IPAAG, as far back as 2016, but none of the online advertising platforms introduced the system. After the Animal Health and Welfare (Sale or Supply of Pet Animals) Regulations were introduced in 2019, the major online pet advertiser withdrew from the market. Since then, Fido has collaborated with the current main online pet marketplace,, to introduce the verification system. As Mr. Savage said, it went live in November 2021.

Ireland is in a unique position in that we are the first country in Europe to have a statutory requirement for verification of the details of a dog being advertised for sale or supply. There are several requirements now for advertising animals, but Fido's sole competency in this area is the verification of the microchip number, as Regulation 8(c) states that in the case of a dog, the unique code of the microchip implanted into the animal must be shown.

When the regulations were introduced, many advertisers simply put in fake microchip numbers, adding no improved traceability or transparency to the ads and doing little to improve consumer protection. The Fido PetSAFE system had been developed to overcome this practice.

Anyone who has purchased anything online will most likely have used a two-step authentication system to pay for it. This is where the purchaser's bank sends a verification link to the mobile phone number associated with the credit card account used to ensure that no fraud is being committed. Veripet is a similar technology. With the Veripet application programming interface, API, only the registered owner of a dog is allowed to advertise the dog for sale. The registered owner's details have been independently verified and his or her proof of identity and proof of address have been seen, in most cases by a veterinary surgeon, and certified in the database. When placing an advertisement on a participating classified ad site, the seller will need to provide the dog's microchip number along with his or her mobile phone number or email address. The Veripet API will then carry out an automatic check with the pet registration database that the details match. If they do, a one-time code will be sent to the registered owner of the dog and that code will need to be added to the advertisement in order for it to go live.

As for the detailed steps of how the technical system works, the pet owner or breeder registers the dog on a Department-approved database. The pet owner visits a classified ad site, enters the microchip ID for the dog into the relevant field on the classified ad site, the microchip number for the dog is checked against the information on the database, and a one-time passcode is sent to the telephone number of the pet owner on the database. The IT system developed by Fido has now been integrated into Europetnet to give a federated system across Europe. This will go live in Switzerland in the coming months, with France, Norway and the UK also looking to implement it on the basis of its success in Ireland.

We have been presented with many reasons not to introduce this system by advertisers, but the technical solution provided by Fido has been extensively trialled live in the marketplace and is proven to work, with several thousand ads having now been verified. GDPR concerns are dealt with at the advertisement platform level, which allows for the independently verified details stored on the database to be released to the new owner if there are problems with the pup and the new owner cannot contact the vendor.

Since implementation of the system, some issues have arisen. First, there is little or no recognition by the public of the difference between a verified ad and a non-verified ad. Second, no prominence is given to verified ads on sites, and there is little explanation of what this verification means and how it improves customer protection. Third, Fido is the only database using this system, and that invariably leads to rogue breeders using other databases as it is easier to get their dogs posted on ad sites. Fourth, some quality-of-data issues have been observed. If the person registering the pup's details initially enters incorrect data such as an incorrect mobile phone number, the owner cannot receive the one-time passcode to allow the ad to be posted. Fifth, other verification systems for non-Veripet verification are not robust. They are subject to fraud, altered certs, old certs, reused certs and fake certs. Sixth, other databases are not on board, and there appears to be no incentive to be on board the system. In reality, there is no advantage to Fido in being on board. Seventh, if there are different "levels" of verification available to prospective advertisers, the rogue producers will always gravitate to the easiest and least robust system.

It is not possible for an unregistered owner to advertise an animal on a marketplace that allows only ads that are verified through the system. What we have found is that rogue breeders and those who want to circumvent the system will register their animals on a database that does not have the same controls in place. Manual verification of these animals by the online advertiser is not robust and is easily circumvented by using old certs, falsified certs, previous owners' certs or other means.

The simplest solution is that advertisement sites publish only ads with microchips verified to the same level as Veripet, whether that is a voluntary code of practice decision or a legally mandated one. Nothing in the current regulations compels the databases to provide this verification. If, however, the online platforms did not allow non-verified ads to be posted, it would compel databases that are not on board to join the system because their clients, who will not be able to sell pets without proper verification, will demand that. Manual authentication and verification is simply not robust enough to provide the verification that the spirit of the regulations sought.

The Veripet system works, and all adverts for dogs in Ireland should be verified through it, or through an authentication system with comparable levels of security, probity and transparency. This will give consumers the protection they deserve when completing what can be expensive purchases. We are always available to the committee to elaborate on any points about the system that may be unclear. Again, I thank the committee members for their time. Because of time pressures, we have kept much of the technical detail out of this presentation, but API documentation and further technical specifications are available should any member require them.

Sorry, Mr. Heslin. I did not realise there were two opening statements. I printed off only one before I came down.

I thank both witnesses. Mr. Heslin summed up the issue at the end in his points about Fido and the database. Fido is trying to do the right thing, but if this is not legally mandated, its competitors will not comply and then unscrupulous breeders will be driven to those databases. Does Mr. Heslin think the review of the microchip legislation needs to mandate that all the online sale platforms and all the databases that hold microchip numbers be uniform in what they are obliged to do? If Mr. Heslin wishes to answer that question first, then I will come back in with some of my other questions.

Mr. Finbarr Heslin

As I said, we have been working on this since 2013. We were constantly producing code that allowed some form of verification and we used to present it to what was at that point the biggest marketplace in operation, and there was always a reason they did not want to implement it. When the regulations came in there was even an argument as to whether or not an online platform was subject to these regulations at all. We saw the laughable situation whereby microchip numbers that had been just pulled out of the air were used to facilitate the advertisement of pets. There was no consumer protection in this. With the Veripet system, it is now proven that there is a system that is instant and that works. It is now being used across Europe, in much more complicated marketplaces than Ireland's, so the short answer to the Senator's question is "absolutely". I do not know if there will be a voluntary code of practice that will compel enough of the databases to do this correctly and to the same level. As for all the arguments against using a system, the coding is there, it is not difficult, it is not dear and very little needs to be done on the other end. We have given this code to Europetnet, which is a non-governmental body based in Brussels, for roll-out across Europe, so there is nothing for Fido in this. We just want to do the right thing. The statistics to which Mr. Savage has alluded, with verification of 35% of dogs advertised, tell their own story. That means that nothing in these regulations has contributed to an improved consumer protection for the 65% of people who have bought dogs via ads since November.

As for the 65%, one of the problems is that the Minister's response when we bring this up - and I have brought it up in the Seanad - is that the public need to do their homework and their research if they are going to buy a pup rather than going to a rescue. The problem, however, is that they cannot do their research because they do not know what a proper microchip number or a proper dog breeding establishment, DBE, number looks like. Even if they have the proper DBE number, they then have to try to find out information from the local authority, and not all the information is given. My argument, therefore, is that buyers cannot do their homework if the online platforms do not do their homework. In fairness to, it is doing that in conjunction with Fido.

Other points have been made to us. This probably has to be brought in across the board for the four different databases. What information is contained on a Fido microchip? Would Fido have any objection to increasing the amount of information on the microchips, whether the colouring, sex or age of the dog or where the dog was bred, if that information is available?

Mr. Finbarr Heslin

To be clear, a microchip is an inert piece of hardware and has only one piece of information on it, that is, a world-unique 15-digit code.

It is worthless to have that in a dog unless it is registered.

As to the details the Senator is looking for, we are mandated under the Microchipping of Dogs Regulations 2015 to register, store and verify 13 different pieces of information associated with that ownership - the dog's colour, date of birth, sex, breed, markings, etc. If Mr. Savage decided in the morning that was going to integrate totally with our system, the owner would only have to type in the microchip number and verify it. The system would then write the ad detailing from the independently verified details what dog was for sale.

A point that is often missed in this debate is that the quality of the data on databases is important. In Ireland, we have predominantly chosen to use veterinary certified data. As a vet, if I falsify data on the registered database, I could lose my licence. That is a price I am not willing to pay, and few people are. In the UK, owners can register data and there is no imperative to do it properly and give the dog's future owners any protection. If the ad is run through our system, it means that a vet somewhere has certified that he or she has seen proof of ownership, a picture ID and a bill recording the address. This was always the problem in the old days - a dog being picked up at the back of a pub car park and a mobile number that would ring out after the transaction had been finished. That cannot happen. If there is a contention subsequent to the purchase of the dog, the details on the database can be released to the new owner. That is the GDPR consent for publication. Those details have been certified by a vet under the regulations. If there is anything wrong with those, the vet is the one who has to answer why. It has been difficult to circumvent the Microchipping of Dogs Regulations 2015 because it is so robust. This is one of the things we can bolt onto it to provide massive consumer protection and improvement in animal welfare, given that we will have good data.

What saddens many people involved in animal welfare - the Senator has campaigned on this matter - is that it is actually easy to get this right, to legislate or regulate, or to agree a voluntary code of practice among online platforms. Our disappointment is that there is not public awareness of what verification involves and means. Our verified ads do not even get prominence on We get a little tick. Someone would need to go looking. We all know that, when it comes to the purchase of a pup, emotion trumps any form of will to do due diligence. As soon as someone sees the picture or the puppy, he or she is sold.

Mr. Heslin would have no objection to the four databases having a central repository where the information would be accessible to the authorised authorities if, for example, a dog had to be reunited with its owner. A concern raised by one of the animal welfare organisations was that some microchip databases require people to phone in, which can delay reunification with the dog. If someone could go online and verify the details, though, the dog would be reunited with its owner much more quickly.

Mr. Finbarr Heslin

There are different legal templates for this across Europe. Ireland has chosen to have a number of independent databases. This meets competition requirements. Computer systems are so advanced now that a centralised portal would be very quick and easy. We coded a centralised system and presented it to the Department of Agriculture, Food and the Marine and the other databases last year. However, we cannot make the other databases tie into it. Obviously, they have concerns. Were the Department to host a centralised system, though, we have already written the coding that would be plugged into the four databases. This would provide the centralised look-up that the Senator is suggesting. That system is in place in many other countries and there is little impediment, other than desire, to introducing it in Ireland.

I thank Mr. Heslin. I know I am hogging the time, but may I ask a further question? Does only use the Veripet system?

Mr. Paul Savage

We launched it in September 2021 and were the first platform to have it. We have worked closely with Mr. Heslin’s team. I believe that none of the other online platforms in Ireland uses it.

All of the ads that are put up are verified.

Mr. Paul Savage

No. There are also ads from all of the other registries with the microchips that are registered with them.

What is preventing from restricting that? is a business and there are other online platforms, but given what we know about puppy farms in Ireland, why does not say – at least as a marketing tool – that it will only use the verified system? Advertising that would help the public in terms of knowing where they should go.

Mr. Paul Savage

Our strategy was to get the first database going. That was successful. I believe that a second database is at an advanced stage in what it is doing. Once we are half-way there, we will issue databases a mandate and tell them that they have six months or the like or we will cut them off. We first want to make sure that the system works and can be rolled out and that people have enough time.

I have two brief questions for Mr. Savage, the first of which is on the types of breed advertised. Does accept any type of dog? If someone has pomskies and wants to advertise them for sale on its website, does

Mr. Paul Savage

There is no legal restriction on breeding, as far as I am aware. There are dog breeds that are on the so-called banned dog list, but they are also allowed to be bred and sold, so it is possible to advertise any type of dog mix.

I am asking about pomskies because they cannot be bred without artificial insemination. We heard about the issues around that recently. I had a quick look around the site. In one ad, there were 100 breeding bitches. Does only accept ads from a registered breeding establishment that caps the number of breeding bitches or does it accept ads from anyone?

Mr. Paul Savage

They would all be inspected and licensed by the local authorities. If the local authorities deem that they are correct and operating within the law, we are happy to publish their ads. We include the number of breeding bitches because just seeing the licence number does not give someone an idea of the scale. That is why we have pushed registered breeding establishments to share a little about their size and what they do. That has been helpful for people, as it gives them a better idea.

I agree. It is a great improvement on what is on some other sites. From a marketing point of view, though, would it not be better if was able to pitch itself as only hosting pre-verified ads from someone with a maximum number of breeding bitches and about dogs that, due to the health and behavioural issues that affect artificially bred breeds, can only breed naturally? It would be a big selling point for dog lovers.

Mr. Paul Savage

It is difficult to say what the maximum number should be. We are not in control-----

The Irish Kennel Club would say 30.

Mr. Paul Savage

Right, but there could be many differences between a breeder of 30 in one county versus the next county. It is down to the quality of inspections, ensuring that socialisation plans are being adhered to, the cleanliness of the facilities, etc. Breeding establishments are regularly inspected to retain their licences. Inspectors can also turn up unannounced. I would encourage local authorities to spend more time on ensuring that all of these elements are being adhered to.

The Irish Kennel Club would say the maximum number someone could have while making a living from it is 30.

I welcome the guests. I have a couple of questions for Fido. Mr. Heslin says the simple solution is to only have sites that publish with microchips. Following on from what Senator Boylan said, would his preference be for a voluntary code database or a legally mandated one? Which would Fido prefer? I imagine it is a legally mandated one.

Mr. Finbarr Heslin

We have been dealing with a voluntary code of practice through the Irish Pet Advertising Advisory Group. I am not sure if members are aware of IPAAG but it is basically a group of interested parties in pet advertisement. That has been in existence since the middle of the last decade. Repeatedly, we will go to the members with solutions, they work and they are not introduced. There is always an excuse. Even when the regulations were printed in 2019, we were hit with the excuse that they did not apply to online platforms. They hid behind the Facebook excuse that they were not the advertisers but just facilitating display of an advertisement. If we could have a magic wish, we would definitely want it to be legally mandated.

I am sure members are aware that there are many different forms of two-step authentication. This is one that works particularly well in Ireland because we have such good mobile phone penetration and the original regulations made contact details a requirement. We use that as our template and it works very well. Another database or online platform may come up with a different form of two-step authentication. Two-step authentication is the minimum we should be looking for here. There should be traceability and some independent verification, so that when an ad comes up with a chip, there is a background store of details associated with that person. That way, if they disappear off the face of the earth, we can still track them down and they can be held to account if there is a consumer protection or animal welfare problem.

Over the last 20 years, Fido has stored and registered over 1 million pets. That is impressive. Do all four approved dog identification databases work on Fido's system? Why are there so many databases?

Mr. Finbarr Heslin

When the regulations were published in 2015, it was decided that there would be a non-ministerial database, primarily because there were an awful lot of data already on databases and there would have been a complication in moving those data onto a ministerial database. It would have been incredibly difficult under GDPR to contact those people and we may not have been able to do it. A set of incredibly extensive criteria was printed by the Department and if a database adhered to those conditions, it was approved. Historically, the Irish Greyhound Board and the Irish Kennel Club would have stored data and then there would have been two independent databases, which have been in existence for 20 years. We were the ones who knew how to store data associated with microchips. The centralised database is a slight red herring insofar as we do not need a centralised database; we just need systems to talk to each other. That is what API platforms are. If the Minister decided there was a requirement for a centralised portal, we would not need to reinvent the wheel. We would just need those four databases to talk to each other and that is incredibly easy and basic now with API systems.

Mr. Heslin said in his opening statement that there are databases that do not have the same controls in place. What is the reason for that? Are there genuine reasons for those kinds of databases?

Mr. Finbarr Heslin

There is no requirement in legislation for any of the databases that store microchips to provide a verification system for ads. We are doing this because we have a welfare bent and because we have always interfaced very well with the welfare community. The Deputy would have to ask the others why they are not doing that. We are the first in Europe to have done this and we have proved that it works. It will be rolled out in Europe.

Are those kinds of databases intended to get around the regulations? Are those dogs chipped at all or is it just a fictional number?

Mr. Finbarr Heslin

Senator Boylan probably has more experience of the rogue nature of some of these ads over the years. There is definitely an easier way to advertise a dog. It does not confer any consumer protection on the potential purchaser. We have had that forever, since we were buying dogs out of the boot of a car or in a pub. That has always been the way. You ring up the mobile number a week later when the puppy is in a vet's with parvovirus and it is disconnected. That has always been the problem. What is hugely important about this regulation is that the microchipping of dogs regulation is a very good statute. However, many people have criticised its implementation and control. Sale and supply is by far the most important critical control point in pet ownership and this is the easy solution. If the chip is registered correctly and the details are certified by a vet on a database, which is already mandated under the previous regulations, it means every single ad is a potential policeman looking at the data and making sure people have done their job. It can make sure the vet certified it correctly, the pup was produced properly and that when somebody buys that pup, they are getting what they think they are getting. If there are any problems subsequent to that, people will at least be able to know who sold them the pup.

This question is for The VeriPet system is impressive. It has been used 5,000 times since September 2021 and that accounts for 35% of the dogs listed for sale. Why has its usage been limited in this way? What can be done to increase its usage?

Mr. Paul Savage

It has do to with the spectrum of where the dogs have been registered. Generally, the vet gets to choose which registry they are affiliated with and, of course, only pedigree dogs can be registered with the IKC. It is a little bit of a numbers game with regard to how many people are registering with different ones. It is just not available to the other registries. If someone picked a registry that is not on the system, which is all the other ones besides Fido, then we cannot access that verification system.

Is there a resource for vets when a pup gets microchipped? Could vets play a bigger role in this?

Mr. Paul Savage

We get to see a lot of microchip certificates and things like that. Data quality is something we see questions about. For example, when the birth date of the pup is unknown or not listed, that microchip could technically be used for lots of animals of different ages. This comes back to quality of data, accessibility of those data and being able to verify them independently. That is not just for ourselves, but also to let the public verify that a dog is in fact black and white and male and born on this date. These things should also be verified by people when they go to see the puppy.

I thank the witnesses for coming today. My first question is for Fido. Do all databases use the vet verification?

Mr. Finbarr Heslin

There may be a bit of confusion in the room. There are four databases and Fido has coded for this system. The only chips that can be verified through this at the moment are Fido chips. The European project is rolling out now and it is entirely up to the other databases if and when they want to join that. Currently, if you were to advise a potential future owner of a dog that they should be getting a dog that is verifiable and whose ownership is verifiable, and if they wanted it verified through the VeriPet system, it would have to be on Fido.

Just so I am 100% sure, Mr. Heslin is telling the committee that not all databases use vet verification.

Mr. Finbarr Heslin

VeriPet is a specific coded system. It is only available to data on Fido because Fido is the only organisation to have implemented it.

It is available to all others to join the same system. Mr. Savage would have to go through the processes he would use to verify data that are on a different database from our database.

Am I correct in saying that not all databases use a vet verification system at present?

Do vets verify and register them?

Mr. Finbarr Heslin


That is an important point. If so, who registers the other chips?

Mr. Finbarr Heslin

The original regulations from 2015 have a section that allows for lay implantation. The act of microchipping any pet was always a veterinary surgeon act. In other words, it was only allowed to be done by veterinary professionals - veterinary surgeons or nurses. The 2015 regulations provided for lay implantation as a third category. A lay implanter can physically implant a microchip, only in a dog, and register it with one of the authorised databases. Lay implanters are lay by definition. They may not have as much to lose by not registering correctly. If I were to register something incorrectly, it is an act of certification under my control and I could lose my licence to practice. A lay implanter could implant 1,000 pups, register them in maybe not the best manner and head to Australia but we would never have any control over that data.

Okay. I will come back to the lay implanters for a minute. Mr. Heslin is in this business and knows it. My question is addressed to all three witnesses. Can those who have concerns about lay implanters share those concerns? Do they have concerns about data? Are they concerned about abuses of the system? They might share with us their take on this aspect of the matter.

Mr. Finbarr Heslin

There are mountains of information on the differences between the systems across Europe that involve veterinary certified data, lay certified data or - in my view, this is worse - owner-certified data. If an owner is involved in the production, identification and sale of pups, there are loads of reasons he or she will not want to do that honestly. The comeback can range from Revenue to welfare. Across Europe, there are over 100 million pets in the Europetnet system. We know that in countries which predominantly use a system of veterinary certification, the quality of the data is better. Unfortunately, members will have seen reports of the horrendous situation in Dublin where there was a decapitated dog.

Mr. Finbarr Heslin

We would like to be able to make sure that in any situation, we have a complete loop we can trace. If we cannot trace the owner, we should be able to the microchip back to the vet who implanted the chip. When we go outside of veterinary certification, we lose a little bit of that control. I totally understand the rationale behind the introduction of this system. Charities may not have had the finances to pay a vet to implant a microchip.

It could be done by a veterinary nurse, which would not incur the same expense.

Mr. Finbarr Heslin

Yes. The four databases were mandated under the original regulations to provide for training for lay implanters. We have done that for a number of lay implanters, predominantly in the dog control system - within the local pound systems - and with charities such as Dogs Trust Ireland. We do not train breeders or anybody like that because under the original regulations, it is our duty as the database to control the data we get. If we think somebody is giving us incorrect data, it is our duty to pass that information to the Minister.

Okay. How many times has information been passed to the Minister in the last 12 months?

Mr. Finbarr Heslin

We have never had a problem with our lay implanters but we are incredibly picky about who we allow to use our system.

What would Mr. Heslin like us to take away in relation to lay implanters? What would he like to see happen? What controls are preferred? What would he like the committee to recommend?

Mr. Finbarr Heslin

I would like the committee to have an informal discussion with the other databases. I think they would recognise that their choice of lay implanters has caused problems at times. There are some who they would much prefer had never been registered as lay implanters. The thing about databases and chips is that issues will always come to light. As Senator Boylan has said, when one buys a dog, having seen the chip advertised, one will pick up the dog and bring it to the vet along with the certificate, but when the vet checks it he might discover it is not the right chip or certificate. Things will always come to surface. Most of these animals, regardless of where they are produced, end up in what we refer to as their forever home with people who want to look after them. In certain situations, we forget that chips exist for the most part to ensure that if one's dog gets away but turns up in a pound or a vets' surgery, somebody will ring one and ask one to collect the dog.

Do the other witnesses have views, concerns or recommendations regarding lay implanters?

Mr. Paul Savage

From our standpoint, I support Mr. Heslin's suggestion that there is a higher level. We do not see the direct data to have any numbers in that regard.

Is Mr. Savage aware of any abuses in this regard?

Mr. Paul Savage


Does Mr. Savage have concerns?

Mr. Paul Savage

I do not have concerns but I believe that more checks and controls would be helpful.

Does Mr. McMullen have a similar view?

Mr. Timothy McMullen


I ask Mr. Savage to explain what he meant when he said:

At we pride ourselves on bringing a high level of trust and transparency to online pet sales. We have some additional systems and rules that go beyond the legal requirement.

I ask Mr. Savage to tease out one or two of those additionalities. What makes different or more special, on top of its governance issues? Mr. Savage is saying that this is a selling point. Can he tease that out with me?

Mr. Paul Savage

In addition to the Veripet system, which we are all aware of now, we do not publish advertisements until the dogs are seven weeks old. Legally, as long as a dog is microchipped and registered, one can advertise it, but one cannot sell it until it is eight weeks old. We hold those advertisements back to decrease the likelihood that a person will sell a dog before eight weeks. We actively block bad actors on our system. In the last 12 months, we have probably blocked 700 bad credit cards from people who we do not want to use our website. The public never gets to see the advertisements that we block because of this safeguard that is in place. We have added a field to indicate whether a seller is a registered seller of pets, and we explain what that is.

I am conscious that my time is limited. Mr. Savage has said that 700 advertisements have been blocked. Can he give me two or three examples of advertisements that have been blocked? Can he outline the extent of the concern that had that led to blocking in these 700 cases? That is a substantial number of advertisements.

Mr. Paul Savage

When a person who has created an account and posted advertisements for dogs for sale hits a certain limit, he or she needs to be registered as a registered seller of pets with the Department. If that person does not want to register, or creates another account to get around our checks, we return his or her money, say thank you, tell him or her that he or she needs to register and give him or her all of the information. That person's card cannot be used again until he or she presents a registered seller ID.

Is that the only concern or are there broader concerns? Is it just about the number and the registration process or are there bigger concerns?

Mr. Paul Savage

We want to make sure people are in line with the laws. When a person hits the number, having sold or supplied six or more dogs, we want him or her to be registered as a registered seller of pets.

Mr. Savage told us that offers "a free dog buying contract template to make sure all the right information is captured and exchanged". I would be interested in seeing that template. Would Mr. Savage be able to share it with the committee?

Mr. Paul Savage

I can share the template with the committee.

I think it would be interesting. I would like to learn from that. The committee might like to learn something from it. If Mr. Savage would not mind, that would be great.

Mr. Paul Savage

I will go through the process of purchasing a dog. It is a question of the probity of the information. When one brings a dog to be microchipped on the first day, one must show one's identification and a utility bill. We encourage people to ensure that when they transfer ownership, for example from the breeder to the first owner and then to subsequent owners, that information is captured and verified in order that people know the addresses, etc., of the people in question.

Is it like a logbook?

Mr. Paul Savage


If we could see the template, it would give us a greater understanding.

I thank the witnesses, who have been very helpful, and the Chairman.

I do not have many questions, since much has been covered already. I extend my apologies to my committee as I have to leave for the second session, which will be important. I commend Senator Boylan on bringing this matter to the committee.

To get a better understanding of Fido, am I correct in saying that it is a private company?

Mr. Finbarr Heslin

Yes, it is.

Is it limited?

Mr. Finbarr Heslin


What is its structure? I see it is based in a veterinary clinic. Is it assigned to a specific vet?

Mr. Finbarr Heslin

I am a veterinary surgeon and this was my baby. I used to be a consultant vet to the Irish Society for the Protection of Cruelty to Animals. We found in the last century that we rarely had problems proving cruelty or neglect, but we had massive problems proving ownership. When chips started to become ubiquitous in the 1990s, we tried to provide better and more responsible ownership by being able to make sure that people were identifiable as the owners. It is a limited company. We have been registering animals since 2004. Between 2004 and 2015, it was entirely voluntary on the part of the owner. The bonus for the owner was that if animals got lost and the chips were scanned in a pound or at a veterinary practice, we provided the IT to make sure the details of the owner were released to whoever had the dog. As I tried to point out earlier, we effect reunifications with thousands of animals every year based on this small piece of hardware carried between their shoulder blades.

Who are Fido's customers? Who does it liaise with? Is it other vets, individual owners or breeders and sellers?

Mr. Finbarr Heslin

Every single chip is unique in the world, so there is a supply chain that needs to be monitored. If people do not do their job, the person who sold them the chip has to inform the database or the court about whom he or she sold it to. Our channel is veterinary practitioners. We also have significant relationships with many of the welfare charities and local authority pounds, which use our system.

If a vet or a pound does not use Fido's system and a dog that is microchipped comes into its possession, how easy is it to find out how to return the dog to its owner? Does it have to pay Fido a fee? Is the option available to anybody who has access to read the chip?

Mr. Finbarr Heslin

That is correct. Very few people are carrying a microchip scanner with them, so if people find a dog, they tend to have to bring it to either a vet or a pound. There is a process by which the data pertaining to that chip would be released to them. That is done free of charge. We are obliged under the regulations to provide a 24-hour service, which we do. If somebody rings our call centre and the chip is not registered with us, we will know where it is registered. The regulations require that the information in the four databases is also transmitted to the central European database, which is how we know where the data are and who we need to talk to to effect a reunification.

Is that European database a conglomeration of companies similar to Fido in different countries?

Mr. Finbarr Heslin

It is a non-governmental, non-profit organisation based in Brussels. It is not all companies that are involved. Some are government bodies. It depends on the legislation in each European country. There are different models. It is a government database in France, which is a member of Europetnet. In Ireland, the four registered databases approved by the Department have to be a member of Europetnet. There are a number of individual, private databases in Germany. Each country has different legislation underpinning mandatory chipping. Europetnet is usually the central clearing system. It is important that Europetnet does not store GDPR-sensitive data. It just tells us where data are stored. Anybody, including a member of the public, can log on to Europetnet and put in a chip number, and it will tell them where it is stored. It does not give any details of ownership, but tells people which database they should be in contact with.

Has Brexit had an impact? Is there a British affiliation to that database? Is it still in place? Does Fido operate on an all-Ireland basis? How does the Irish market work? Is there a distinction between North and South?

Mr. Finbarr Heslin

In the UK, the original legislation was developed at the same time as it was done here. It chose to go down a completely different path, with a much more liberal attitude, where there is self-registration and breeders can register. Nineteen different databases operate in the UK. There is not joined-up thinking at all. Integration with Europe by the UK even before Brexit was always a problem.

Going back to a point I made earlier, every chip is traceable for a manufacturer. If an English dog ended up in Ireland and was registered on a database there that was not integrated into the European system, we would be able to trace it from the manufacturer to where it was distributed. We would also be able to track down the owner that way.

Mr. Heslin described the French system in response to Deputy Martin Browne earlier. He said that he does not see a need for a single database. As Mr. Heslin is probably aware, our committee deals with many issues pertaining to the tracking of animals and databases. It primarily relates to foodstuffs, but also to racing horses and so on. It would be hard to imagine a scenario with four different companies operating separate databases for any of them. I know Fido has a particular interest and a system that appears to work well. Is Mr. Heslin aware of any analysis that has assessed and compared those governmental, streamlined systems with the liberal approach that appears to be adopted in Britain and the halfway house that we might be described as having?

Mr. Finbarr Heslin

I would not describe Ireland as a halfway house. The control point from the perspective of welfare and probity of data is more about who is certifying, rather than where they are certifying. There are many data across Europe that indicate veterinary certification, whether by veterinary surgeons or nurses, creates a better system than non-veterinary certification. My point about the four databases here and whether a central database might be a better system is that there are many data on those four databases, which can communicate efficiently with the central database provided by the Government. If, as we proposed last year, we coded for a centralised system, where all four would have a firewall, but there would be traceability across databases, there is a difficulty in that it should be independently hosted. We would see the Department as being the best host. We do not want to host it because, as the Deputy says, we have a vested interest. I am sure some of our competitors in the market would not be happy if we hosted a system that had some insight into their data. If we had a magic wish, a centralised API hosted by the Department of Agriculture, Food and the Marine would solve all the problems.

Regarding relationships between individual databases and their clients, Mr. Savage referred to the Irish Kennel Club, which has a certain parish that it is integrated with, while we are integrated with the veterinary side.

I am not sure we need to reinvent the wheel. We just need to get the four wheels talking to each other, as it were.

I thank Mr. Heslin. I turn quickly to Mr. Savage to get a better sense of how this works. We have learned a lot already in the session. What responsibility does his company have when things go wrong? If I were to purchase an animal off his site and it then transpired that rather than the 700 bad actors he identified last year there were actually 701, and let us say one got through the net and I experienced a difficulty because of that, where does Mr. Savage see his responsibility in that regard? What obligation is there on him to recompense me for any losses or injuries?

Mr. Paul Savage

It is a fair question. What generally happens is we will work with the customer to figure out what the issue has been. It might just be getting back in contact with somebody. For example, people just forget the telephone number or delete the message and are not able to do that, so we can facilitate that. We will verify the customer at least has the microchip number or the microchip certificate. That would be the first one. If it is a case where it is a little more serious, we direct the customer to the ISPCA - we have a great relationship with it - or to An Garda Síochána and provide other information we can share with the authorities. We have done that a number of times in the past year.

Mr. Savage would not consider himself to have the same obligations as a person operating a shop under the Sale of Goods and Supply of Services Act, in the sense of having a responsibility for the product he has facilitated the sale of.

Mr. Paul Savage

Even under that Act, it is still a customer-to-customer transaction so you are not protected under the realm of what goes into that. We are not there when the transaction happens. We are not there for the physical cash transaction or those parts or any of the terms and conditions that could have been agreed upon. It would be very difficult to say what terms and conditions went into buying that dog at that time.

Mr. Savage's model is essentially, if I want to sell a pet, I pay him a fee and place my ad. The person who is buying the pet does not pay him a fee. Is that correct?

Mr. Paul Savage

Yes. The person buying does not pay a fee. He or she gets in contact, gets the contact details or sends a message through the website. There are different methods of contact. Under each ad there is a list of tips we give people for when they go to see the dog. We update those regularly when we get feedback from customers. That transaction then happens off the platform. We do not take a deposit or something like that because situations might change and somebody does not want to sell that pet anymore, for example.

Yes. Again, let us say I am a buyer who sees an animal on Mr. Savage's website and make contact. I buy the animal and take possession of it but then it transpires it was stolen and gardaí come and take it away. As far as Mr. Savage is concerned, that is not a matter for him but for the Garda or others. Is that correct?

Mr. Paul Savage

In that case of it being stolen goods it would be very difficult to get a certificate. The microchip certificate shows the name of the owner and has the details of the dog. We encourage people to get the certificate as part of the transaction because they need it. It is a dog and a certificate. I believe, and we could check this with Mr. Heslin, that it would be impossible to get a certificate or you would have to steal the dog and the certificate at the same time, which would probably be a little bit difficult. In the case that a dog is stolen, there is a flag on the databases. That dog's microchip details are then locked and flagged, and if it gets scanned, it will show it is either lost or stolen, so there is extra information available. You can call up the microchip databases and mark your dog as stolen or lost.

I am on a learning curve with respect to the four different databases. In Mr. Savage's experience as a facilitator of sales, is there a distinction to be made between the four databases and would there be a benefit to having the single database we discussed?

Mr. Paul Savage

Competition in the market is of course good. Having multiple places where you can go has historically been good for the consumer, so to my mind there are only benefits there. A federated system that holds all the information and where we could talk to one or check the source of data would make our lives easier. It already exists in a lot of respects, for example, where the date can be seen on the Europetnet and which database a dog is registered on can be seen. That is part of our checks before the dog is listed for sale. You are not allowed legally to list a dog for sale unless it has been microchipped and registered. The registration is the second important part there. We see that federated information is already available, is mandated and works very well.

I have one last question. I was looking at Mr. Savage's site in relation to stud dogs. Does he have the same levels of control for people advertising dogs that are essentially being lent for stud as those listed for sale?

Mr. Paul Savage

We have an example of a contract, so that is helpful for people because sometimes people do not know how they should-----

I am referencing the advertising. If I want to advertise a stud dog on Mr. Savage's website, what controls are in place? Are they the same as if I were selling a puppy or is it a different system?

Mr. Paul Savage

There is no legal requirement to have the microchip information in there. It would not really help the person to see the quality of the dog. People could add the microchip information or the country of birth if they thought it was relevant but it is not a requirement for stud ads.

There are no specific rules in place on Mr. Savage's website when it comes to advertising for stud.

Mr. Paul Savage

We do not publish ads for dogs for stud until they are at least 12 months old. This is around the genetic issues that can generally show up in that period, so we do not publish an ad until a dog is at least sexually mature and some hereditary issues might crop up.

I have a question related to that. Have our guests knowledge of regulation on the number of litters a bitch can have?

Mr. Paul Savage

I believe the Irish Kennel Club, IKC, has some limits about breeding and the ages and times that qualify to be a fully IKC-registered pet, but there is no legal framework that says a dog cannot have puppies at a certain age or you cannot breed it.

There is no regulation on the number of litters a bitch can have?

Mr. Paul Savage

Not that I am aware of.

Mr. Finbarr Heslin

In the dog breeding establishments there is. That is defined in the Act.

Is that for all breeds?

Mr. Finbarr Heslin

Once it is a registered dog breeding establishment.

Is it limited to six litters?

Mr. Finbarr Heslin

It is one per year. There are minimum and maximum ages as well.

There is no set figure.

Mr. Finbarr Heslin

I think it changes depending on the size. The smaller breeds would be fertile a lot longer than a giant breed, for argument's sake.

I thank our guests. I do not think anyone else is indicating.

May I come back in Chairman, if there is time?

It is just to take up a couple of things Mr. Savage mentioned. He said 700 sellers were blocked. I am aware he is saying he just provides the advert and the contract is between the seller and the purchaser, but if somebody comes to him and tells him the dog died within a few weeks of him or her purchasing it, would he ban that seller?

Mr. Paul Savage

We would gather the information first to verify it. There could be real reasons a puppy died, unfortunately.

We have had cases where dogs have contracted parvovirus, but in the end it was found that the person had brought a young puppy into a pet store, which is most likely where it got it. We pass the information on. The report was made by the person whose dog was sick and, fortunately, the dog recovered. We helped the person make a report to the local county council, which inspected the place. It checked for parvovirus, because there was still one remaining dog, and everything was fine.

Would Mr. Savage ban somebody in the case of the local authority finding parvovirus on the site following an inspection? Has it ever happened that he has banned one of the dog breeding establishments from its site?

Mr. Paul Savage

As far as I am aware, all the dog breeding establishments are working within the law. In the case of a licence being revoked, generally it makes the news.

Two weeks ago we had a meeting with the Department of Agriculture, Food and the Marine on registered sellers. It told us that if somebody gets removed from the 1,400 on the list, it will now notify us. Someone who is no longer a registered seller or a registered breeding establishment is not able to use the licence number to proceed. In the past year, two or three registered sellers of pets have been removed.

If someone comes to Mr. Savage and says they bought a pup from an advert on his site and it died of parvovirus or whatever other condition, would he simply suspend the dog breeding establishment pending an investigation?

Mr. Paul Savage

If there was an issue like that or based on information from the Department or local authorities, we could stop the account, or at least pause it until we found out what was going on.

Mr. Savage would pause it until he found out what was going on. He said that if a pup is stolen, it is very hard to have both the microchip and the certificate. We know lay people are putting microchips in. What happens, for example, if the pups are stolen when they are too young to be microchipped?

Mr. Paul Savage

There was a well-known case of corgis last year that were stolen before they were microchipped. Different methods were used to ensure the perpetrators were caught. That was down to the Garda investigations. It would be possible for the microchip registry to see the data before us if a dog of a certain breed in a certain age group turned up. When we look at the data, if a microchip is in the person's name and he or she is registered and has all the information that shows he or she is the legitimate owner, it would be very hard to take action, but that would not be the case if it was clear it was a stolen dog and the person then produced a microchip.

Does share information with Revenue on dog breeding establishments and the number of dogs that are sold by each one?

Mr. Paul Savage

The dog breeding establishments are required by law to have their own logs. That is part of their licensing. I do not think all of the dogs that are produced by registered breeding establishments are sold on our site. Some are sold privately, and others are sold internationally. They have to keep logs and records. Registered sellers of pets are also required to keep a record.

Does keep a record of that? When I went on to the site in advance of the meeting, I could see the same dog breeding establishment, in a number of different adverts, was selling dogs that were only a couple of weeks apart in age. The adverts outlined there were ten dogs, for example, in one litter and nine dogs in another litter. Does collate the information? It was the same dog breeding establishment.

Mr. Paul Savage

We have the information on sales but we have never had a request to share it. The information is stored on the system.

Is it the case that has the information if Revenue comes to it?

Mr. Paul Savage

If there was a request, we would be happy to help.

I wish to ask a supplementary question following on from the question on Revenue. Mr. Savage says he has never had a request. I want to be clear that he means he has never had a request from Revenue for information.

Mr. Paul Savage

Revenue has never asked.

That is grand. I thank Mr. Savage.

I thank the witnesses for participating in today's meeting. We will suspend to allow the witnesses for the second session to take their seats.

Sitting suspended at 6.55 p.m. and resumed at 7.02 p.m.