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.