Over the past few months, I’ve found myself thinking a lot about governance. Not governance as a set of documents, policies or committee structures, but governance as the thing that sits behind them. What is it that turns a strategy from words on a page into real-world change? What creates genuine leadership, clear direction, and accountability? How do we design systems that don’t simply oversee activity, but actually achieve the outcomes they were created to deliver?

These questions have arisen in several different contexts for me recently, but they have also led me to look again at the governance arrangements for the UK Government’s Replacing Animals in Science Strategy; and, in particular, the newly established Ministerial Committee that will oversee its delivery.

Cross-departmental working is key

In many respects, the introduction of the Ministerial Committee represents one of the most significant developments in the strategy and something we have been calling for for some time. Historically, governance of animal research sat primarily within the regulatory framework established by the Animals (Scientific Procedures) Act, supported by expert advice from the Animals in Science Committee. That system has played an important role in improving animal welfare and advancing the principles of the 3Rs, but ensuring the end of animal use in all but exceptional circumstances is different. It requires ensuring that scientific advances and innovations are invested in, validated, and then actually used in preference to animals. This is not simply about regulatory compliance. It is a scientific, technological, educational, regulatory, cultural, and economic challenge that spans multiple government departments, regulators, funders, universities and industry.

The creation of a cross-government Ministerial Committee recognises this reality. Rather than treating Replacement solely as a Home Office issue, responsibility now reaches across government, with ministers, officials and key delivery partners expected to work together to remove barriers, coordinate action and monitor progress. Alongside an official-level Delivery Group, a commitment to public reporting and the development of key performance indicators, this brings the strategy much closer to recognised principles of good governance: clear leadership, cross-system accountability, transparency and shared ownership of delivery.

Defining success is essential for progress

This is unquestionably progress, but good governance is not simply about who sits around the table. It is also about how success is defined.

Re-reading the strategy, one thing struck me. Most of the commitments (and, therefore presumably the future KPIs) focus on whether Government has delivered what it said it would. Has UKCVAM been established? Has funding been allocated? Have guidance documents been published? Have training programmes been introduced? These are all important milestones, and they should absolutely be monitored. Yet they are measures of delivery, not necessarily measures of transformation.

The fundamental purpose of the strategy is not to establish committees, publish guidance or launch new initiatives. It is to replace the use of animals in science, and that is a different aim.

System transformation vs delivery monitoring

A governance system that is genuinely focused on transformation should increasingly ask whether the research system itself is changing. Are biomedical researchers choosing human-specific methods more often? Are funders expecting alternatives as the default? Are regulators routinely accepting non-animal data? Are universities training the next generation of scientists differently? And, ultimately, are fewer animals being used because better approaches have become the norm?

Perhaps the most notable omission is an explicit theory of change linking today’s activities with tomorrow’s outcomes. The strategy contains many excellent actions, but it says relatively little about how those actions are expected to influence behaviour across the research ecosystem, or how the Ministerial Committee will know whether those behavioural changes are actually taking place. Without that chain of reasoning, there is a risk that success becomes defined by completing actions rather than achieving the system-wide transformation those actions are intended to create.

The long-term challenge of continuity

There is also a broader governance question in that Ministerial leadership brings authority, visibility and the ability to coordinate across government, which are undoubtedly significant strengths. But ministers change. Governments change. Political priorities change. Replacing animals in science is a generational challenge that will extend far beyond any single Parliament or administration. That raises a question about how continuity will be maintained and how momentum will be protected when political attention inevitably shifts elsewhere.

None of these questions diminish the significance of the strategy. Quite the opposite. The publication of the strategy marks an important milestone and demonstrates a welcome ambition to accelerate the development, validation and uptake of alternative methods. We will of course be monitoring developments closely.

What we would like to see

As the Ministerial Committee develops its work programme and performance framework, there are, perhaps, a few questions worth asking.

• How will success ultimately be defined? Will it be measured by the completion of actions, or by demonstrable changes across the research system?
• How will the Committee know that its interventions are driving the cultural, scientific and regulatory changes needed to achieve replacement?
• Will the forthcoming KPIs include indicators of system change alongside programme delivery?
• Does the Committee have sufficient authority to influence the decisions of funders, regulators, departments and research organisations when priorities diverge?
• And perhaps most importantly, what institutional arrangements will ensure that the UK’s commitment to replacing animals in science continues to gather momentum regardless of future ministerial appointments or changes in government?

The governance of the strategy matters because governance shapes outcomes. If the UK is serious about becoming a world leader in replacing animals in science, then the governance of that ambition deserves every bit as much attention as the science itself.