10 most common cross-compliance breaches and how to avoid them

Failing to conform to bovine tuberculosis testing intervals has topped a livestock-heavy list of the most common cross-compliance breaches.

The rules apply to all Basic Payment Scheme (BPS) claimants and are made up of statutory management requirements (SMRs) and standards for good agricultural and environmental conditions.

Any breach results in the Rural Payments Agency (RPA) imposing a penalty. This involves BPS payments or agri-environment payments being reduced by a certain percentage depending on the severity of the breach.

See also: Handy guide to key cross-compliance dates 2019

Farmers Weekly has listed the top 10 most common cross-compliance breaches found during the 2018 inspection programme, according to the RPA’s records.  

Top tips for preventing these cross-compliance breaches have been provided by cross compliance experts CXCS.

Bovine TB testing intervals

Number of breaches: 674

Reference: SMR 4 – D10 (i)

Breach type: Failure to ensure that all eligible animals conform to national herd/flock health surveillance and testing intervals for TB.

Top tips to avoid penalties:

  • Pre-movement testing is needed when moving cattle to another county parish holding, if the move is not within 60 days of the full herd test, unless a temporary land association has been established.
  • If handling facilities are inadequate for the test, a vet can refuse to perform the test.

Current year records

Number of breaches: 303

Reference: SMR 1 – A1 (2016)

Breach type: Current year records incomplete, not presented or do not exist.

Top tips to avoid penalties:

  • The farm-loading calculation is done on the basis of a calendar year. Calculate the farm loading by 30 April for the previous year.
  • Animals stipulated in the NVZ guidance and manures produced/imported must be included in the whole farm loading calculation, including digestates containing any proportion of animal waste, but not items such as sludge, paper waste or compost.
  • Observe closed periods, according to soil type and crop, for both fertiliser and manures with a high available nitrogen (over 30% available).
  • Get someone to double check your calculation when complete.


Number of breaches: 229

Reference: SMR 8 – A5 (iv) (2016)

Breach type: Sheep/goat movement records not maintained to legal standard.

Top tips to avoid penalties:

  • Records are needed if sheep are being moved to a holding with a different county parish holding number, regardless of distance. The exception to this is if the field is joining the main county parish holding and there is an open gate between the fields for frequent movements (daily).
  • Alternatively a temporary land association can be set up with the Animal and Plant Health Agency.
  • Keep three years of sheep records on the holding.
  • Number each movement licence and reference this number in your on/off movements sections in your holding register to make it easier to cross reference.


Number of breaches: 164

Reference: SMR 8 – A5 (v) (2016)

Breach type: Sheep/goat replacement tags not maintained to legal standard.

Top tips to avoid penalties:

  • Make sure you tag your sheep and/or goats: within six months of birth if they’re housed overnight; within nine months of birth if they’re not housed overnight; before you move them off their holding of birth if this is sooner.
  • Make sure replacement tags are recorded in your holding register.
  • Make sure any missing tags are replaced within 28 days of noticing the tag is missing.


Number of breaches: 149

Reference: SMR 8 – A5 (vi) (2016)

Breach type: Sheep/goat deaths records not maintained to legal standard.

Top tips to avoid penalties:

  • Make sure all deaths are noted in your holding register

Animal identification

Number of breaches: 142

Reference: SMR 8 – A5 (vii) (2016)

Breach type: Sheep/goat animal identification records not maintained to legal standard.

Top tips to avoid penalties:

  • See advice for Tags

Sick animals

Number of breaches: 132

Reference: SMR 13 – A4

Breach type: Animal has not been cared for appropriately or there has been an unacceptable delay in the care of the sick animal.

Top tips to avoid penalties:

  • Routinely check the welfare of all livestock on the holding.
  • Take into consideration changes in weather conditions which may cause distress.

Medicine records

Number of breaches: 131

Reference: SMR 13 – A6

Breach type: No medicine records are kept or are unavailable at the time of the inspection; records are kept, but are inaccurate or missing information; records have not been kept for the required period of time.

Top tips to avoid penalties:

  • Ensure your vet and medicine records are kept up to date.
  • Invest in an official vet and medicine book, which has all the required information listed in columns.

Stock conditions

Number of breaches: 124

Reference: SMR 13 – A13

Breach type: No well-drained lying area for stock not kept in buildings or lack of protection from adverse weather conditions, predators and/or other risks to health.

Top tips to avoid penalties:

  • Ensure housing conditions are adequate: Bedding; building structure; shelter; stocking occupancy; consider adverse weather and make any necessary amendments.

Staff resources

Number of breaches: 123

Reference: SMR 13 – A1

Breach type: Number of staff available insufficient to prevent welfare problems occurring or stockperson demonstrates lack of professional competence and/or ability in livestock care.

Top tips to avoid penalties:

  • Make sure there is enough staff to carry out essential welfare checks and procedures on site. This should be all year round with no exceptions.
  • Keep on top of staff training, including agency or temporary staff.