Top livestock cross-compliance breaches and how to avoid them

Failings in cattle and sheep identification and animal welfare issues topped the league table of cross-compliance breaches in 2020, provisional inspection results show.

Of more than 8,140 Basic Payment Scheme (BPS) inspections carried out in 2020, 1,014, or 14%, identified failures in compliance.

These resulted in a range of actions, from 194 warning letters carrying no penalty, to 95 cases where a 15% penalty was applied.

Livestock consultant and sheep and beef farmer Ian Cairns said: “The top three on the league table – and it’s been the case for quite a long time – are all livestock-specific inspections.

See also: What to do if you have a health and safety farm inspection

“They are either standalone cattle inspections, standalone sheep inspections, or animal welfare inspections carried out by Animal and Plant Health Agency vets or staff.”

Of the total failures, 537 were for cattle identification.

Of these, 43% resulted in a penalty being applied. More than a third of animal welfare inspections revealed an issue that warranted a failure of cross-compliance.

Top three failures in cross-compliance in 2020

Statutory management requirement (SMR)

Area of inspection

% failure

Number of failures


Cattle ID




Sheep ID



SMR 13

Animal welfare



Source: Farming Advice Service

Mr Cairns suggested five reasons for livestock topping the league table:

  1. Standalone inspections have a sharp focus and involve a lot of detailed checking and linkage between different information systems
  2. Detailed on-farm records are required and checked
  3. The inspector will expect on-farm records to tie up with information from the relevant national database for animal movements: Cattle Tracing System (CTS), Animal Reporting and Movement Service (Arams) for sheep (soon to be moved to the Livestock Information Service (LIS)), and Electronic Movement Licensing (eAML2) for pigs
  4. Discrepancies in individual animal identification on farm. Issues tend to arise, particularly with cattle, when the physical inspection, farm records and national database don’t all tie up neatly
  5. Most farms are more complex businesses than they used to be, with greater potential for movements not to be recorded correctly.

Rationalisation of land parcels in County Parish Holdings (CPH) and Temporary Land Associations (TPH) can help reduce requirements.

Cattle inspection failures

Failures to report cattle movements and errors in recording deaths make up more than half of the breaches in cross-compliance.

Breakdown of main breaches in cattle inspections over past 10 years



% of total


Failure to report movement to British Cattle Movement Service (BCMS)



Animal is dead or presumed dead, but animal documentation is found on farm. Also, animal recorded as dead in records with no passport present and no death reported to BCMS



Movement details not recorded or incorrectly recorded on passport, farm records or Cattle Tracing System (CTS)



Animal not found in farm records


Source: Farming Advice Service


To reduce the risk of failing an inspection, Mr Cairns advised the following action:

Check that information held by the CTS is correct and address any problems promptly. BCMS staff are very good at ironing out errors and putting things right.

Ensure timely reporting to the BCMS:

  • Three days for movements
  • Seven days for deaths
  • 27 days for registering calf births

(If deadlines are missed an on-farm inspection is more likely.)

Sheep inspection failures

Accuracy of on-farm movement records, records of deaths and inconsistencies with data held by Arams are the main areas of concern.


The following action is recommended:

  • Check you have the correct system for your farm for recording and reporting movements between different holdings
  • Carry out on-farm checks and administration with regular checks for lost tags (replace within 28 days) at least twice a year
  • Take time to keep accurate records and update them promptly, whether using electronic identification (EID), record-keeping software packages, or manual recording
  • The more complex the setup, and the larger the number of livestock, the bigger the risk of errors in manual systems. Recording individual animal ID and managing that data is much easier with EID readers.


Mr Cairns said that part of Defra’s strategy to transition from EU-funded schemes in England was to make the delivery of cross-compliance and the inspection process “a bit more user-friendly”.

“It’s still an inspection, but there will be more proportionate use of penalties, and a bit more of an emphasis on providing guidance and advice and targeting efforts to the highest areas of risk,” he added.

For confidential advice on technical queries, call the FAS helpline on 03000 200 301 or email

Ian Cairns was speaking at a webinar on livestock compliance organised by the Farming Advice Service (FAS).

What is covered at an inspection?

Standalone cattle inspection:

  • Full on-farm records check
  • Check of passports held of animals on farm records
  • Physical inspection of all cattle
  • Check of supply of unused tags securely stored

Standalone sheep inspection:

  • Full records check
  • Check of farm copies of movement licences reported to Arams
  • Physical inspection of sheep and goats. With larger flocks, a sample check of at least 60 animals to check ID of those 60 is compliant with age group
  • Check of supply of unused tags appropriate to flock structure

Animal welfare inspection:

  • Medicine record
  • On-farm record of deaths
  • Animals and their care – a large number of penalties are applied when the inspector is not content that either a care package is in place for a sick animal or the level of experience is up to standard for looking after it
  • Handling facilities
  • Housing