A nonpartisan Congressional Research Service report found that APHIS has fewer inspectors than last year, is not following its own risk-based inspection system, and has no documented process for handling complaints — while 80% of facilities reviewed were found noncompliant. This report was requested by Congress and represents the most authoritative public assessment of USDA's enforcement posture in years.
In May 2025, the Congressional Research Service — Congress's own nonpartisan policy research arm — published Report IF13002, a frank assessment of USDA Animal Care (APHIS) enforcement. The report was prepared at the request of members of Congress seeking an objective, data-driven picture of how the Animal Welfare Act is being enforced in practice. Its findings are sobering.
First, inspector staffing has declined. APHIS has fewer animal care inspectors than it did the prior year, even as the regulated population remains substantial. The report notes that the agency is not consistently following its own risk-based inspection system, which was designed to prioritize higher-risk facilities. In practice, inspections appear to be scheduled without clear risk weighting, reducing the effectiveness of limited resources.
Second, the report found no documented, standardized process for handling complaints — the primary mechanism by which animal welfare concerns are reported to the agency. Complaints arrive from the public, from animal rights organizations, from veterinarians, and from internal sources. Without a documented intake and triage process, there is no way to ensure consistent, timely, or fair handling of these complaints across regions and inspectors.
Third — and perhaps most striking — the CRS reviewed inspection outcomes and found that approximately 80% of facilities inspected were cited for at least one noncompliance. While this could reflect either widespread industry noncompliance or aggressive inspection standards (or both), the sheer consistency of the finding raises questions about whether the inspection regime is achieving its intended purpose of improving animal care, or primarily generating paperwork.
For licensed and registered facilities, the implications are significant. The report signals congressional scrutiny of APHIS enforcement, which may lead to legislative pressure for more inspections, more citations, and more aggressive enforcement. Facilities that have been operating on the assumption that inspections are predictable and manageable may face a shifting landscape. The best preparation is not reactive — it is proactive documentation, consistent compliance, and a clear understanding of what inspectors are required to examine under 9 CFR Parts 2 and 3.
This CRS report is arguably the most authoritative public assessment of USDA's animal welfare enforcement posture in years. Unlike advocacy reports or media investigations, it carries the institutional weight of Congress's research service and draws directly from agency data. Licensees and registrants should read it carefully — not because it will change the regulations overnight, but because it signals where enforcement attention and political pressure are heading.