Controlled Drugs Register for UK Vets: Storage and Who Can Sign

A controlled drugs register is required for every Schedule 2 CD a UK vet practice buys or supplies (MDR 2001 reg 19). Format, storage, signatures, audits.

Verika Editorial··8 min read·United Kingdom

Short answer: In Great Britain, any vet practice that buys or supplies a Schedule 2 controlled drug, such as ketamine or fentanyl, must keep a controlled drugs register under regulation 19 of the Misuse of Drugs Regulations 2001. Entries go in on the day (or next day), can't be altered, and the register is kept two years from the last entry (regulation 23).

This guide covers England, Scotland and Wales. Northern Ireland has its own Misuse of Drugs Regulations (Northern Ireland) 2002 and different destruction rules, which the RCVS and VMD flag separately. We checked the legislation and guidance on 7 October 2026. legislation.gov.uk showed the 2001 Regulations up to date to 5 October 2026, with one pending amendment that doesn't touch veterinary record keeping.

Which controlled drugs need a register, a cabinet and a witness?

It depends on the schedule. The RCVS controlled drugs guidance sums up how each schedule is handled in practice:

ScheduleVeterinary examples (per RCVS)CD registerSafe custody (locked cabinet)Witnessed destruction of stock
1None. Needs a Home Office licence, so vets can't supplyn/an/an/a
2Ketamine, fentanylYes, reg 19Yes, except quinalbarbitone (RCVS still requires it locked away)Yes
3Buprenorphine, tramadol, gabapentin, pregabalin, barbituratesNoOnly buprenorphine, diethylpropion, flunitrazepam and temazepam by law; RCVS requires all Schedule 3 locked awayOnly if prepared extemporaneously under the Cascade
4Most benzodiazepines (Part 1); anabolic steroids (Part 2)NoNo legal requirementOnly if prepared extemporaneously under the Cascade
5Low-strength preparations such as some codeine or morphine productsNoNoNo

The VMD also publishes a list of authorised veterinary medicines containing controlled drugs, with each product's schedule and whether safe custody applies. Check a product there rather than guessing from the active ingredient.

What has to go in a veterinary CD register?

Regulation 19(1)(d) and (e) set the column headings, and the VMD's guidance repeats them for practices.

When you receive a Schedule 2 CD:

  1. Date supply received
  2. Name and address of the supplier (for example, the wholesaler)
  3. Quantity received

When you supply it, including by administration to an animal:

  1. Date supplied
  2. Name and address of the person or firm supplied
  3. Details of the authority to possess (prescriber or licence holder)
  4. Quantity supplied
  5. Who collected it: animal owner, owner's representative, or healthcare professional (with name and address if a professional)
  6. Whether proof of identity was requested (yes or no)
  7. Whether proof of identity was provided (yes or no)

The VMD also recommends a running balance after every entry. That isn't in regulation 19, but it is how you find a discrepancy in days rather than months.

How must the register be kept?

Regulation 20 sets the format rules. In plain terms:

  • One class of drug per register or section, with a separate page for each strength and form, named at the top of the page (20(a)).
  • Enter on the day the drug is received or supplied, or the next day if that isn't reasonably practicable (20(b)).
  • No cancellations, obliterations or alterations. Corrections go in a dated margin note or footnote (20(c)). The VMD adds that corrections should be signed.
  • Ink or an auditable computerised system where every entry is attributable (20(d)). Both the VMD and RCVS say a bound book only, no loose-leaf or card index. The RCVS adds that a practice management system doesn't count unless it meets the requirements for a computerised CD register.
  • Used for nothing else (20(e)).
  • One register per premises, kept at those premises (20(f) and (g)). The RCVS asks for a separate register for each cabinet, and a separate register for CDs kept in a vehicle.
  • Kept for two years from the last entry (reg 23(1)).

Who can sign the register and other CD records?

Several people can sign, but legal responsibility sits with the vet. Here's who signs what, according to the RCVS and VMD guidance:

RecordWho can sign or complete it
Day-to-day register entriesA suitably trained, authorised person such as a veterinary nurse. Responsibility stays with the prescribing vet
Running-balance checkThe RCVS recommends marking the balance as checked and countersigned. This can be anyone responsible for the register, not necessarily a vet
Correction of an entrySigned and dated note in the margin or at the foot of the page
Discrepancy explanationThe appointed senior vet makes the entry, witnessed and signed by another vet or a veterinary nurse
Destruction of Schedule 2 stockThe authorised witness signs, recording date and quantity (reg 27(3)). An independent vet also records their RCVS number and a statement of independence
Waste (unusable residue, drawn up but not given)Recorded and denatured, no formal witness needed. The RCVS says it's good practice for another vet or RVN to countersign
Returned CDs from clientsNo legal witness requirement. The RCVS recommends a separate returns record, countersigned by a second member of staff
Prescriptions for Schedule 2 and 3Signed in ink by the prescribing vet, with their RCVS number. No electronic signatures

Who counts as an independent witness for destruction?

A vet who has no personal, professional or financial interest in the practice. The VMD says temporary staff and family members of staff don't count. The witness can't accept payment beyond reasonable travel costs. A vet from the same corporate group can witness if the practices have different owners and are separate legal entities. Don't use the same witness every time. The VMD charges £142 for a dedicated witness visit, or £31 if it's done during an inspection.

How should CDs be stored?

Answer: in a locked cabinet that meets the safe custody standard, bolted down, with controlled keys. The Misuse of Drugs (Safe Custody) Regulations 1973 require drugs that are subject to safe custody to be kept in a locked safe, cabinet or room built and maintained to prevent unauthorised access, or otherwise in a locked receptacle that only the holder or someone they authorise can open (regulations 3 and 5). Schedule 2 of the 1973 Regulations sets the structural standards. Note that legislation.gov.uk only shows the 1973 Regulations as originally made, so rely on the RCVS guidance for which drugs are currently in scope.

The RCVS adds these practice expectations:

  1. Cabinet bolted to the wall or floor, ideally double-locked, with a lock different from every other lock in the building.
  2. Nothing on the outside to show it holds CDs. Situated away from public view in a room clients don't enter unsupervised.
  3. Access only for a vet or a nominated responsible person authorised by a vet. A non-vet keyholder removes or returns CDs only on a vet's specific authority.
  4. Keys not kept with other building keys, not hidden in a desk drawer. A wall-mounted combination key box is acceptable if the combination changes regularly and whenever staff change.
  5. Combination locks changed at least every six months, following Home Office good practice.
  6. In vehicles, Schedule 2 and 3 CDs go in a locked receptacle fixed to the vehicle and out of sight, with a separate CD register for the vehicle.

How often should you audit, and what if it doesn't balance?

At least weekly. A full audit and reconciliation of Schedule 2 CDs against the register is an RCVS Core Standard requirement, and the RCVS expects all CDs to be audited regularly, at least weekly. Some loss to needle and syringe dead space is unavoidable with multi-dose vials. The VMD says small discrepancies explained by dead space aren't treated as a breach, as long as you record what was withdrawn each time and write the vial off when nothing usable is left.

If the count doesn't match:

  1. Tell the appointed senior vet straight away.
  2. Check deliveries were entered on the right page, that every administration was recorded, and that nothing is in the wrong place in the cabinet, a vehicle or a bag.
  3. Have two people re-check the arithmetic and the bottle volumes.
  4. Check entries against clinical records.
  5. If you find the cause, the senior vet records the reason and corrected balance, witnessed and signed by a vet or veterinary nurse.
  6. If not, investigate further. Consider contacting your police Controlled Drugs Liaison Officer and changing cabinet codes.

How long do you keep prescriptions and other CD records?

The two sources don't give the same figure. Regulation 23(3) requires veterinary prescriptions on which a controlled drug is supplied to be kept for two years from the last delivery. The RCVS tells practices supplying Schedule 2 and 3 CDs against another vet's prescription to keep the prescription for at least five years, and to keep invoices and usage records for Schedule 3, 4 and 5 CDs for five years. Use five years, which meets both.

Other points from the RCVS guidance:

  • Schedule 1 to 4 prescriptions are valid for 28 days; Schedule 5 for six months.
  • No repeat prescriptions for Schedule 2 and 3. Use an instalment prescription if supply needs to be spread out.
  • For both acute and chronic conditions, prescribe no more than 30 days' worth unless there's a justified clinical need, and record the reason in the clinical notes.
  • Requisitions for Schedule 2 and 3 stock use the specified form (in use since 30 November 2015).

Getting the answer on a busy shift

A practice SOP is only useful if staff can find the right line quickly. If you upload your CD SOP, key-holder list and destruction procedure to Verika, a nurse can ask "who can witness us destroying out-of-date ketamine?" and get the answer from your own SOP, with the document named. If your SOP doesn't cover it, Verika says so and logs the question for your clinical director to answer once. Verika doesn't come with veterinary legislation built in, so it answers only from what your practice has uploaded or approved. There's more on how it works for clinics on the veterinary page, or you can start a free trial.

Sources

  1. The Misuse of Drugs Regulations 2001, regulation 19 (record-keeping requirements for Schedules 1 and 2) — legislation.gov.uk, up to date to 5 October 2026
  2. The Misuse of Drugs Regulations 2001, regulation 20 (requirements as to registers) — legislation.gov.uk
  3. The Misuse of Drugs Regulations 2001, regulation 23 (preservation of registers and documents) — legislation.gov.uk
  4. The Misuse of Drugs Regulations 2001, regulation 27 (destruction of controlled drugs) — legislation.gov.uk
  5. The Misuse of Drugs (Safe Custody) Regulations 1973, regulations 3 and 5 and Schedule 2 — legislation.gov.uk (original version as made)
  6. Controlled drugs: recording, using, storing and disposal — Veterinary Medicines Directorate, GOV.UK, updated 5 August 2025
  7. Controlled Drugs Guidance – A to Z — Royal College of Veterinary Surgeons, accessed 7 October 2026

Frequently asked questions

›Do Schedule 3 drugs like buprenorphine need to go in the CD register?

No. The register under regulation 19 of the Misuse of Drugs Regulations 2001 covers Schedule 1 and 2 drugs. Buprenorphine is Schedule 3, but it is subject to safe custody and the RCVS requires all Schedule 3 CDs to be locked away.

›Can a veterinary nurse fill in the controlled drugs register?

Yes. The RCVS says the register can be maintained by a suitably trained and authorised person such as a veterinary nurse, but responsibility stays with the prescribing veterinary surgeon.

›How long must a vet practice keep its controlled drugs register?

At least two years from the date of the last entry, under regulation 23(1) of the Misuse of Drugs Regulations 2001. The VMD and RCVS guidance repeat the two-year minimum.

›Who can witness the destruction of Schedule 2 controlled drugs at a vet practice?

In Great Britain, an inspector appointed under the Veterinary Medicines Regulations (including VMD inspectors and RCVS Practice Standards Scheme assessors), a vet independent of the practice, or another authorised person such as a police Controlled Drugs Liaison Officer. Northern Ireland has different rules.

›How often should a vet practice audit its controlled drugs?

The RCVS expects all CDs to be audited regularly, at least weekly, and makes a full audit and reconciliation of Schedule 2 CDs a Core Standard requirement.

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