Animal advocates in India are fighting draft rules that would overhaul how the country approves animal experiments, and the fight has drawn significant media coverage. 

Published in the Gazette of India on October 6, the draft Prevention of Cruelty to Animals (Control and Supervision of Experiment, Breeding and Trading of Laboratory Animals) Rules, 2026, would replace the rules that have governed Indian laboratories since 1998, and critics—from PETA India to former Union Minister Maneka Gandhi—have condemned the changes as a rollback of hard-won protections for animals in labs.

But one critical point appears to have escaped that coverage: most of the changes advocates are decrying mirror, or even remain more restrictive than, the rules that govern animal research in the United States.

In other words, India’s proposed “rollback” largely describes how the U.S. system already works.

That may help explain why some coverage has framed India’s proposed changes as aiming to “modernise research approvals.” By that logic, moving India’s system closer to America’s counts as progress—but, in the U.S., we know the reality is otherwise. Here, advocates, lawmakers, and regulators are facing an industry that has failed to modernize, held in place by old conventions and deferential regulations.

The Proposed Changes Would “Shift Control” From India’s Regulator to the Labs Themselves

Under the rules now in force in India, an institution’s own animal ethics committee, or IAEC, generally handles experiments on smaller animals, while experiments on larger animals commonly require clearance from India’s central regulator, the Committee for Control and Supervision of Experiments on Animals (CCSEA). 

The draft would supplant that species-based split with a severity scale. Every experiment would be classified as non-recovery, mild, moderate, or severe, and that classification would determine who approves it:

• Mild and moderate experiments on any species—including larger animals like dogs, monkeys, pigs, horses, and cattle—would be decided by the IAEC alone.
• Non-recovery and severe experiments on animals larger than rodents and rabbits would still require CCSEA approval after the IAEC’s recommendation.

Animal advocates warn that this change would effectively “transfer[] a major regulatory power from the central committee to the very institutions seeking permission to experiment.” 

Critics of India’s draft have also argued that the changes would increase the risk to animals by: 

• putting the “ease of doing business” ahead of animal welfare, 
• reducing “friction” for researchers, 
• letting institutions with competing research and commercial interests make critical decisions, and 
• making it “easier” for labs to carry out invasive procedures without independent review.

They are right, and what they describe is the very foundation of the U.S. system.

What India’s Advocates Fear Is Already the Norm in the U.S.

No national regulator reviews or approves American animal experiments before they begin, regardless of species or severity. That authority rests with Institutional Animal Care and Use Committees (IACUCs), which sit inside the same institutions whose work they approve. 

The setup now raising alarm in India is already the reality here. 

As one petition opposing the draft puts it: 

‘What does this mean? It means that highly sensitive, social small animals like dogs (beagles), as well as monkeys, pigs, and cattle, can be subjected to invasive surgeries, tumor inductions, and genetic mutilation with no independent, central oversight.’ 

In the U.S., that has been true for decades. Every protocol that requires approval at all is approved by the institution’s own IACUC—and some experiments require no approval whatsoever, because the animals being exploited fall outside the Animal Welfare Act (AWA) and the facility receives no federal funding.

Even if India’s draft takes effect as written, Indian labs would still have to send non-recovery and severe experiments on dogs, monkeys, and other larger animals to a national regulator for a decision—meaning that the draft builds in a layer of outside review that the U.S. lacks entirely.

The same goes for the committees themselves.

Even Under the Draft, Indian Committees Would Seat More Outsiders Than American Ones

Critics point out that IAECs are “part of the establishment,” even though they include members nominated by CCSEA. Under the draft, five of each IAEC’s nine members would come from the research facility itself, giving insiders a majority at a fully attended meeting. The other four seats would go to nominees appointed by CCSEA, and at least two of them would have to be present before the IAEC could act.

U.S. requirements are thinner.

The AWA requires an IACUC of just three members—including at least one veterinarian (with responsibility for the institution’s animal research program) and at least one member “unaffiliated” with the institution—all appointed by the institution’s chief executive. 

Institutions funded by the Public Health Service must seat at least five members, but the structure is the same: the institution chooses every member, only one must come from outside, and no regulator nominates anyone. Nothing in U.S. law even requires that the lone outsider be present when a protocol is approved.

So, even under the proposed rules, Indian IAECs would bring more institutional outsiders into the room than U.S. IACUCs do.

But more institutional outsiders is not the same as real oversight. CCSEA is itself a government body, and PETA India has criticized its core committee as being dominated by representatives of animal experimentation institutions. That pattern is familiar in the U.S., where federal agencies like USDA and NIH, charged with overseeing animal research, also fund and engage in the practice.

In Both Countries, Those Seeking Approval Decide How Much an Experiment Will Hurt

Animal advocates warn that “vague or generous grading” of animal experiments as mild or moderate could become the route by which larger-animal experiments escape central scrutiny in India. The concern is well-founded: under the draft, the institution that wants to perform the experiment classifies its severity, and the IAEC’s veterinarian—one of the institution’s own members—certifies that classification.

In the U.S., this kind of self-classification has long been routine. 

American researchers assign their experiments to USDA pain categories, which are supposed to indicate whether an experiment causes pain and whether that pain is relieved—even though federal regulations fail to define “pain” (or “distress”). Institutions then report how many animals fall into each category, but those categories dictate only what gets reported to USDA (not, as they would in India, who approves the experiments). 

India’s draft would also go further than U.S. law in another respect: it would prohibit experiments involving severe pain that is likely to be long-lasting and cannot be relieved. It would fall to the institutions themselves to apply that ban, but U.S. law contains no comparable prohibition at all.

Here, virtually anything can be done to any animal, so long as the researcher who wants to do it justifies it in writing and their own institution’s committee signs off.

U.S. Law Doesn’t Even Count Most Animals as Animals

India’s rules would apply broadly to vertebrate animals, including some animals at early stages of development, such as independently feeding fish larvae, embryonated eggs, and mammalian fetuses in the last third of their development. But the draft still draws arbitrary species-based lines beyond the one between vertebrates and invertebrates. PETA India has rightly objected that rabbits and other small animals could be subjected to non-recovery or severe experiments without CCSEA review “‘simply because of their species — even though severe pain and suffering are no less serious in these animals….’” 

The objection is valid, and the same species-based logic runs even deeper here.

In the U.S., no animal of any species receives central review, and the AWA excludes the overwhelming majority of animals used in labs (an estimated more than 99%) from its definition of “animal” altogether.

The Rest of India’s Proposed “Rollback” Already Reads Like U.S. Law

For most of the remaining changes, the pattern is the same: India would be moving closer to the U.S. For example: 

• The draft would permit animals to be used for higher education and professional training, including the acquisition of vocational skills. In the U.S., using animals in teaching and training is common and fully permitted under the AWA.
• Though the draft would bar the use of stray dogs, cats, and other domestic animals, critics warn that, unlike the rules now in effect, it would let unspecified “competent authorities” grant exemptions. The U.S. has never enacted a federal ban on using “random source” dogs and cats, and some states still permit pound seizure—the procurement of shelter animals by labs.

Indian Advocates Are Right—and Their Arguments Indict the U.S. System

Indian advocates are right to fight these proposed changes. Their core arguments—that animal research facilities should not approve their own experiments and that the people who profit from animal research should not be allowed to regulate the practice—are valid. But those arguments don’t stop at India’s border.

The criticisms leveled at the draft apply with even greater force to the U.S., 

where self-approval is not a proposal but the law, 

where no national regulator reviews experiments before they begin, and 

where most animals in labs are not even legally considered “animals” at all.

The controversy in India shows what happens when a public recognizes industry self-regulation for what it is, and it should inspire us in the U.S. to look more closely, and critically, at our own system.

If India wants to modernize, the U.S. offers a cautionary tale, not a model.

Adopting the draft would be a step backward for India—and a step closer to the U.S. system. Outrage is warranted here, too.

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About the Author: Lindsey Soffes is Head of Programs at Rise for Animals. She holds a law degree from William and Mary Law School and has spent her career advocating for the rights of all animals—both human and non-human.