Frequently Asked Questions About the
Licensing Legislation for Professional Dog Trainers
Note: *NEW* and *UPDATED* FAQs addressing revisions in the Model legislation.
- *UPDATED* Why is licensure important to our profession?Licensure and the qualifications associated with it advance recognition and validation of the dog training profession. Without licensing requirements, it’s a “buyer beware” system for dog owners seeking professional dog training or behavior consulting. And those most at risk from unqualified or abusive trainers are the animals, who have no say in how careful or well-informed their owners are in selecting the trainers who are entrusted with their dogs. Even dog owners seeking qualified trainers may not know what credentials they should look for in a professional dog trainer. The model licensing legislation builds on current training and certification and adds a level of consistency by setting minimum standards and providing for enforcement of those standards. All 50 states have licensing laws for occupations where public safety and protection are at stake; dog owners and their companion dogs deserve a similar level of protection. At least two states have already introduced bills to license professional dog trainers (see #3 below).
- *UPDATED* What’s the harm in allowing dog trainers to do business without any certification or licensing?
- An eight-month-old puppy enrolled in a five-week training course died from strangulation due to the trainer’s use of a choker collar to apply pressure to the dog’s neck during a “power struggle”; the trainer was convicted of animal cruelty – Wisconsin, October 2020
- Forty-one dogs were found severely neglected, with many emaciated, after authorities searched a dog training business; citations were issued against the trainer – South Carolina, May 2021
- Twelve dogs were found at a training facility with untreated injuries and no access to food or water in feces-filled crates; the trainer was charged with felony animal cruelty – Virginia, March 2021
- A dog trainer stabbed and killed a dog with pocketknife in an failed attempt to “control the dog”; the trainer was charged with torture of an animal – Kentucky, April 2020.
These appalling incidents all led to law enforcement involvement and criminal charges, but substandard training can also harm dogs in lasting ways for which animal mistreatment laws provide no remedy, by causing stress, trauma, and behavioral problems. By enforcing minimum requirements for practice of the profession, licensing would help protect against these undesirable outcomes. Certification organizations can develop the content of standards for professional dog training, but enforcement of standards is more effectively done by a licensing agency. Private certification organizations lack the legal authority and the resources to serve as a substitute for licensing boards in protecting the welfare of the animals entrusted to dog trainers and behavior consultants.
- What goals does the Alliance have for promoting model licensure legislation beyond assuring the public they are hiring a qualified professional?Another primary goal of developing model legislation on dog trainer licensure is to have a voice in shaping such legislation in the most informed and effective manner. In at least two states, legislation to require licensure of dog trainers was introduced, without CCPDT, APDT, or any other dog training organization proposing the legislation or being offered the opportunity to comment on it. The Alliance has developed a model for such legislation that (1) prioritizes the well-being of the dogs receiving training, (2) provides assurances to the public of the competencies and quality of dog trainers, (3) is appropriately inclusive of other pathways to licensure besides CCPDT certification, (4) provides an appropriate and balanced structure of licensing board oversight of dog trainers, and (5) supports dog trainer geographic mobility. State legislators routinely utilize model legislation developed by stakeholders and/or experts as a guide in crafting formal legislation.
- *UPDATED* How will a dog trainer obtain or renew a license? How will licensing for currently practicing dog trainers be handled? Are there any exemptions from dog trainer license requirements?The model legislation proposes that, once a state’s Dog Trainer Licensure Board is up and running, an individual in the state who works as a professional dog trainer for financial compensation would need a license or a provisional permit (see #8 below), unless they qualify for an exemption. During a transitional phase-in period, currently practicing dog trainers with at least one year of experience, and who commit to abide by LIMA or any Board policies that are more restrictive of aversive practices, can be granted an initial license on the basis of that experience. After the transitional period, or for new applicants or renewal of licensure, a dog trainer must be an adult of good professional moral character (see #5 below for the definition), and must hold current certification either (i) in dog training (which may include certification in dog behavior consulting) from an Approved Certification Program (see #7 below) or (ii) as a Certified Applied Animal Behaviorist or Associate Certified Applied Animal Behaviorist.A dog trainer license is not required of exempt professionals who are already licensed in a related field and who hold an advanced degree or certification the Licensure Board regards as equivalent to the credentials from Approved Certification Programs, such as board-certified Veterinary Behaviorists and licensed veterinary technicians holding VTS (Behavior) certification.The revised model legislation also exempts from State licensure requirements active military service members who train dogs in connection with their military service roles, active law enforcement in connection with K-9 training, and incarcerated persons engaged in dog training under the auspices of a penal institution’s program.The Licensure Board would issue licenses for a three-year term, and renewal of licenses would be based on payment of a reasonable fee and evidence that the licensee continues to hold one of the required current certifications.Licenses and permits would be issued in the legal name of the applicant, but applicants could direct the Board to include on their license or permit additional alternative names that the applicant uses personally and/or professionally.
- *NEW* How is “good professional moral character” defined in the model legislation?The revised model legislation has been modified to now define “good professional moral character” to mean that the dog trainer has not abused a position of trust or engaged in fraud or engaged in conduct that poses a substantial risk to the health or safety of the public or of animals under the person’s care or supervision, or that the dog trainer has demonstrated sufficient evidence of rehabilitation commensurate with the seriousness of the person’s past misconduct, as determined by the Licensure Board. At the application stage, the Licensure Board would be responsible for defining what documentation would need to be submitted to establish this element, as well as making the determination about whether the applicant has met the requirement.
- *NEW* What educational prerequisites, if any, are spelled out in the model legislation?The revised model legislation no longer requires that licensed dog trainers or provisional permit holders have earned a high school degree or GED. Some dog trainer certification programs require certificants to have an educational preparation, and individual Licensure Boards will determine the minimum education and/or experience eligibility requirements that certification programs must have to be recognized as Approved Certification Programs. Each state legislature will determine the minimum education levels that licensees should be expected to have, given that many licensed dog trainers will operate their own dog training businesses.
- *UPDATED* Who will determine which programs qualify as an Approved Certification Program in each state?The model legislation supports multiple options for professional dog trainer certification. Under the bill, each Licensure Board would establish the criteria for Approved Certification Programs. The criteria would include minimum dog trainer education and/or experience eligibility requirements, adherence to LIMA or to policies equivalent to or even more restrictive of aversive practices than LIMA, as adopted by the Licensure Board, and maintenance of certification requirements for continuing education units. Any examination-based dog trainer certification program that is accredited by the National Commission for Certifying Agencies and meets those requirements would be an Approved Certification Program, and the Licensure Board would also review other examination-based dog trainer certification programs for approval. The Licensure Board would maintain a list of Approved Certification Programs, as well as a list of approved dog trainer education programs that meet minimum education requirements for Approved Certification Programs.
- *UPDATED* Does the model legislation include a process for inexperienced dog trainers or uncertified professionals to offer professional dog trainer services? During the transitional period after licensing regulations are first rolled out, currently practicing dog trainers with at least one year of experience would not be required to hold a current certification. In addition, the model legislation also calls for the Licensure Board to issue provisional dog trainer permits that would authorize unlicensed applicants to provide dog training services under the supervision of a licensed dog trainer for renewable one-year periods, without holding current certification from an Approved Certification Program or as a Certified Applied Animal Behaviorist or Associate Certified Applied Animal Behaviorist. These permits would enable individuals to develop the work experience required by some certification programs and give those individuals more time to earn their certifications, and also allow dog training businesses to employ provisional permit holders who have not earned certification, in addition to licensed dog trainers.
- *UPDATED* What is the proposed level of supervision required for a trainer holding a provisional permit?Aspiring trainers and other dog trainers who have not earned certification from an Approved Certification Program can qualify for a provisional permit under the provisions in the model legislation. Provisional permit holders must work under the supervision of one or more licensed dog trainers. The level of supervision would be up to the licensed dog trainer, and the model legislation does not include a requirement that the licensed dog trainer be continuously present while the permit holder is working with a dog. However, a supervising licensed dog trainer must take responsibility for the quality of the permit holder’s dog training work as well as any complaints regarding the permit holder’s dog training. Failure to adequately supervise the dog training services of provisional permit holder who provides those services under the supervision of the licensee would be a basis for discipline by the Licensure Board, if a complaint is lodged. Supervision requirements of this nature are common in many licensed professions, including health care professions.
- *NEW* Will licensed dog trainers be able to provide services remotely?Yes. The revised model legislation clarifies that any person authorized to practice dog training in the State may conduct such dog training or provide dog behavior consultant services in person and by live, remote means, for any dog located in that State. However, if a dog trainer is providing services by remote means to a dog in a different jurisdiction, the location of the dog receiving the services will determine which law applies. No State has the authority to override another State’s contrary laws. As far as the licensing State is concerned, the model legislation authorizes a licensed dog trainer to practice in-person or remotely either within or outside the State – unless the services are provided in a different jurisdiction that prohibits or restricts such practice. In addition, the model legislation calls for states to adopt reciprocal licensing procedures to enhance dog trainer geographic mobility (see #11 below). Legislatures are increasingly adopting reciprocal licensing measures, whether profession-specific or applicable to all licensed occupations, especially with respect to individuals who practice in adjoining jurisdictions.
- *UPDATED* What about out-of-state dog trainers?The model legislation calls for Licensure Boards to adopt regulations to allow for short-term limited dog training or dog behavior consultant services by out-of-state practitioners who hold current certification from an Approved Certification Program, or as a Certified Applied Animal Behaviorist or Associate Certified Applied Animal Behaviorist, but who do not hold a license in the State. The Licensure Board would also adopt procedures to allow such individuals to apply for temporary limited permits that authorize the individual to work in the State as a dog trainer for a longer, but still limited, period of up to a specified maximum number of days per calendar year. These provisions would apply to out-of-state dog trainers who perform services either in-person or virtually in a state that requires licensure. The model legislation also calls for reciprocal licensure for individuals who hold current certification in dog training from an Approved Certification Program, or as a Certified Applied Animal Behaviorist or Associate Certified Applied Animal Behaviorist, and who hold a dog trainer license issued by another State.
- *NEW* What dog training disciplines are covered by the model legislation?The disciplines covered are those where consumer protection is of concern and in which federal or state government agencies do not already oversee the conduct of dog trainers. According to the model legislation, “dog behavior consultants” means those who engage in the practice of evidence-based applied behavior analysis and behavior modification of dogs, in areas such as fearful behavior, compulsive behaviors, anxiety, or aggressive behavior, when performed for consumers or dog owners for financial compensation. These professionals – including those who train sporting dogs – are included in the definition of “dog trainers” who will be required to hold a license or permit in order to offer training services to others for financial compensation. Dog behavior consultants are separately defined in the model legislation because of the requirement that one of the dog trainer members serving on the Licensure Board hold a professional certification as a dog behavior consultant. Otherwise, the model legislation’s provisions governing dog trainers apply equally to dog behavior consultants and those professionals engaged in other forms of dog training instruction or services.The revised model legislation clarifies that a dog trainer license is not required for those who may seek to modify the behavior of dogs on an incidental basis ancillary to other services, such as dog grooming or dog walking.A dog trainer license will not be required for active duty military service members who train dogs in connection with their military service roles, for active duty law enforcement in connection with K-9 training, or for incarcerated persons who train dogs under the auspices of a penal institution’s program.
- *UPDATED* Who would serve on the Licensure Boards and why?The model legislation calls for the Licensure Board to have nine members, appointed by the Governor of the State, which is the model for most occupational licensure boards. The members would consist of a state agency employee, four professional dog trainers who hold the required certification or license (including at least one holding a professional certification as a dog behavior consultant), a licensed veterinarian who is either a board-certified veterinary behaviorist or has professional certification in dog training, a representative of a nonprofit animal welfare group, and two public members who have used dog trainer services but have no financial or professional connection to dog training businesses. This broad composition avoids potential antitrust concerns by ensuring that the Licensure Board is not dominated by active market participants, and it ensures a balance of perspectives, including from those with a specialized focus in the medical or overall welfare of dogs, from consumers who are the end users of dog training services, and from a state agency employee familiar with licensing and governmental procedures. In addition to the oversight Licensure Board, the model legislation authorizes appointment of an employed Executive Director and, as needed and if funding is available, support staff, to carry out the day-to-day administration of licensing activities. This also is the structure of most occupational licensure boards: a governing body that adopts regulations and makes disciplinary and enforcement decisions, but whose members serve in addition to holding other regular jobs that qualify them for service on the Licensure Board, and an employed staff that processes applications, answers the phones, and carries out the day-to-day operational and administrative work of the agency. You can have direct input and involvement by applying to be on the Board in your state after the bill has been adopted.
- *UPDATED* How would the Licensure Board enforce compliance with licensure regulations and standards? Under the provisions of the model legislation, the Licensure Board may adopt LIMA, or standards equivalent to or even more restrictive of aversive practices than LIMA, as the practice standards for licensed dog trainers. Any licensed dog trainer or provisional permit holder who violates those standards or engages in other enumerated offenses would be subject to disciplinary action by the Licensure Board, according to procedures established by the Licensure Board. Penalties could include revocation of licensure or revocation of eligibility for licensure, lesser disciplinary actions, and other remedial measures as a condition of licensure. All of the disciplinary provisions have competence, safety, and honest business dealings as their touchstone. Based on comments received, the disciplinary provisions in the revised model legislation no longer treat recent addiction or habitual intoxication as grounds for disciplinary action, and abuse of drugs or alcohol is only deemed relevant if the person provided dog training services while under the influence of alcohol or a drug addressed in the legislation. Criminal conviction history alone would not trigger disciplinary proceedings by the Licensure Board.However, the Licensure Board could choose to discipline a licensee or permit holder if it finds, based on evidence and in accordance with its procedures, that a licensee or permit holder has committed fraud or a criminal offense that reasonably calls into question the person’s ability to practice as a dog trainer without posing a substantial risk to the health or safety of the public or of animals under the person’s care or supervision. Because the Licensure Board would be authorized to place conditions on licensure, it also has the discretion to impose remedial conditions, such as continuing education classes on non-aversive training techniques that promote the safe practice of the trainer, rather than revoking a trainer’s license after a violation.If the Licensure Board finds probable cause to believe a person poses a substantial and imminent risk to the health and safety of the public or of animals under the person’s care or supervision, it can summarily (without a full hearing) suspend the person’s authorization to practice, pending the outcome of the disciplinary proceeding. Otherwise, however, the Licensure Board will impose any discipline only after affording the dog trainer a hearing. As other licensure boards do, the Licensure Board will have the authority to call witnesses, issue subpoenas, and establish procedures that provide full and fair due process to the subject of any complaint.The Licensure Board is authorized to impose civil fines on persons who practice without authorization, or who commit fraud on consumers or in applying for a license. The Licensure Board also must refer to law enforcement any disciplinary matters involving fraud or animal cruelty or neglect. Any decisions about whether to prosecute a dog trainer, as well as specific criminal penalties, would not be imposed by the Licensure Board itself; rather, criminal penalties would arise only from a conviction prosecuted by a law enforcement agency.
- *NEW* How would the Licensure Board go about investigating complaints?The Licensure Board would have authority to investigate and gather evidence, including by issuing subpoenas for documents or calling witnesses, and would follow procedures that provide due process to the subject of any complaint during an enforcement proceeding. The Licensure Board may suspend or revoke a license if, after an investigation and hearing, it determines that a dog trainer poses a substantial risk to the health or safety of the public or of animals under the dog trainer’s care or supervision. Summary suspension of a license while the investigation is pending would require a finding of probable cause that the trainer poses both a substantial and an imminent risk.
- *NEW* How was it made clear that the model legislation does not restrict persons with disabilities from obtaining a license? The model legislation has been revised to clarify that eligibility for licensure is not restricted in any way for persons with disabilities in any portion of the model legislation. Safety and competence are touchstones of licensing for all dog trainers. Individuals with disabilities – whether a physical disability or a mental health diagnosis – are fully able to earn certification as a professional dog trainer and to hold a license to practice as a dog trainer.
- *NEW* Why is substance abuse mentioned in the model legislation?Any dog trainer can be subject to a disciplinary proceeding if their ability to practice in a safe and competent matter was materially compromised in a way that posed a substantial risk to the health and safety of the public or of animals under the person’s care or supervision. The model legislation also authorizes disciplinary proceedings if a dog trainer practices while under the influence of alcohol or a restricted drug and also has an active addiction or substance abuse problem. Some incidents resulting in complaints may fall under both of these disciplinary provisions, but the evidence presented to establish violations of the two provisions may have a different focus. Practicing while impaired will result in discipline only if there was a substantial risk to the health or safety of people or animals, or if the evidence establishes that the dog trainer has an active substance abuse problem which, as evidenced by impaired practice, the dog trainer is unable to keep from affecting their professional practice. The Alliance expects that, as with licensure boards for other professions, the dog trainer Licensure Board will use its enforcement authority in non-punitive ways when presented with substance abuse issues, e.g., by placing a dog trainer’s license on probation, subject to appropriate conditions (such as compliance with outpatient rehabilitation recommendations, etc.).
- *UPDATED* How much will licensure cost?The model legislation specifically calls for Licensure Boards to “set the fees such that the revenue generated from these fees is not expected to exceed the operating costs incurred by the Board” in administering statutory requirements of the legislation. The revised model legislation calls for the legislature to set a cap on fees for initial licensure and renewal of licensure. The fees for licensure in most fields are modest, and we anticipate the fees here will be modest as well.
- Why does the model legislation leave some provisions undefined, such as not setting some of the specific timelines or identifying the list of the Approved Certification Programs?The model legislation aims for a balance between specificity and flexibility so that the needs of the state’s professionals, consumers, and dogs can be met. Some specific details are left to each state to identify or alter, such as the duration of the transitional period for eligibility based on a year or more of current practice, or of temporary authorization for out-of-state dog trainers to provide services without applying for a license. Other details are left to each Licensure Board to address through a rulemaking process that includes public comment. Where specifics have been included, such as with the composition of the Licensure Board, these specifics reflect our proposals for optimal operation of the licensing authorities and align with policy objectives that are protective of public and animal health, safety, and welfare. The Alliance recognizes that this is only a model, and that each state legislature may make other changes as part of the legislative process.
- In how many states will the Alliance pursue consideration of the model legislation?The Alliance will be launching advocacy efforts in a few initial states that will serve as pilots for the legislation but ultimately aims to have the model legislation adopted across the country. As with any legislative effort, the timing and the political dynamics are hard to predict. Our hope is that once a few states successfully adopt this model, other states may follow suit on their own initiative, recognizing dog trainer licensure as a best practice.
- *NEW* Why take a state-by-state approach rather than promoting a national model?Occupational licensure is a state function, not a federal function. By developing model legislation and advocating for state legislatures to adopt that legislation, and by calling for reciprocal licensure, the Alliance is promoting consistent standards and greater geographic mobility of practice across the country.
- *NEW* Which groups belong to the Alliance, and who provided input?An initial draft of the model legislation was shared with virtually all the well-known dog trainer certification organizations and professional dog trainer associations in the U.S. several months prior to the formation of the Alliance. APDT, following a survey of its membership, strongly agreed that creating licensing and standards for the dog training industry would benefit and advance the profession, as well as protect the animals entrusted to dog trainers. CCPDT and APDT jointly formed the Alliance. After the Alliance was formed, the draft model legislation was further revised before it was shared with all APDT members and CCPDT certificants and made publicly available on the Alliance’s website, with an invitation for public comment. APDT’s Diversity, Equity, and Inclusion (DEI) Team has also reviewed and provided input on the revised model legislation. The model legislation has been updated in light of this collective feedback. The Alliance has now received requests from several other organizations to support this effort. Plans are in progress to develop a framework for ongoing involvement of other groups. We will keep the community updated as things progress.
- How can I help support this effort? After the model legislation has been introduced in a state, grassroots advocacy can be instrumental in winning support for the bill among legislators. We’re not yet at the stage for mobilizing such support, but please fill out this short form if you would like us to contact you when the time is right to support our advocacy efforts in a state where you live or work.
- *NEW* Will there be an effort to educate consumers about hiring certified, licensed dog trainers?The Alliance’s advocacy efforts in promoting the model legislation will help educate consumers and lawmakers about the value of hiring certified, licensed dog trainers. Additionally, APDT and CCPDT are often called upon by news media to comment on issues related to dogs and dog training. We make every effort to provide comments that educate and encourage consumers to seek out qualified, certified professional dog trainers, and will continue to do so for licensure. We will keep you posted as further plans emerge for increasing awareness of the value of hiring certified, licensed dog trainers.