USA vs UK
With there being ~500,000 assistance dogs in the USA, it is no wonder that there is more information spread about assistance in the USA than the UK. This can lead to confusion online about what is correct for a particular place. Here is some clarification about the differences between the USA and UK. For ease of reading, ‘assistance dog’ will be the term used to describe a dog that assists a disabled person throughout this page.
Service dogs in the USA describe both dogs that are trained to assist diabled people and those that work in the military and emergency services. In the UK, service dog is only used in reference to a dog that works in the miltary or emergency services while assistance dog is the term for a dog trained to assist a disabled person.
In the USA, ESAs are animals that are prescribed by a doctor and provide emotional support to an individual and legally required to be allowed access to no pet housing. They do not have public access rights and airlines are no longer legally required to allow them to fly. In the UK there is no equivalent system.
In the USA, assistance dogs are protected under the Americans with Disabilities Act (ADA) and are required to be task trained. In the UK, assistance dogs are protected by the Equality Act 2010 and Disability Discrimination Act 1995 and must mitigate the disability of the handler.