The Food Standards Agency (FSA) Board has agreed to take its Future of Food Regulation programme into a detailed design phase, marking a potentially significant change in how food regulation could operate across England, Wales and Northern Ireland.
The programme is intended to explore how the food regulatory system can become more effective, resilient and responsive to emerging risks, while making greater use of data, intelligence and modern regulatory approaches.
For food businesses, the proposals are particularly relevant because they could influence how businesses register with regulators, how compliance information is collected and assessed, how enforcement is approached and how food hygiene information is made available to consumers.
Importantly, no immediate changes to regulatory requirements are being introduced. The FSA is still developing the proposals, with further consideration by the Board and a public consultation expected during 2027.
However, the direction of travel is already becoming clearer.
Background: Why is the FSA reviewing food regulation?
The food regulatory system in England, Wales and Northern Ireland has developed over many years and involves a combination of national and local responsibilities.
The FSA establishes food safety policy and standards, while local authorities are responsible for much of the practical delivery of food safety and food standards enforcement. Environmental health officers and trading standards officers carry out inspections and other regulatory activities across a diverse food sector.
This system covers approximately 600,000 food businesses, ranging from small independent food businesses and hospitality operators through to major manufacturers, retailers and businesses operating complex national supply chains.
At the same time, local authorities have faced sustained pressure on resources and capacity.
The FSA’s Future of Food Regulation programme is therefore looking at whether the existing regulatory model remains capable of providing effective oversight of a modern food system, particularly as businesses increasingly operate across multiple sites and supply chains and generate large volumes of compliance and assurance data.
The programme is not simply about increasing inspections. Instead, the FSA is considering how regulation could make better use of information already generated by food businesses and other organisations.
What is the Future of Food Regulation programme?
In March 2026, the FSA Board approved the scope of the Future of Food Regulation programme.
The programme covers several areas of the regulatory system, including:
- Food business registration
- The regulatory oversight of large food businesses
- Regulatory guidance
- Enforcement tools and powers
- The use of data and intelligence
- Consumer access to food hygiene information
- The future operation and visibility of the Food Hygiene Rating Scheme (FHRS)
The underlying objective is to create a regulatory system that can identify and respond to risk more effectively, while maintaining confidence among consumers, businesses and regulators.
This represents an important shift in emphasis.
Rather than relying solely on periodic, premises-based inspections, the future model could make greater use of information generated centrally by businesses and across the wider food system.
Six outcomes identified by the FSA
The FSA has identified six broad outcomes for the future regulatory system.
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Enhanced food business registration
The FSA is looking at how food business registration could be strengthened.
A more effective registration system could give regulators a clearer and more complete picture of the food businesses operating within the system, helping to ensure that regulatory resources are directed towards the appropriate businesses and activities.
For food businesses, this reinforces the importance of ensuring that registration information remains accurate, current and aligned with the actual activities being undertaken.
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Different regulatory pathways based on business characteristics
The FSA is considering whether businesses should be subject to different regulatory approaches depending on their characteristics and risk profile.
This could potentially allow regulatory resources to be targeted more effectively, rather than applying exactly the same approach across businesses of very different sizes, structures and levels of risk.
For businesses operating across multiple sites, or with sophisticated food safety management systems, this could mean greater emphasis on demonstrating how controls operate consistently across the organisation.
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Greater use of data and intelligence sharing
One of the most important themes within the programme is the increased use of data.
Modern food businesses already generate substantial amounts of information through their food safety management systems, internal audits, verification activities, corrective actions, supplier assurance programmes, laboratory testing and other monitoring processes.
The FSA is exploring how regulatory oversight could make better use of this information.
This could mean that the quality, consistency and accessibility of a business’s food safety data become increasingly important.
A business may have a strong food safety management system on paper, but if its records are inconsistent, incomplete or difficult to access, it may be harder to demonstrate effective control.
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Improved guidance
The programme also considers how regulatory guidance could be improved.
Clearer and more effective guidance could help businesses understand regulatory expectations and support more consistent implementation across different parts of the food sector.
For businesses operating in multiple locations, consistency of interpretation and implementation can be particularly important.
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Revised enforcement tools and powers
The FSA is also considering whether the enforcement tools available to regulators remain appropriate.
The intention is not simply to increase enforcement, but to consider whether regulators have the right tools to intervene effectively where risks are identified.
This could form part of a wider move towards more proportionate, intelligence-led regulation.
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Greater transparency
The programme also places greater emphasis on transparency.
One proposal is the mandatory display of Food Hygiene Ratings online across the UK, alongside physical display requirements at premises in England.
For food businesses, this could increase the visibility of regulatory outcomes and make food hygiene performance even more relevant to consumers and commercial customers.
Why are large retailers receiving particular attention?
One of the most significant elements of the programme is its proposed approach to large food businesses.
Ten large retailers account for nearly 97% of the retail market. The FSA’s position is that decisions made centrally by these organisations can potentially have an impact far beyond an individual premises.
For example, a change in a company’s procurement process, food safety management system, supplier requirements or central operating procedures could affect a large number of sites and potentially millions of consumers.
This creates a challenge for a regulatory model that relies primarily on inspecting individual premises.
A local authority inspection provides valuable information about a particular site at a particular point in time. However, it may not provide the same visibility of a decision or control implemented centrally across hundreds of locations.
The FSA is therefore considering whether greater access to centrally held data could provide earlier visibility of wider or systemic risks.
Moving from premises-based oversight to data-led assurance
This is potentially one of the most important changes being considered.
The FSA previously conducted a proof-of-concept trial involving five major retailers.
The work explored whether centralised monitoring of food safety management information could provide regulators with an alternative or complementary source of assurance alongside traditional inspections.
The FSA concluded that this approach could provide comparable or greater insight into compliance than routine local authority inspections alone.
The concept is not necessarily about replacing inspections.
Instead, it is about using different sources of evidence to understand whether a business is effectively managing food safety risks.
This could include information about food safety management systems, audit findings, corrective actions, verification activities and other indicators of performance.
For businesses, this reinforces an important principle: being able to demonstrate control may become just as important as having the control in place.
Two regulatory models are being taken forward
Following consideration of six possible frameworks, the FSA is taking two options forward for further development.
Option 1: Direct Assurance
Under the Direct Assurance model, large food businesses would provide data and audit evidence directly to the FSA.
The FSA would operate a national assurance function, while local authorities would remain the competent authorities responsible for regulation.
The information gathered nationally could then be used by local authorities to inform their own regulatory activities.
This approach could provide the FSA with greater visibility of large businesses while maintaining the existing division of responsibilities between national and local regulators.
For large businesses, this could mean a greater requirement to maintain reliable, standardised and accessible assurance information that can be shared with the regulator.
Option 2: FSA as Competent Authority
The second model would go further.
Under this approach, the FSA would directly oversee applicable large businesses and would have stronger intervention powers.
The FSA has described this as the only option among those considered that would deliver full structural reform.
This would represent a more fundamental change to the current regulatory structure.
However, the model remains at the design stage and should not be interpreted as a confirmed future regulatory requirement.
What happens to local authorities?
An important point for the wider food industry is that the proposed changes do not mean that local authorities would cease to play a central role.
The FSA has emphasised that local authorities would continue to regulate the vast majority of food businesses.
The proposed national oversight of large businesses should also not be viewed as a justification for reducing local authority resources.
For smaller and medium-sized food businesses in particular, local authority regulation is therefore expected to remain an important part of the regulatory landscape.
What could this mean for food manufacturers and suppliers?
Although much of the immediate discussion is focused on major retailers, the potential implications could extend further across the supply chain.
Large retailers and other major food businesses depend on information from their suppliers to demonstrate that food safety risks are being managed throughout the supply chain.
If regulatory expectations increasingly place emphasis on data and central assurance, major customers may seek more consistent information from suppliers.
This could include greater scrutiny of:
- Food safety management systems
- Internal audit programmes
- Corrective and preventive actions
- Supplier approval and monitoring
- Traceability records
- Verification and validation activities
- Food safety performance data
- Certification and audit evidence
- Management review and continual improvement
- Evidence that identified risks are being effectively controlled
This does not mean that every supplier will automatically face new regulatory requirements.
However, businesses supplying major retailers should consider whether they can readily demonstrate the effectiveness of their food safety controls if customers or regulators request supporting evidence.
What does this mean for certification and audit programmes?
The proposed direction of travel also has implications for how businesses approach certification and auditing.
Certification should not be viewed simply as an annual exercise or a certificate that sits on a wall.
A well-managed certification and audit programme can provide structured evidence that a business is identifying risks, implementing controls, monitoring performance and addressing weaknesses.
As regulators increasingly consider data and intelligence alongside traditional inspection activity, businesses may benefit from ensuring that their audit evidence tells a consistent story.
For example, findings should be appropriately investigated, corrective actions should address root causes where necessary, and evidence should demonstrate that actions have been implemented and are effective.
The focus should be on evidence of an operating management system, rather than documentation for its own sake.
What should food businesses do now?
There is no need for businesses to make wholesale changes based solely on the current proposals.
The regulatory framework has not yet been finalised, and the FSA’s detailed design work and subsequent consultation will provide further clarity.
However, businesses can use this period to review the strength of their existing systems.
Consider asking:
- Can we demonstrate that our food safety management system is working effectively?
- Is our food safety data accurate, consistent and readily accessible?
- Can we quickly provide evidence of corrective actions and their effectiveness?
- Are internal audits identifying meaningful risks rather than simply generating completed checklists?
- Are food safety objectives supported by measurable evidence?
- Are our supplier assurance arrangements proportionate to risk?
- If we operate across multiple sites, are our controls and records consistent?
- Could we provide a clear evidence trail if a customer or regulator asked us to demonstrate how a particular food safety risk is being controlled?
These are useful questions regardless of the final regulatory model.
What happens next?
The FSA is expected to take the proposals back to its Board in March 2027, with a public consultation expected later in 2027.
The consultation will be particularly important because it should provide businesses and other stakeholders with an opportunity to understand the proposed model in greater detail and provide feedback before any final decisions are made.
Until then, businesses should treat the current proposals as an indication of the direction of regulatory development, rather than as new requirements.
Looking ahead
The Future of Food Regulation programme could represent a significant evolution in how food safety oversight is delivered in the UK.
The key theme is not simply more regulation. It is potentially different regulation: regulation that makes greater use of data, intelligence, central assurance and risk-based oversight alongside established inspection and enforcement activities.
For major food businesses, this could mean greater scrutiny of centrally managed food safety systems and assurance data.
For suppliers, it could mean increased expectations from major customers around the quality and availability of food safety evidence.
For smaller businesses, local authority regulation is likely to remain the primary regulatory route, but the wider emphasis on transparency, registration and effective risk-based regulation will still be relevant.
The final outcome will depend on the detailed design work and the consultation process.
At PJRFSI, we will continue to monitor developments and keep our UK clients informed as the proposals progress.
If you have questions about your food safety certification, audit programme or the evidence you maintain to demonstrate effective food safety management, please get in touch with our team.
