Transparency data

Future of Food Regulation report to the FSA Board: September 2026

Published 3 September 2026

Applies to England, Northern Ireland and Wales

Report by Emily Antcliffe to the Food Standards Agency (FSA) September 2026 Board meeting.

1. Summary

1.1 In March, the FSA Board formally agreed to establish the Future of Food Regulation Programme (the Programme), with the vision to deliver ‘an effective, resilient and trusted regulatory system that is fit for the future to ensure that food is safe and what it says it is’.

1.2 Since March, officials have refined and finalised the intended outcomes and impacts for the programme; assessed six options for the future regulatory model against our intended impact statement and identified challenges to be worked through in the next detailed policy design phase.

1.3 This paper asks the Board to endorse some of the key conclusions reached in that work so far, which will shape our next stage of the work.    

1.4 In particular, the Board is asked to:

• note progress since March 2026
• agree the intended programme outcomes and impacts which have been developed through high-level analysis and engagement
• agree that we should now develop proposals for whole system reform, which incorporate the two leading frameworks from our policy sprint for national level regulation of retailers and wider proposals for strengthening local delivery 
• note that we are starting the national approach by considering large retailers.  Further work will be done during the next phase on how we can future proof the model so that it could be applied to out of home, manufacturing and feed businesses
• provide any further feedback on the proposed way forward ahead of the next phase of delivery

2. Progress over the past six months

2.1 In March, the Board agreed 6 specific workstreams for the programme covering: the registration model; roles and accountabilities in the overarching regulatory framework; a modernised enforcement framework; evolving FHRS;  guidance for local authorities and businesses; and sustainable resourcing for the future system. Since then, we have completed a three-month policy design sprint looking across all six workstreams. We have also: completed an initial legislative mapping exercise to understand existing statutory requirements and the legislative implications for potential changes; initiated the data and digital workstream; and, crucially, undertaken significant stakeholder engagement, a summary of which is at annexes C and D.

2.2 The impetus for this programme was the UK Government’s request for advice on a national level approach to regulation. The Board agreed in March that that the programme should not be limited to developing proposals on national level regulation and should also develop proposals to better support delivery of regulation at local level too. Those workstreams were deliberately designed to cover the whole system and we see this as a system-wide reform programme.    

2.3 We know that we must have a clear, system-wide case for change; identifying the problems with the current regulatory system, defining the outcomes we want to achieve and the expected impact. The policy design sprint and our stakeholder engagement to date, building on work already completed with the previous Senior Stakeholder Forum, has helped us to refine this analysis.

2.4 Our vision for the future, and the outcomes we want to achieve, are set out in section 3 for the Board’s approval. The outcomes proposed here reflect feedback from stakeholders, including our local authority delivery partners, about those areas they want to see addressed in this programme alongside the UK Government’s ask to consider a national approach to regulating large food businesses.

2.5 As part of the policy sprint on the overarching regulatory framework, we developed six different potential frameworks of roles and accountabilities to explore with stakeholders.  These set out different ways in which a national level approach could be applied to the regulation of large food businesses, responding to the request from the UK Government for proposals on this point. Having discussed these frameworks with stakeholders and assessed them, we propose to focus on two potential frameworks for national level regulation as we develop system-wide proposals during the next phase. Section 5 covers this in more detail.

2.6 In parallel, the policy sprints identified changes that could be made to better support the delivery of regulation at a local level, which have fed into the outcomes set out in section 3. The sprints have also helped us to identify the policy, legislative, operational and digital challenges to be worked through; these will be addressed in the next phase. 

2.7 Between March and July 2026, the Programme undertook extensive stakeholder engagement across local authorities, industry, professional bodies, government partners and other regulators. This included regional local authority engagement events, frontline visits, senior stakeholder roundtables, routine engagement forums, strategic advisory groups, and initial discussions with Ministers regarding the programme within devolved administrations. In Northern Ireland (NI) the programme met with members of the NI Food Managers Group and their chair for discussion, briefed the lead officers at the Environmental Health NI and engaged the NI Food Advisory Committee in the ongoing work of the programme. In Wales, we have met with representatives of Directors of Public Protection Wales and held engagement sessions that all 22 local authorities were invited to attend.  Further detail is set out at annexes C and D.

2.8 These engagement events have been both helpful and collaborative.  We continue to hear lots of questions about the detail of possible changes to the regulatory system which we will work through with stakeholders as part of the next phase.

3. Vision for the future: the case for change and desired outcomes

3.1 We are seeking to create a regulatory system that is effective, resilient and trusted, and fit for the future, ensuring that food is safe and what it says it is.

3.2 Any proposed model must meet the request by the UK Government for the FSA to develop a consistent, national approach for England for the regulation of large food businesses, but it must also support and strengthen the local delivery of food safety and standards regulation by skilled officers with local expertise. It must result in a resilient system with the necessary financial and human resources to function.

3.3 The policy sprints helped to define the required components and associated outcomes of a new, coherent, connected regulatory system. This work has moved us on from the description of the workstreams in the March Board paper to propose the following outcomes for the programme:

• Enhanced registration for all to improve visibility of businesses in the food system, help quantify risk and support allocation of resources and remove opportunities for businesses to use re-registration to appear as new businesses. It will respond to new and emerging business types and be underpinned by sustainable funding.
• Triaged regulatory pathways to provide national oversight of the largest, most influential businesses, driving good behaviour across supply chains, while the vast majority of businesses continue to benefit from local scrutiny, advice and guidance from experienced local food teams. 
• Greater use of data and strengthened intelligence sharing to help streamline processes, reduce unnecessary burden and direct resources to where they can make the greatest impact. This will enable a joined up national-local regulatory model - with improved use of data to support an intelligence-led, risk-based targeting approach to regulation.  
• An improved guidance hub to empower food regulators and businesses with tools and guidance that make it easy to do the right thing.
• A revised enforcement framework with updated tools and powers to create a clearer hierarchy of enforcement action and support joined-up, proportionate enforcement practices, sanctions and incident responses to drive business behaviour.
• Greater transparency about food hygiene for businesses in any regulatory pathway – including mandatory Food Hygiene Rating Display online across the UK and in-store in England (it is already mandatory in Wales and Northern Ireland) – to drive improvements in businesses and help customers to make informed choices.

3.4 We should specifically address here the policy rationale for a national approach to regulation for some large businesses, as part of the ‘triaged regulatory pathways’ outcome. This has been the most controversial part of the programme so far, and we have heard from some (but not all) stakeholders in the local authority sector that they do not see the rationale for it, and do not understand why we are focusing on the large businesses rather that than small, who tend to pose a higher risk. In our view, this is an important part of ensuring the system is effective, resilient and fit for the future, recognising the shape of the food sector today and better exploiting the data being generated. 

3.5 The vast majority of the nearly 600,000 food businesses in the UK are micro, small and medium sized businesses, but there are a handful of very large businesses that have huge reach with consumers, and influence across the sector.  For example, ten large retailers together have nearly 97% of the retail market share.^{[footnote 1]} While individual branches of those retailers are often highly compliant and unlikely to be classed as high risk by their local food team, those businesses as a whole should warrant significant regulatory attention because of the impact their activities can have on consumers and on other businesses, particularly in their supply chains. The decisions taken by these businesses at national level can potentially have a very significant impact on food safety and standards. More effective use of the data held at a national level could give much better and more immediate visibility of system-wide risks and problems (a point which was recognised by stakeholders during our engagement). This is why we believe that the programme needs to deliver some form of national oversight for these businesses, as one part of strengthening the use of data and intelligence-sharing in a joined-up national and local model.

Does the Board agree that these are the right Programme outcomes?

4. Alignment with government policy

4.1 As mentioned above, this programme was established following a request from the UK Government for proposals on a consistent national approach to the regulation of large retailers, and potentially other large food businesses, in England.  

4.2 In July 2026 the Government announced and published a set of outcome-focused ‘growth goals’ for 2026/27 for key regulators. Goals for the FSA were agreed with the Department of Health and Social Care (DHSC) and include development of a new national approach to regulation for large food businesses, to be delivered through the Future of Food Regulation Programme.^{[footnote 2]} Milestones for this goal include development of a workplan for the programme (set out at annex A) and a report to the FSA Board on progress towards detailed design frameworks, which is in this paper.

4.3 Since then, the Cabinet has issued a statement on ‘Rewiring the State’.^{[footnote 3]} This sets out a vision for future delivery of public services based on a principle of devolution by default to strong strategic and local institutions, with central government focussed on the challenges that can best be dealt with at national level.

4.4 We believe the vision for the Future of Food Programme is in keeping with this approach. The future vision, high-level analysis and stakeholder engagement sets out our intention to strengthen local delivery as part of a whole system approach. The elements that strengthen local delivery, which should lead to a more effective system for the majority of food businesses, have been informed by extensive engagement with our local authority delivery partners. The programme is explicitly examining the question of what should be done nationally, with the expectation that a local approach will be the default for the vast majority of businesses. However, we would welcome views from the Board on the strategic fit of our programme with the government agenda.

4.5 We recognise that the Future of Food Regulation Programme was established in response to a UK Government ask and that governments in Wales and Northern Ireland have not made the same ask. We have however been asked by the Welsh Government to explore options for an enhanced system of registration or licensing of food businesses/prior approval rather than a right of registration which we are addressing through this programme’s ‘enhanced registration for all’ outcome.

4.6 More broadly, the FSA is committed to three nation working. We have therefore developed the programme with involvement from our teams in Wales and Northern Ireland and engaged with stakeholders in all three nations. We have updated the Wales and Northern Ireland Food Advisory Committees, we sought views from the Northern Ireland Food Managers Group, where we took account of the existing regulatory framework and gathered opportunities for potential development, recognising the stable District Council resourcing picture in Northern Ireland. In Wales we have engaged with Directors of Public Protection Wales and held an engagement session where all 22 local authorities were invited to share their views on the proposed frameworks. We have also been working closely with Food Standards Scotland as they pursue their separate but parallel programme of reform to the food regulatory system (SAFER).

4.7 We intend to put proposals to Ministers in all three governments, while recognising that they may choose to take different approaches. In developing our proposals we will consider carefully how any future regulatory model balances national consistency and system-wide oversight with local expertise, place-based delivery and devolved responsibilities in line with government thinking on devolution and localism.

5. Framework approach

5.1 As part of the policy design sprint, six potential frameworks for delivering a national approach to regulating large businesses were developed. These set out different options for how a national approach might be applied to a set of large food businesses. Under all frameworks, the majority of food businesses continue to be regulated by local authorities at local level supported by changes to make regulation more effective, with the FSA performing its existing role of ‘central competent authority’ overseeing the system.

5.2 At the end of the policy sprint phase, which was done in parallel with external engagement, we took each of the potential frameworks and conducted a prioritisation exercise, assessing each of them to see which could deliver against the desired outcomes and intended impact of the Programme; earlier identification of risk, more effective intervention, a more resilient and trusted regulatory system, better recognition of responsible businesses, and greater system-wide influence in support of growth. The assessment focused on strategic outcome alignment rather than ease of implementation. This assessment enabled us to identify the most promising proposals, which were the most transformational and most closely aligned to the ambitious approach endorsed by the Board as well as wider asks from the UK Government. Subject to Board agreement, we will take these frameworks forward into detailed design and further evaluation, combining both the national approach and improvements to the local approach, to create potential regulatory models.  

5.3 The outcome of this prioritisation exercise is summarised below.

Framework 1: National Targeted Monitoring Strategy

This would strengthen national targeting by enabling the FSA to set risk-based inspection frequencies using business and system data, while local authorities would continue to undertake regulatory activity.  

Although it would improve risk targeting, it was assessed as a low-change model that would not materially improve oversight, intervention capability or strategic influence across the system.  

Framework 2: FSA-Approved Assurance Schemes (Earned Recognition)

This would allow businesses participating in approved third-party assurance schemes to receive reduced regulatory oversight.

While it introduced greater proportionality for compliant businesses, it was assessed as being highly dependent on third-party assurance arrangements and only moderately aligned with the programme’s intended outcomes.

Framework 3: FSA Direct Assurance

This would establish a national assurance function within the FSA, with large businesses submitting data and audit evidence directly to the Agency. 

Local authorities would continue as the competent authority and would use FSA assurance to inform the delivery of regulatory functions.  

This framework scored highly against the outcome criteria because it would significantly improve national intelligence, risk identification and compliance oversight while retaining much of the current delivery structure.  

Framework 4: Enhanced Primary Authority

Although this would offer a different approach to governance arrangements, it would not significantly impact the current perceived inconsistency in system wide influence and risk management processes across Primary Authorities or support early identification of risk.

Framework 5: FSA as Competent Authority

This framework achieved the strongest overall assessment, providing the highest level of alignment with the programme’s objectives through direct national oversight, stronger national intervention powers and greater influence over system outcomes.  

Framework 6: FSA as Primary Authority

The framework was assessed as a strong option, although it would require changes to the Regulatory Enforcement and Sanctions Act (2008) that would need significant modelling and impact analysis for OPSS and other regulators.

From early discussions, indications are that OPSS would not have scope to engage with this work within programme timeframes. Should our ongoing cross-government engagement suggest a change in this we will revisit this framework.  

6. Recommendation on frameworks to progress to detailed design

6.1 Following the assessment, we recommend taking Frameworks 3 and 5 into detailed design (September 2026 to March 2027) to create potential regulatory models:

• Framework 3: FSA Direct Assurance, because it offers a credible, data-led route to significantly strengthen national oversight and intelligence while requiring less structural change and disruption than Framework 5
• Framework 5: FSA as Competent Authority, because it demonstrated the strongest alignment with the programme’s objectives and is the only option that delivers full structural reform of the regulatory system

Does the Board agree that these are the right frameworks to prioritise?

Are there elements of other frameworks that you would like to see included in the models at this stage?

7. Next step: detailed design phase

7.1 If the Board agrees, we will commence a detailed design and implementation assessment phase to develop two regulatory models. We will develop proposals for the future regulatory system which build on these two frameworks and include the changes that will make the local system more effective, drawing on elements of other frameworks where necessary in line with stakeholder feedback and requirements.  We will give consideration to changes wanted and needed to the local approach based on feedback from our stakeholders including registration, FHRS and guidance, with a clear understanding of finance and resource sustainability considerations alongside data, digital and legal requirements.

7.2 Only when we have completed this phase will we be able to identify the proposed structure of a future food regulatory system to take to formal consultation. This essential design work must be done in collaboration with experts and stakeholders to create an evidenced, costed, and deliverable regulatory model with a full assessment of legislative and data needs and possibilities.

7.3 Our underlying assumption, for the reasons set out in paragraphs 3.4 and 3.5 above, is that there is a case for taking a national approach to regulation of some large food businesses (particularly large retailers) alongside a strengthened local approach for most businesses We will use the detailed design phase to stress-test this assumption further and will return to the Board with our findings.

7.4 We know that there are resource pressures across the current system. Local authorities have to make difficult prioritisation decisions, and do not have the resources they need to deliver against all of their responsibilities. Any new regulatory model must be developed within this context and make delivery more effective and sustainable. It should acknowledge the additional cost of change as well as the benefits across the whole system, for example, improving and increasing digital and data infrastructure and capabilities.  

7.5 It is critical that proposals as part of introducing a national approach to regulation for large food businesses are not used as a reason to reduce available local authority resource. The vast majority of businesses will still be regulated at a local level, and local food teams will need sufficient resources to do that job well.

8. Roadmap to consultation

Period	Focus	Main activity
March to June 2026	Policy sprints split into workstreams	National approach to regulation; local approach; enhancing registration; evolving FHRS; evolving guidance; finance and resource sustainability.
June to July 2026	Define national approach frameworks and shortlist	Seven frameworks defined, one discounted immediately; remaining six assessed against Board design principles and impact statements; shortlisting recommendations; data workstream initiated.
July to October 2026	Priority work packages	Evidence gap analysis; stage 1 data workstream; national approach entry criteria; definitions of out of home and large business; guidance catalogue; working groups and TAC; registration improvements; PA scheme impact.
September 2026 to February 2027	Detailed design through two recommended national frameworks	Detailed system design through the lens of two national frameworks, looking at data and legislative requirements deliverability, registration, FHRS, guidance, local approach, and sustainability considerations.

9. Other elements to be phased

9.1 Regulation of online platforms has emerged as a significant and complex policy area that extends beyond the scope of the current programme. By online platforms, we mean platforms selling food without a physical premises in the UK and who are not already regulated with inspections by local authorities under the food hygiene and food standards frameworks. Businesses with physical premises are already inspected by local authorities. We need to establish whether and what type of regulation is needed for these online only platforms on which food is sold, possibly by overseas sellers or unregistered businesses. We need to ensure it receives appropriate focus and scrutiny and, building on the work already achieved through the voluntary food safety charter, a dedicated discovery and scoping exercise is underway. This work will assess the scale of the challenge, policy and legislative implications, delivery options and resource requirements. Recommendations and potential next steps will be brought to the Board next year.

9.2 We said to the Board in March that we would start with retailers and then consider how national level regulation might apply to other sectors. Early engagement suggests the retail pilot model may not carry across to other sectors directly. Further discovery is needed to define what is possible and how we can future proof any new regulatory model for large food businesses to extend in time to other sectors; namely out of home, manufacturing and feed. We are beginning discovery work on this in September 2026 and will revert with findings on whether other sectors can be considered at a later Board in 2027.

10. Conclusions

10.1 Since March a significant amount of work has been undertaken to develop the vision, outcomes and workstreams and assess the possible frameworks for a national approach to the regulation of large food businesses.

10.2 Our engagement with local authorities, businesses and other government departments has highlighted the importance of developing changes on a system basis. We are also hearing support for meaningful change to issues with delivery of the current system faced by local authorities and businesses.

10.3 The next phase of work is the most critical. We will work with our partners to develop the two lead frameworks in more detail as regulatory models, including stress testing elements of the future regulatory system we are designing with businesses and local government. While we are confident this aligns with ‘Rewiring the State’, we will continue to engage across government and with our partners in local government. Through this process we will develop a model for recommendation to the Board prior to a consultation in summer 2027.

11. Decision

11.1 The Board is asked to:

• note progress since March 2026
• agree the intended programme outcomes and impacts which have been developed through high-level analysis and engagement
• agree that we should now develop proposals for whole system reform, which incorporate the two leading frameworks from our policy sprint for national level regulation of retailers and wider proposals for strengthening local delivery
• note that we are starting the national approach by considering large retailers. Further work will be done during the next phase on how we can future proof the model so that it could be applied to out of home, manufacturing and feed businesses
• provide any further feedback on the proposed way forward ahead of the next phase of delivery

Annex A: proposed timeline

Narrative Description of Proposed High-Level Plan.

The High-Level Plan shows proposed dates for the programme.

The plan highlights the period between March 2026 and June 2028. The plan highlights a number of governance milestones including:

• March 2026 – FSA Board meeting: FSA Board approval to commence the Future of Food Regulation programme
• September 2026 – FSA Board meeting: FSA Board approval of framework recommendations
• December 2026 – FSA Board Meeting: Programme update to FSA Board via the CEO Report
• March 2027 – FSA Board Meeting: FSA Board approval of consultation recommendations
• June 2027 – FSA Board Meeting: FSA Board approval of proposed consultation scope
• December 2027 – FSA Board Meeting: FSA Board discussion post consultation analysis
• January 2028 – Submission to Ministers, review proposed regulatory model that we have consulted on

The plan highlights the following programme activity and milestones:

• detailed design development and review of regulatory models – running for circa 6 months from October 2026 to March 2027
• consultation drafting - running for circa 3 months from April 2027 to June 2027
• publication of Consultation Milestone – June 2027
• consultation running for circa 3 months from July 2027 to September 2027
• consultation analysis running for circa 3 months from October 2027 to December 2027
• testing and piloting commencing in January 2028 – duration – to be confirmed (TBC)
• detailed implementation planning commencing in January 2028 – duration – to be confirmed (TBC)
• stakeholder engagement running for circa 27 months from April 2026 to June 2028

Annex B: framework descriptions

Framework 1: National Targeted Monitoring Strategy

This framework would retain the current regulatory model and introduce a stronger national role in setting risk-based inspection priorities. The FSA would analyse intelligence received from local authority and business data to determine where regulatory effort should be focused. Local authorities would remain responsible for official controls and associated activities as they do now. 

Framework 2: FSA-Approved Assurance Schemes (Earned Recognition)

This framework would extend the existing model for FSA approved assurance scheme which feature in dairy and feed controls to provide evidence of compliance. The FSA would approve and oversee assurance schemes, with local authorities taking account of scheme membership when determining regulatory activity. Businesses in this model would join UKAS accredited third party assurance schemes who would also be subject to audits by these certification bodies.

Framework 3: FSA Direct Assurance

Under this model, the FSA would directly assess large food businesses using company-wide compliance data and assurance information. This assurance would be used to inform local authority regulatory activity. Local authorities would remain the competent authority.

Framework 4: Enhanced Primary Authority

This framework would build on the existing Primary Authority system to give FSA greater oversight of inspection plans, advice and Primary Authority performance, building on the national supporting regulator role. This model would also include a specific Primary Authority performance monitoring function so would require OPPS support and potentially specific legislation.

Framework 5: FSA as Competent Authority

This framework would see the FSA become the direct regulator for large food businesses, taking responsibility for oversight, official controls enforcement and intervention at a national level. Local authorities would continue to regulate all other businesses.

Framework 6: FSA as Primary Authority

This framework would transfer the food Primary Authority relationship for large food businesses to the FSA, while local authorities would retain wider regulatory responsibilities. The model delivered many of the benefits associated with a national regulatory approach but retained split accountability and more complex governance arrangements.

Annex C: summary of stakeholder feedback March to July 2026

Below we provide a summary of feedback that we have received. We have taken this feedback into account and will continue to do so as the programme progresses. We have therefore not provided any responses below, either for or against the points that were made.

Overview

1. Following the March Board discussion, the programme undertook a series of engagement activities with various stakeholders to gather views on potential future approaches to food regulation. Stakeholders welcomed the opportunity to contribute to the development of the programme and expressed support for continued engagement as proposals are developed further.

2. Stakeholders broadly supported the ambition to modernise the regulatory system and recognised opportunities to improve consistency, intelligence sharing and risk-based regulation.  While views differed on the preferred delivery model, there was broad agreement on the importance of maintaining effective regulatory oversight, public confidence and clear accountability.

3. Stakeholders also repeated calls to strengthen upstream controls through improvements to registration, licensing and business onboarding arrangements, helping to improve compliance earlier and target regulatory effort more effectively.

4. We again heard a significant amount of detailed implementation questions across the framework options primarily focussed on how the models would operate in practice, including governance, accountability, workforce capacity, data and intelligence requirements and interactions with existing regulatory requirements. This is a positive indication of stakeholder engagement with the proposals and reflects a natural desire to understand the practical implications of future models. The programme is currently seeking agreement on the preferred strategic direction and the detailed operations considerations raised will be addressed during the detailed design phase.

Clarity of purpose and scope

5. A consistent theme across discussions was that stakeholders challenged the programme rationale and sought stronger evidence of the problem being addressed and the benefits reform would deliver. Several participants questioned whether the proposed frameworks addressed the underlying challenges facing the current regulatory system, with some commenting that “it’s not clear what the problem is that we’re trying to solve” and asking “what is the actual benefit to us?”. Stakeholders sought clearer articulation of how proposed changes would improve regulatory outcomes, support businesses and strengthen the overall system.

6. Some stakeholders also noted the importance of considering wider system interdependencies as proposals develop, recognising that future reforms may need to be considered within the broader regulatory landscape.

7. Stakeholders repeatedly questioned the programme’s focus on large businesses and sought greater clarity regarding which businesses would be included within any future national model. Several argued that many large national operators are already subject to significant regulatory and assurance activity and challenged whether the greatest regulatory risks sit within this part of the food system. As one stakeholder commented, “the risk doesn’t sit with large businesses who mostly self-regulate, the risk sits in small/medium businesses”. Stakeholders also highlighted that the absence of a clear definition of a ‘large business’ made it difficult to assess the suitability of the proposed frameworks.

8. While stakeholders held differing views on the preferred operating model, there was support from some business representatives for approaches that could reduce duplication, simplify regulatory relationships and provide greater national consistency. These stakeholders emphasised the importance of clear accountability, streamlined regulatory interactions and ensuring that resources are targeted towards the highest-risk areas of the food system.

Local authority delivery and local intelligence

9. Local authorities’ representatives consistently emphasised the importance of local authority expertise, local intelligence and independent official controls. Feedback highlighted the value of local knowledge in identifying emerging risks, responding to incidents and understanding local circumstances that may not be visible through national systems or datasets.

10. A strong message from local authority stakeholders was that any future regulatory model should continue to support local responsiveness and professional judgement. Stakeholders emphasised that intelligence-led approaches should complement, rather than replace, local inspection activity and regulatory oversight. Stakeholders stressed that local knowledge remains essential and that regulators “must be able to react to local intelligence”.

Data, assurance and public confidence

11. Stakeholders supported the principle of making better use of data and intelligence to inform risk-based regulation. There was recognition that improved intelligence sharing, national analysis and more consistent use of information could support more targeted regulatory activity.

12. Some stakeholders also highlighted opportunities to make greater use of existing assurance information and business intelligence where these can support more proportionate and targeted regulatory activity.

13. Stakeholders highlighted the importance of digital and data infrastructure in supporting any future regulatory model. Feedback emphasised that successful implementation would depend on clear data standards, effective information sharing, compatible systems and sufficient investment in both national and local capability. Stakeholders noted that implementation challenges should not be underestimated where reforms rely on new data flows, technology platforms or changes to existing processes.

14. Some stakeholders expressed concern about relying too heavily on business-generated data, corporate systems or assurance arrangements as a substitute for regulatory oversight. Feedback highlighted concerns that documentation, assurance reports and corporate data may not always reflect conditions in practice, and that independent verification remains essential. Many emphasised the need to maintain mechanisms that test whether information provided reflects actual compliance, with one stakeholder commenting that “Nothing beats an independent unannounced official control” and another noting that “what happens in reality isn’t what the paperwork says”.

15. Stakeholders also highlighted the importance of maintaining consumer confidence in the regulatory system. There was a view from regulators that public confidence depends on visible and independent oversight and that reforms should preserve trust in regulatory assurance arrangements, including maintaining confidence in established public-facing schemes such as the Food Hygiene Rating Scheme.

Primary Authority and system design

16. The future role of Primary Authority generated significant discussion. Stakeholders acknowledged benefits within the current system yet also identified concerns regarding inconsistency, variation in delivery and the effectiveness of some arrangements. There was broad agreement that opportunities to strengthen consistency and transparency should be explored.

17. Stakeholders also requested greater clarity regarding how future arrangements would interact with existing regulatory structures and accountabilities. Feedback highlighted the importance of avoiding duplication and ensuring that roles and responsibilities remain clear across the system.

18. Stakeholders noted that regulatory arrangements differ across the UK and highlighted the importance of ensuring that future proposals remain adaptable to different national contexts, legislative frameworks and delivery models. Feedback emphasised that implementation considerations and the suitability of approaches may vary across nations and should be reflected in future design work.

Workforce, governance and implementation

19.  Workforce capacity and resourcing were strongly identified as significant concerns. Stakeholders highlighted existing recruitment and retention challenges and questioned whether future models could be delivered without drawing staff from local authorities that are already experiencing workforce pressures. Stakeholders emphasised the importance of ensuring that any future model is supported by sustainable workforce and funding arrangements and takes account of wider pressures and organisational change across local government.

20. Stakeholders sought greater detail on how future arrangements would operate in practice, including governance, accountability, oversight and implementation. There was particular interest in understanding how decisions would be made, how responsibilities would be exercised and how regulatory outcomes would be monitored.

21. Stakeholders expressed a range of views on the scale and pace of reform required. While there was support for exploring transformational opportunities, many emphasised the importance of building a robust evidence base, demonstrating clear benefits and considering whether gradual changes could deliver improvements before undertaking more significant structural reform. Several stakeholders favoured a phased approach, arguing that “incremental change allows for a stronger foundation on which to build” and cautioning that implementation timescales may be ambitious.

Overall conclusions

22. Stakeholders were broadly supportive of reform to improve consistency, intelligence sharing and risk-based regulation, provided proposals are evidence-based, proportionate and deliver clear benefits. Views differed on the preferred approach, with local authority stakeholders prioritising local delivery and responsiveness, while some business stakeholders favoured greater national consistency and reduced duplication.

Annex D: summary of stakeholder events

1. Between March and July 2026, the programme delivered an extensive engagement programme across local authorities, industry, professional bodies, government partners and other regulators. This included regional local authority engagement events, frontline visits, senior stakeholder roundtables, routine engagement forums and strategic advisory groups.

2. This comprised 59 external engagement activities including more than 20 Future of Food Regulation focussed stakeholder engagement events or updates, 41 Food Liaison Group touchpoints with 315 Local Authority (LA) Lead Officers, and updates at 27 routine engagement events. 17 of these included strategic Executive/Board level engagement. The focussed events included nine in-person and one virtual local authority engagement events, five frontline visits to local authorities, a round-table discussion with senior stakeholders following the March meeting to hear their views directly, a meeting with the ten large retailers, a meeting with the Primary Authority Regional Group, meetings with Food Standards Scotland, updates to the Welsh Food Advisory Committee and Northern Ireland Food Advisory Committee and two meetings with the newly established Senior Advisory Forum.

3. The engagement programme reached at least 1,256 stakeholders between March and July 2026, noting that attendance figures were not available for a small number of events and therefore the actual reach is higher.  In addition, we provided an update on FSA LINK, our platform for sharing information with local authorities, which reached approximately 2900 more stakeholders.

4. A programme of ongoing engagement is planned to include routine engagement with focus groups, industry liaison meetings, stakeholder forums, professional body engagement, frontline visits and Board discussions. These activities will enable the programme to gather further feedback, test policy development, strengthen stakeholder relationships and ensure a broad range of views continue to inform the Future of Food Regulation programme. We will continue to organise frontline visits to help inform policy development. They will provide opportunities for senior FSA leaders, Board members and programme colleagues to observe frontline regulatory activity and gain first-hand insight into the operational challenges and opportunities faced by local authorities and industry. These visits will help ensure that future policy development is informed by the practical realities of food regulation delivery and enforcement.

5. The Technical Advisory Committee is being brought together to include representatives from local authorities and industry initially, with other key stakeholders such as consumer groups to be considered as the work moves into more detailed design. The Committee will provide expertise and challenge, supporting the ongoing development of the Future of Food Regulation framework.

Name of Event	Date of Event	FSA Lead Name, Title
1. Local Authority Food Liaison Groups – routine engagement updates	March to July	Local Authority Relationship Managers, FSA
2. Katie Pettifer and Food and Drink Federation Food Safety Committee – routine engagement	26 March 2026	Katie Pettifer, FSA Chief Executive
3. CIEH routine update (workforce survey)	9 April 2026	Programme team
4. Local authority Frontline Visit - West Berkshire Council (including Board Members)	16 April 2026	Nathan Barnhouse Deputy Director of Regulatory Compliance, Steve Ruddy and Alison Austin, FSA Board Members
5. Future of Food Post Board Round Table - key stakeholders	16 April 2026	Susan Jebb, FSA Chair, Tim Riley, Steve Ruddy and Alison Austin FSA Board Members, Nathan Barnhouse Deputy Director of Regulatory Compliance, David Holmes Deputy Director of Strategy
6. International Heads of Food Agencies Forum 2026 (IHFAF)	20 April 2026	Katie Pettifer, Chief Executive of the FSA, Liz Stretton, Head of International Strategy
7.  NIFAC - Northern Ireland Food Advisory Committee – Future of Food Regulation themed update	22 April 2026	Anthony Harbinson, FSA Board Member for Northern Ireland/Chair of NIFAC, Karen McCloskey Head of Regulatory Reform , Philip Kennedy Head of Food Safety Policy and Delivery,
8. Meeting with Lord Rooker	29 April 2026	Susan Jebb, FSA Chair
9. Business Expert Panel - Food Standards & Labelling Group – routine engagement	28 April 2026	Regulatory Compliance Division
10. Local Authority Engagement Event – London (including Board Member attendance)	7 May 2026	Sean Suckling, Team Leader, Regulatory Reform
11. Local Authority Reference Panel – routine engagement	7 May 2026	Karen McCloskey, Head of Regulatory Reform and Lisa Brooks, Team Leader, Regulatory Reform
12. British Retail Consortium Technical Directors meeting – routine engagement	11 May 2026	Katie Pettifer, Chief Executive of the FSA
13. Food Standards Scotland SAFER Programme Board (FSS)	12 May 2026	Emily Antcliffe Director of Strategy, Trade and Food System Policy
14. National Local Authority Food Hygiene Focus Group – routine engagement	12 May 2026	Karen McCloskey, Head of Regulatory Reform and Nathan Barnhouse, Deputy Director of Regulatory Compliance and Fiona McClements, Head of Frameworks and Local Authority Engagement
15. Northern Ireland Food Managers Group – Future of Food Regulation themed update	14 May 2026	Louise Connolly, Local Authority Policy and Delivery Lead and Karen McCloskey, Head of Regulatory Reform
16. CTSI/CIEH (workforce survey)	14 May 2026	Programme team
17. Cross Government Regulation Programme Board	14 May 2026	Christy Lindsay, Head of Legislative and Regulatory Strategy
18. Meeting with Department of Business and Trade – routine engagement	14 May 2026	Emily Antcliffe Director of Strategy, Trade and Food System Policy
19. Meeting with Health and Safety Executive	15 May 2026	Sean Suckling, Team Leader – Regulatory Reform
20. Senior Advisory Forum	18 May 2026	Emily Antcliffe Director of Strategy, Trade and Food System Policy, Nathan Barnhouse, Deputy Director of Regulatory Compliance, David Holmes, Deputy Director of Strategy, Jodie Sharma, Head of Regulatory Reform (Legislation & Strategy),
21. Welsh Food Advisory Forum – Future of Food Regulation themed update	18 May 2026	Karen McCloskey, Head of Regulatory Reform, Sarah Aza, Head of Delivery Wales, Neil Arbery, Head of Local Authority Delivery Wales
22. 10 Large Retailers – Future of Food Regulation themed update	19 May 2026	Karen McCloskey/Owen Lewis Head of Regulatory Reform, Micah Mcguire, Regulatory Reform – Team Leader
23. Frontline visit to London Borough of Croydon	20 May 2026	Steve Smith, Head of LA Intelligence Coordination
24. LA Engagement Event - East region (Cambridge) (including Board Member attendance)	20 May 2026	Sean Suckling, Regulatory Reform, Team Leader
25. Incidents Prevention Team and Fresh Produce Consortium - routine engagement	20 May 2026	Tina Potter, Head of Prevention
26. CTSI engagement (online workstream)	28 May 2026	Steve Smith, Head of LA Intelligence Coordination
27. FSA Annual Parliamentary Reception	2 June 2026	Susan Jebb, Chair of the FSA, Kate Todd, Head of External Affairs
28. Local Authority engagement event - South West Region (Taunton)	3 June 2026	Nathan Barnhouse, Deputy Director of Regulatory Compliance, Karen McCloskey, Head of Regulatory Reform, Rebecca Jones, Team Leader – Regulatory Reform
29. CTSI conference – plenary session panel member	11 June 2026	Emily Antcliffe, Director of Strategy, Trade and Food System Policy
30. Joint FSA/FSS Future of Food / SAFER session	16 June 2026	Nathan Barnhouse, Deputy Director of Regulatory Compliance
31. Local Authority Engagement Event - Midlands Region (Birmingham)	18 June 2026	Karen McCloskey, Head of Regulatory Reform, Chris McManus/Lisa Brooks – Team Leaders, Regulatory Reform
32. Local Authority Engagement Event - North West Region (Chester)	24 June 2026	Rebecca Jones, Team Leader – Regulatory Reform
33. Future of Food Regulation/ OPSS Primary Authority Leads	25 June 2026	Karen McCloskey Head of Regulatory Reform, Lisa Brooks/Rebecca Jones – Team Leaders, Regulatory Reform
34. Food and Drink Federation Food Safety Committee	25 June 2026	Nathan Barnhouse, Deputy Director of Regulatory Compliance and Sam Faulkner, Deputy Director International, Trade and Devolution
35. LA Engagement event (virtual)	30 June 2026	Rebecca Jones, Regulatory Reform – Team Leader, Sarah Maddox, Head of Delivery Standards
36. FSA/FSS Future of Food Regulation/SAFER	30 June 2026	Nathan Barnhouse, Deputy Director of Regulatory Compliance, David Holmes Deputy Director of Strategy, Karen McCloskey/Owen Lewis, Head of Regulatory Reform
37. CIEH update – routine engagement	1 July 2026	Emily Antcliffe, Director of Strategy, Trade and Food System Policy
38. Home Office engagement relating to business registration	1 July 2026	Nathan Barnhouse, Deputy Director of Regulatory Compliance
39. Wales LA engagement event – Future of Food Regulation themed update	1 July 2026	Sarah Aza, Head of Delivery, Wales
40. National Local Authority Food Standards and Information Focus Group – routine engagement	2 July 2026	Owen Lewis, Head of Regulatory Reform
41. Frontline visit – London Borough of Ealing	8 July 2026	Steve Smith, Head of Local Authority Intelligence Coordination Team
42. Institute of Grocery Distribution (Sarah Bradbury) – routine engagement	9 July 2026	Katie Pettifer, Chief Executive
43. FSA/SAFER - research and evidence discussion	14 July 2026	Imogen Cartwright, Economics Advisor
44. Cross government meeting with partners/regulators from the Netherlands	14 July 2026	Nathan Barnhouse, Deputy Director of Regulatory Compliance
45. Business Expert Panel Food Standards & Labelling Group	14 July 2026	Owen Lewis, Head of Regulatory Reform
46. Food Industry Liaison Group	16 July 2026	Owen Lewis, Head of Regulatory Reform, Lisa Brooks, Team Leader – Regulatory Reform,
47. Chief Executive meeting with CEO of Association of Convenience Stores – routine engagement	17 July 2026	Katie Pettifer, Chief Executive Officer
48. Senior Advisory Forum	21 July 2026	Emily Antcliffe, Director of Strategy, Trade and Food System Policy, Nathan Barnhouse, Deputy Director of Regulatory Compliance, David Holmes, Deputy Director of Strategy, Peter Quigley, Director of Wales
49. National Local Authority Food Hygiene Focus Group – routine engagement	21 July 2026	Lisa Brooks, Team Leader – Future of Food Regulation, Fiona McClements, Head of Frameworks and LA Engagement
50. Royal Welsh Show including meeting with Deputy Minister for Public and Preventative Health	22 July 2026	Susan Jebb, FSA Chair
51. Frontline visit to Wakefield Council and West Yorkshire Joint Services	22 July 2026	Nathan Barnhouse Deputy Director of Regulatory Compliance and Rebecca Jones, Team Leader – Regulatory Reform
52. Frontline visit to North Yorkshire Council accompanied by the Home Office	23 July 2026	Nathan Barnhouse, Deputy Director of Regulatory Compliance and Steve Smith, Head of LA Intelligence Coordination Team
53. ACTSO Business Meeting – routine engagement	23 July 2026	Mark Davis, Head of Delivery Support Unit and Owen Lewis, Head of Regulatory Reform
54. FSA/Home Office engagement (High Street Organised Crime Unit) – engagement relating to business registration/licensing	24 July 2026	Nathan Barnhouse, Deputy Director of Regulatory Compliance
55. Local Authority Engagement Event – South (Haywards Heath)	24 July 2026	Rebecca Jones, Team Leader – Regulatory Reform
56. FSA/FSS regular engagement	27 July 2026	Nathan Barnhouse, Deputy Director of Regulatory Compliance, Karen McCloskey, Head of Regulatory Reform, Lisa Brooks, Team Leader – Regulatory Reform
57. Routine Bi-Lateral Meeting with FSA New Zealand	28 July 2026	Karen McCloskey Head of Regulatory Reform, Lisa Brooks, Team Leader – Regulatory Reform
58. Local Authority Engagement Event - York	28 July 2026	Sean Suckling, Team Leader - Regulatory Reform
59. Primary Authority Regional Leads	13 August 2026	Rebecca Jones/Lisa Smith/Lisa Brooks – Team Leaders – Regulatory Reform

1. Food statistics in your pocket. ↩

2. Food Standards Agency (FSA) economic growth goals. ↩

3. Rewiring the State – Cabinet Statement. ↩