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1 Summary

1.1ÌýÌýÌýÌý ÌýThe paper updates the Business Committee on the rollout of the Food Standards Delivery Model (FSDM) in England and Northern Ireland.ÌýÌýIt sets out how we propose to approach the performance management of Local Authorities (LAs) as they start operating the new model, in light of the historical challenges that are facingÌýLAs and the FSA.ÌýÌýÌý

1.2ÌýÌýÌýÌý ÌýThe Business Committee is asked to:

• Comment onÌýthe proposed performance management framework for England which lays out the FSA’s expectations for (LAs) to deliver food standards controls in accordance with their legal and statutory obligations prescribed within theÌýFood Law Code of Practice (the Code)Ìýover a period of three years, incorporating regular reviews to monitor progress and challenge unacceptable performance.

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2.1ÌýÌýÌýÌý ÌýLAs are responsible for enforcing compliance with food safety and standards legislation for most food businessesÌý.Ìý The FSA has statutory dutiesÌýto monitor and report on their performance in doing so.Ìý

2.2ÌýÌýÌýÌý ÌýIn 2018 the Board agreed to the development of a new food standards model, recognising that a new approach was needed.ÌýÌýThe new model was developed to enableÌýLAs to make better use of the resources they have, with intervention frequencies that are more risk-based and potential for greater use of intelligence to inform action.ÌýÌýLack of confidence in the old model effectively targeting resources to the highest risk establishments, coupled with prolongedÌýLAÌýunder investment in officer numbers, had already led to poor delivery against required intervention frequencies for some years.ÌýÌýÌý

2.3ÌýÌýÌýÌý ÌýThe new model was introduced this year.ÌýÌýThe process of introducing it has given us a deeper understanding of the impact of the reduction in resources byÌýLAs over time to deliver their food service and the scale of the challenge they now face.ÌýÌýThis is most visible in the large backlogs of overdue interventions.

2.4ÌýÌýÌýÌý ÌýThe underlying concern is that manyÌýLAs lack the resources to meet their legal obligation to deliver interventions at all food business establishments.ÌýÌýThe new FSDM introduces a better approach forÌýLAs to assess and manage risk, prioritise interventions, and use intelligence more effectively—for example, by considering allergens.ÌýÌýHowever, while the frequency of interventions may have changed, the legal requirement for an intervention at every establishment remains unchanged under the new FSDM.ÌýÌýThe new FSDM corrects inaccuracies in someÌýLAÌýdatasets, which means that in the short term the backlog will appear to worsen.ÌýÌýThe new FSDM exposes these issues and forces both the FSA andÌýLAs to face the reality of the system and work towards a shared understanding that more accurately reflects actual risk.

2.5ÌýÌýÌýÌý ÌýThe reasons for this decline have been driven by decisions made by both the FSA andÌýLAs, some of which have resulted in unintended consequences:

• ÌýThe reduction in funding available to food teams byÌýLAs has resulted in a steep decline in officer numbers starting in 2011, which has left us with almost a 50% reduction in posts.ÌýÌýThis is most severe at English county councils, where performance against code requirements is lower.
• ÌýSomeÌýLAs have developed service plans based on flat funding levels rather than in response to need.ÌýÌýThis has had a knock-on effect on the accuracy of their establishment data, which appears to have been altered to facilitate this.
• ÌýThe FSA decision to withdraw from performance management of food standards controls byÌýLAs in 2015 due to the recognised failures of the old model has resulted in a lack of appropriate challenge to those local authorities affected by the first two points.ÌýÌýWith hindsight, a more rigorous approach would have been more appropriate.

2.6ÌýÌý ÌýIt is important to reflect that the underlying risk to the consumer presented by businesses has not materially changed.ÌýÌýThe new FSDM should result in a far more accurate understanding of the level of risk and the resource needed to effectively manage it.ÌýÌýHowever, although the new model will lead to improvements over time, it is clear thatÌýLAs will not be able to comply with all its requirements straight away.ÌýÌýThis paper presents the pragmatic manner in which the FSA proposes to work withÌýLAs over the next few years to achieve that transition towards full compliance.ÌýÌýThe plan will be regularly reviewed to monitor progress given the complex challenges facingÌýLAs including finance, local government reorganisation and recruitment and retention of qualified staff to deliver the service.

3ÌýFSDM Rollout

3.1ÌýÌýÌýÌý ÌýThe rollout of the FSDM has presented significant challenges, in the main due to issues with Management Information Systems (MIS) being upgraded to record and report in accordance with the model.ÌýÌýOnce fully implemented, this will give the FSA a better understanding of thoseÌýLAs who are struggling to fulfil their obligations but have yet to accept the reality of their situation or not provided the FSA with accurate information necessary for us to determine that on our own.ÌýÌýÌý

3.2ÌýÌýÌýÌý ÌýIn March 2025, the new FSDM requirements were introduced into the Code.ÌýÌýProgress has been made and, as at mid-November 2025, 150 of the 154 impactedÌýLAs across England and Northern Ireland have self-reported that they are implementing the new model.ÌýÌýOf these, 96ÌýLAs have indicated that their MIS has been updated to reflect the requirements of the new model, with the remaining 54ÌýLAs at various stages of progress but still using temporary recording solutions pending MIS update.ÌýÌýWe continue to work with the fourÌýLAs that have not yet indicated that they are implementing the new model, to understand the specific circumstances and consider the need for escalation.ÌýÌýDespite the progress made, significant challenges remain, particularly in respect of the level of confidence forÌýLAs to carry out necessary data reporting.ÌýÌýThis will continue to be a cause for concern until we can get the necessary reassurances fromÌýLAs and their MIS providers.ÌýÌý

3.3ÌýÌýÌýÌýÌýÌýÌý ÌýRollout of the new FSDM continues to be a priority programme of work.ÌýÌýDelays because of MIS providers failing to provideÌýLAs with the required software updates, and issues with data conversion, have impacted on the planned rollout schedule.ÌýÌýWhileÌýour expectation remains that allÌýLAs with responsibility for food standards will be implementing the new model by 31 March 2026 and be able to report data to the FSA, we must be mindful that long standing issues with quality of data may affect the level of accuracy of some of the responses.ÌýÌýWhilst we are providing support and taking action now, ultimately it is eachÌýLA’s responsibility to have regard to the Code.ÌýÌýWe continue to supportÌýLAs with single points of contact and are closely monitoring progress, as failure to accurately report is grounds for performance management in its own right.

4ÌýLAÌýPerformance on Food Standards

4.1ÌýÌýÌýÌýÌý ÌýIn England, meaningful performance management ceased in 2015 when the previous Food Standards Delivery Model (FSDM) was deemed unfit for purpose.ÌýÌýIt was reinstated in 2021 to monitor progress against the COVID-19 Recovery Plan, with an expectation across all three countries that Category A interventions were completed, along with any work required for businesses affected by new legal requirements on food information for Pre-Packed for Direct Sale (PPDS) foods.ÌýÌýAfter the Recovery Plan ended, the FSA issued guidance to allÌýLAs, setting a clear expectation to resume delivery in line with the Code.ÌýÌýIn England, performance management continued to focus on Category A interventions, while Wales and Northern Ireland (NI) returned to monitoring all categories (A–C).ÌýÌýThese differences reflected that Wales had not yet implemented the new FSDM, and NI had maintained resource levels, avoiding significant backlogs.ÌýÌýNew allergen legislation, now embedded in the risk assessment framework of the revised FSDM, has reinforced the importance of delivering official food safety controls.

4.2ÌýÌýÌýÌýÌý ÌýPerformance data in relation to FS evidences the scale of the challenges and why it will take time to transition towards full compliance with the Code.ÌýÌýThe full data described below can be found inÌýAnnex A:

• Table 1 shows the percentage of interventions achieved at establishments that were due an intervention.ÌýÌýReassuringly, in England the figure for Category A was 78% in 2019/20 (pre-pandemic) and in 2024/25 that figure stood at 90%.ÌýÌýHowever, for Category B and C where the bulk of establishments sit, the numbers achieved in 2019/20 were 29.7 and 32.4% compared to 17 and 16% respectively in 2024/25.ÌýÌýTable 2 shows the actual number of overdue interventions, for England this was 126 Category A, 56,647 Category B and 65,094 Category C in 2024/25.
• Table 3 shows the volume of establishments that have never received an initial intervention (unrated with an unknown understanding of the business compliance for food safety as it has never been visited) sits at circ 83,000 establishments.ÌýÌýDuring the data conversion process to the FSDM, large numbers of backlogs of essentially unrated premises have been identified, indicating that the scale of this problem, whilst now becoming clearer, is a significant cause for concern.
• ÌýTable 4 shows the reduction in FS resources from 2012/13 through to 2024/25, reducing from 445 in England to 269 full time equivalent staff.ÌýÌý

4.3ÌýÌýÌýÌýÌý ÌýThe new FSDM now in place will enableÌýLAs to make better use of the resources they have, with intervention frequencies that are more risk-based and potential for greater use of intelligence to inform action.ÌýÌýHowever, it does not solve the underlying resourcing problems inÌýLAÌýfood standards teams.ÌýÌýLAs have reported to us that, even with additional funding, they still face challenges recruiting competent and qualified people.ÌýÌý

4.4ÌýÌýÌýÌýÌý ÌýGiven this history, we consider it will take the majority ofÌýLAs quite some time (years) to reach full compliance with the new Code in England.ÌýÌýWe therefore recommend that we set, for performance management purposes, a risk-based, proportionate and graduated timeline forÌýLAs to realign and deliver in accordance with the Code, in a similar manner to the recovery plan introduced during the COVID-19 pandemic.

4.5ÌýÌýÌýÌýÌý ÌýThere are not the same performance issues inÌýLAs in Northern Ireland and current data indicates their performance is not at a stage that a performance management framework is required.ÌýÌýAs such FS delivery against the Code requirements will continue to be monitored and managed as previously.ÌýÌýWhen the FSDM is implemented in Wales then further consideration will be needed on whether to implement something similar and this will remain under review.

5ÌýPerformance Management Framework

5.1ÌýÌýÌýÌý ÌýDue the challenge of completing all required interventions, including accumulated backlogs, and the number of resources removed from the system over many years, we must be realistic that full delivery of the Code requirements will take time.ÌýÌýHowever, the FSA cannot approve a deviation from the Code andÌýLAs acting as competent authorities have a legal statutory duty to have regard to the obligations within it.ÌýÌýWe therefore need an approach to performance monitoring and management that takes us to full compliance with the Code whilst recognising thatÌýLAs will be building their capability.ÌýÌýLAs have requested clarification of the FSA’s expectations for delivery of the FSDM and what will trigger performance management thresholds.Ìý

5.2ÌýÌýÌýÌý ÌýThe FSDM and flexibilities within the revised Code (October 2025) will help supportÌýLAs delivering their service in a risk-based way.ÌýÌýRecruitment and retention of competent and qualified staff remain a significant challenge, and our proposed performance management framework has been developed to recognise the necessity forÌýLAs to grow their resources over time.ÌýÌýThe framework places a clear emphasis on service planning and looking ahead for the resources that will be required to achieve each milestone and to consider utilising less qualified support officers, trainees and apprentices where appropriate to grow their teams.ÌýÌýÌý

5.3ÌýÌýÌýÌý ÌýThe full performance management framework can be seen inÌýAnnex BÌýand is intended to give clear expectations toÌýLAs on the timeline for recovery, however, it should also be noted that the FSA expects that where possible, quicker progress is made in the interest of consumer safety.ÌýÌýWhile the framework has been aligned to annual end of year reporting and their service planning arrangements to ensure no additional burden is placed uponÌýLAs, we will continue to monitor their progress via the biannual data collection process.

5.4ÌýÌýÌýÌý ÌýThe issues ofÌýLAÌýperformance are far more pronounced in English county councils than their equivalents in Northern Ireland so we must recognise the different operating environments that now exist.ÌýÌýA performance management framework will not be necessary forÌýLAs in NI as they are already exceeding those milestones.ÌýÌýCrafting expectations and communicating them effectively will take careful consideration to ensure that thoseÌýLAs doing a good job are both recognised and do not reduce current levels of service.

5.5ÌýÌýÌýÌý ÌýPresenting clear expectations toÌýLAs now will allowÌýLAs to begin the planning process to meet the framework milestones to mitigate this risk and reduce the numbers requiring performance management intervention.

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6.1ÌýÌýÌýÌý ÌýThe situation in relation to food standards has been complex and challenging in transitioningÌýLAs to the new FSDM, but the fact remains that the reduction of resources delivering food standards byÌýLAs is of the highest concern.ÌýÌýEven when the difficult journey to transition to the new FSDM has been achieved,ÌýLAs will still face issues in being able to deliver interventions at all food establishments in line with their legal and statutory obligations.ÌýÌý

6.2ÌýÌýÌýÌý ÌýThe current known level of deviation from delivery in accordance with the Code requires addressing by the FSA.ÌýÌýHowever, given the time it has taken to reach the current position and the loss of resources delivering FS, it will take time forÌýLAs to fully realign with the Code.ÌýÌýThe FSDM and the new Code (revised October 2025) will help supportÌýLAs in growing their resources over time as there are some new flexibilities that allow competent but less qualified staff to undertake interventions at some of the lower risk establishments.ÌýÌýThis affords the opportunity to bring in trainees / apprentices and regulatory support officers on career pathways and grow the resources in the system, whilst managing risk effectively.ÌýÌýThe addition of the performance management framework, with clear milestones forÌýLAs to achieve, can be regularly monitored by the FSA to ensure unacceptable progress is challenged.ÌýÌýÌýÌý

6.3ÌýÌýÌýÌý ÌýThe Business Committee is asked to:

• Consider and comment on the performance management framework.

Annex A

FS performance data

Table 1 – FS interventions achieved that were due in the reporting period

A-Rated			B-Rated			C-Rated
England	Wales	NI	England	Wales	NI	England	Wales	NI
75.5%	90.8%	94.7%	29.7%	60.3%	89.9%	32.4%	61.5%	80.6%
28.0%	39.0%	73.0%	17.0%	16.0%	38.0%	17.0%	18.0%	23.0%
74.8%	66.6%	80.2%	Ìý	Ìý	Ìý	Ìý	Ìý	Ìý
86.5%	97.6%	100.0%	Ìý	Ìý	Ìý	Ìý	Ìý	Ìý
83.4%	91.8%	100.0%	11.8%	32.7%	74.7%	11.7%	34.6%	73.0%
90.3%	94.7%	96.3%	17.0%	43.9%	75.9%	16.0%	34.7%	51.5%

Table 2 – FS establishments that were overdue an intervention by volume

	A-Rated			B-Rated			C-Rated
Ìý	England	Wales	NI	England	Wales	NI	England	Wales	NI
2022/23	542	6	0	Ìý	Ìý	Ìý	Ìý	Ìý	Ìý
2023/24	288	11	0	59,121	2,986	139	71,398	3,791	1,040
2024/25	126	7	3	56,647	2,065	149	65,094	3,492	833

Table 3 – Volume of FS establishments that are awaiting a first inspection (unrated)

	England	Wales	NI	Total
2022/23	85,595	5,635	519	91,749
2023/24	87,381	5,270	394	93,045
2024/25	83,361	3,897	285	87,543

Table 4 – FS FTE – number of occupied posts (available resources in the system)

	Occupied FTE posts
Ìý	England	Wales	NI	Total
2012/13	445	55	60	560
2013/14	347	49	47	443
2014/15	301	44	48	393
2015/16	269	48	35	352
2016/17	256	55	31	342
2017/18	245	57	35	338
2018/19	272	51	30	354
2019/20	266	47	34	347
2020/21	147	19	24	190
2021/22	279	45	28	352
2022/23	252	53	28	343
2023/24	304	64	27	394
2024/25	269	62	29	360

Annex B

Performance Management Framework with timeline milestones

Timeline	FSA EXPECTATIONSÌý– All expectations should be treated as a minimum and where aÌýLAÌýcan deliver their legal obligations within the Code or make quicker progress than those below, they are expected to do so. Dates used for the timeline are linked to end of year reporting, the expectation is that interventions are delivered when due or quicker if intelligence or other factors require a quicker response.
End of March 2026	- A full database conversion has been completed for all establishments (including backlogs) and the new FSDM risk rating score applied to identify the frequency of next intervention or Inherent Risk (IR) score for establishments that have yet to receive a first intervention (including unrated backlogs). - Priority interventions (1,3, and 6 months) identified during the transition to the FSDM have been completed in line with due intervention frequency.ÌýÌýThis refers to establishments where compliance has been determined on a previous intervention. - All establishments with an Inherent Risk of 1 or 2 identified during the data conversion, including those within unrated backlogs, have received a first intervention. - TheÌýLAÌýcan report to the FSA with accurate and reliable data. - A service plan which includes the service demand and resource requirement to meet demand and achieve the next years milestone.
End of March 2027	- All priority interventions (1,3 and 6 month) have been completed.ÌýÌýThis includes any overdue interventions from backlogs or establishments whose risk rating increased when applying the new score in the data conversion process. - New Business Registrations received from 01 April 2026 have been dealt with in accordance with the Code – - IR score 1 or 2 = 28 days - IR score 3 or 4 = 3 months - IR score 5 = 6 months - Any historic backlogs of unrated establishments identified as high priority (IR 1 or 2) during data conversion process or desk top assessment have received an intervention. - An updated service plan to include the resources required to meet demand, including achieving the next years milestone.
End of March 2028	- All priority interventions (1, 3, 6 month) due / overdue have been completed. - All interventions required within 12 months have been completed.ÌýÌý - New Business Registrations received from 01 April 2027 have been dealt with in accordance with the Code. - All medium risk historic backlogs of unrated establishments (IR score 3 or 4) where no first intervention has been delivered, have received an intervention. - An updated service plan to include the resources required to meet demand, including achieving the next years milestone.
End of March 2029 and future years	- All priority interventions (1, 3, 6 month) due / overdue have been completed. - All interventions required within 12 months have been completed.Ìý - All interventions required within 24 months have been completed. - New Business Registrations received from 01 April 2028 have been dealt with in accordance with the Code. - All low risk historic backlogs of unrated establishments (IR score 5) have received an intervention. - An updated service plan to include the resources required to meet demand, including all interventions due as prescribed by the Code.ÌýÌýfrequencies

Footnote 1. ÌýAs part of the Food Standards Agency duties under the Food Standards Act 1999, and in accordance with the requirements of Regulation (EU) No 2017/625 (OCR) on official controls (retained law in England and Wales).Ìý