20 Jan 2026

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Modernising Food Regulation: Navigating the 2025 Updates to the Food Law Codes of Practice

Modernising Food Regulation: Navigating the 2025 Updates to the Food Law Codes of Practice

by Dr Marie Vaganay Miller, Senior Lecturer in Environmental Health at Ulster University and RIAMS Specialist

The landscape of food safety regulation is undergoing a period of profound transformation. Driven by evolving consumer habits, industry pressures and the ongoing resource constraints faced by local authorities, the Food Standards Agency (FSA) has placed the modernisation of food regulation at the top of its agenda. 

Following a comprehensive 12-week consultation earlier this year, the FSA published the revised Food Law Codes of Practice (CoP) and Food Law Practice Guidance (PG) on 27 October 2025. These updates apply across England, Wales and Northern Ireland, marking a definitive shift toward a more agile and intelligence-led enforcement era.  

The CoP is a statutory document providing essential instructions that local authorities and enforcement bodies must follow by law, whilst the PG is ‘non-statutory’ and offers practical advice on how to implement the rules effectively on the ground. Together, these documents ensure that food safety interventions stay consistent, proportionate and effective across all regions

The updates introduce a more flexible, risk-based approach to food regulation, allowing local authorities to use alternative control methods more widely, including remote assessments, broadening the cohort of professionals who can undertake certain official control activities. The key changes in the revised codes can be categorised into two broad sections: Operational and Workforce related. 

Operational evolution: Flexibility and intelligence 

The 2025 updates introduce a risk-based approach designed to optimise resources while maintaining high safety standards.

  • Flexible triage for new businesses: Moving away from the rigid 28-day inspection target, local authorities now have the flexibility to triage new food business registrations. This allows them to focus immediate physical inspections on higher-risk establishments, while adjusting the timescales for lower-risk sites. 

  • The digital shift: The new code formalises the use of remote official controls. In specific circumstances, ‘desktop reviews’ and remote assessments can be utilised to streamline regulation. However, to protect the integrity of the Food Hygiene Rating Scheme (FHRS), these methods generally do not apply to businesses within the rating scope. 

  • New food standards delivery model (FSDM): Wales has officially implemented the FSDM, aligning it with the system already used in England and Northern Ireland since 2023. While the FSDM was technically introduced in 2023 for England, the 2025 guidance officially incorporates it into a unified statutory requirement. This updates how local authorities regulate food standards such as labelling and composition, and this model prioritises checks on high-risk establishments and uses ‘intelligence-driven’ data to target fraudulent or unsafe food further up the supply chain. 

A workforce for the future: Competency focus 

Perhaps the most significant changes involve the professionals’ enforcement workforce. The FSA has moved to address recruitment shortages by broadening the professional cohort and reviewing the competency framework.

  • Expanded workforce: The range of professionals authorised to perform food controls has been broadened. Competent officers who may not hold traditional qualifications can now undertake specific tasks, allowing qualified environmental health practitioners to focus on more complex, high-risk cases. 

  • The competency framework: The most critical structural change is the transition from role-based to activity-based competency. An officer’s job title no longer defines competency. Instead, a new competency framework defines the specific skills and knowledge required for each task (e.g. auditing, sampling or remote assessment). Officers who do not hold a traditional qualification can now demonstrate proficiency and undertake specific activities. The FSA launched a revised competency standard in 2025 to help local authorities assess staff training needs and advance professional development plans.  

  • Meaningful professional development: The prescriptive requirement for a fixed number of continuing professional development (CPD) hours (previously 20 hours per year) has been removed. In its place is a requirement for officers to demonstrate ongoing, relevant competence. The focus has shifted from ‘clocking hours’ to ensuring training is relevant and effective for the specific activities an officer is authorised to perform. 

The key changes at a glance: 



Feature 



2023 Framework 


 



2025 Framework (current) 



New registrations 



Mandatory 28-day inspection target 



Risk-based triaging upon registration 


 



Inspection methods 



Primarily in-person visits 



Increased use of remote assessments 


 



Professional requirements 



Strict role-based qualifications 


 



Broadened professional cohort 



Training (CPD) 



Mandatory minimum hours 



Competency-led (hours removed) 


 

To conclude, the 2025 updates represent a pragmatic response to a modern food industry. By empowering local authorities with greater flexibility and focusing on demonstrable competence rather than credentials alone, the FSA aims to ensure the UK’s food safety system remains resilient and fit for the future. 


 

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