BRCGS Foundation Level Is Going: What Foundation Certificated Sites Should Do Now

By Robert Low, Lead Management System Specialist and BRCGS Approved Trainer

Of all the changes proposed in the BRCGS Consumer Products Issue 5 draft, the removal of the Foundation and Higher levels is the one with the sharpest edge. Under Issue 4, Foundation level gave newer or smaller sites a legitimate certification route with a reduced set of requirements. Under Issue 5, based on the consultation draft, there is one standard and one level, and everyone is audited against it.

Why This Matters More Than Any Other Change

If you are certificated at Higher level today, Issue 5 is largely an exercise in re-mapping and topping up your existing system. If you are at Foundation level, the gap between your current obligations and the unified Issue 5 requirements is structural. You are not tweaking a system, you are extending one. Requirements you have never been audited against, formal risk assessment methodology, fuller documentation and evidence expectations, all arrive at once at your first Issue 5 audit.

And your customers will not see nuance. A site that fails its first Issue 5 audit is a site without a certificate, whatever level it used to hold. Retailer technologists tend to notice that.

A Practical Twelve Month Plan

Now to October 2026. Work out your first Issue 5 audit date using the published timeline. Read the consultation draft commentary so you understand the direction of travel, and honestly assess where your Foundation system stops short: risk assessment depth, internal audit coverage, supplier approval, traceability testing. Do not build against draft clause numbers, but do start closing the obvious capability gaps, because training people and embedding habits takes months.

October 2026 to your audit. The day the final standard publishes, commission a proper gap analysis against the final text. Turn the output into a corrective action plan with owners and dates, exactly as you would after an audit. Run at least one full internal audit cycle against the new requirements before the certification body walks in.

Throughout. Treat this as a project with a named owner, not something the quality manager absorbs alongside the day job. The sites that struggle with standard transitions are almost never short of ability. They are short of allocated time.

I offer remote gap analysis and transition support built exactly for this situation, and my article on running an Issue 4 to Issue 5 transition project sets out the full approach. The buttons below will start the conversation.