BRCGS 2026: new Position Statements from 10 August. What do you need to know before the audit?

BRCGS certification is entering the next phase of alignment with the GFSI Benchmarking Requirements 2024. From 10 August 2026, all audits conducted under the BRCGS standards – Food Safety, Packaging Materials, Storage & Distribution and Agents & Brokers – will be assessed against the updated Position Statements (Position Statements). This means that certified companies should start planning a review of their procedures, documentation and training now to avoid non-conformities during their next audit.

Below, we explain the reasons behind these changes, who they affect, and which specific areas of the food safety and packaging management systems require updating.

Why is BRCGS introducing changes in mid-2026?

BRCGS has submitted an application for benchmarking against GFSI 2024 for four standards: Food Safety (9th edition), Packaging Materials (7th edition), Storage & Distribution (4th edition) and Agents & Brokers (3rd edition). In order for these standards to formally meet the new GFSI benchmarking requirements, it was necessary to introduce amendments at the level of individual clauses – without waiting for a full, new edition of the standard. Position Statements serve precisely this function: they provide a binding interpretation and clarification of the standard’s provisions, and are treated as an integral extension of the standard.

As a result, four key documents have been updated:

• F926 – Position Statements for BRCGS Food Safety, Edition 9,
• P708 – a new Position Statements document for BRCGS Packaging Materials, Edition 7,
• SD404 – Position Statements for BRCGS Storage & Distribution, Edition 4,
• AB310 – Position Statements for BRCGS Agents & Brokers, Edition 3.

Companies have a transition period to implement the changes – the changes will come into effect for audits carried out from 10 August 2026, which in practice gives them several weeks to prepare for the new requirements.

Training in food defence and fraud prevention

One of the most significant changes is the introduction of a clearly defined requirement for appropriate competence among those involved in threat assessment and vulnerability assessment, as well as in protection against deliberate food contamination and adulteration. The new provisions go a step further than the previous approach – it is no longer sufficient simply to have a procedure or a food defence plan in place. The team responsible for threat analysis must demonstrate documented knowledge of the risks and the principles guiding their work. In practice, this means it is necessary to:

• planning and documenting training for those involved in threat assessments and food defence plans,
• maintaining records of competencies and training which can be verified during an audit,
• linking this documentation to the HACCP/HARA system and verification procedures.

This change applies not only to the Food Safety standard but also, to varying degrees, to the other standards covered by the update.

Cleaning and disinfection – a new, mandatory element of the hygiene system

Another significant change concerns hygiene procedures. Until now, BRCGS standards have focused mainly on cleaning – now, alongside this, there is a formal requirement to include disinfection where justified from a risk perspective. Importantly, the change is not limited to simply adding a single word to the documentation.

The new requirements include:

• the introduction of disinfection procedures to complement cleaning procedures,
• the obligation to validate and verify these procedures based on a risk assessment relating to the product’s intended use or the nature of the activity in question,
• a formal definition of the term ‘disinfection’ within the standard, which is intended to standardise the interpretation of this requirement by different certification bodies.

For quality departments, this means reviewing existing cleaning and disinfection procedures to ascertain whether they have actually been validated (and not merely verified by routine ATP swab tests), and supplementing the documentation with the relevant records.

Clarification of the rules for monitoring critical process parameters

The changes also include a more precise definition of the rules for monitoring critical parameters in specialised processes, such as food irradiation and high-pressure processing (HPP). The aim is to eliminate ambiguity in the interpretation of which parameters should be monitored, at what frequency, and how deviations from critical values are to be recorded and managed.

Companies using these types of processes should verify whether their current monitoring procedures meet the new, more detailed requirements, and whether monitoring records are properly linked to the HACCP plan.

Safety footwear – clarification of requirements in the Food Safety standard

The provisions regarding protective clothing in the Food Safety standard have also been amended. The update explicitly states that protective clothing – where necessary – should include, amongst other things, beard covers and appropriate, safe work footwear. Particular emphasis has been placed on safety footwear: it must be issued and worn wherever there is a risk of product contamination, whilst also fulfilling a protective and hygienic function for the employee themselves.

This clarification has practical significance – auditors will pay attention not only to whether employees are wearing protective clothing, but also to whether the company’s policy explicitly includes footwear as part of the system for protection against cross-contamination.

What should BRCGS-certified companies do right now?

By 10 August 2026, it is advisable to take several preparatory steps:

1. Familiarise yourself with the full text of the current Position Statements relevant to your standard (F926, P708, SD404 or AB310) – these documents are available on the BRCGS website and should be available on-site during the audit.
2. Carry out a gap assessment in relation to the amended and new clauses, paying particular attention to the competence requirements for teams assessing risks and vulnerability to fraud.
3. Update your HACCP/HARA system documentation, verification procedures and records relating to prerequisite programmes.
4. Supplement cleaning and disinfection procedures with risk-based validation and verification elements.
5. Update training programmes and the internal audit schedule to reflect the new requirements.
6. Mark 10 August 2026 in the audit preparation calendar as the fixed deadline for the changes to come into force.

Companies that are only just planning to implement the BRC/BRCGS system or wish to benefit from the support of an experienced consultant when updating their documentation to meet the new requirements can count on assistance at every stage of this process – from gap analysis to audit preparation.

Summary

The update to the BRCGS Position Statements, which comes into force on 10 August 2026, is the result of efforts to ensure that BRCGS standards are fully compliant with the GFSI Benchmarking Requirements 2024. Although formally these are changes at the level of clause interpretation rather than new editions of the standards, their practical impact on food and packaging safety management systems is significant – covering staff competence, hygiene procedures, monitoring of critical processes and personal protective equipment. Companies that analyse the new requirements now and implement the necessary changes to their documentation and training programmes will significantly reduce the risk of non-compliance during upcoming audits.