From local to national: How the FSA plans to reshape food regulation for large retailers

At the March 2026 Board Meeting, the FSA considered a significant paper setting out the proposed scope and direction of the FSA's new Future of Food Regulation programme.

The programme follows the November 2025 budget announcement in which the UK Government specifically directed the FSA to reform the regulation of large food businesses and supermarkets. 

The FSA has already taken steps to modernise the regulatory assurance system, including rolling out a new food standards delivery model and introducing flexibilities in the food hygiene delivery model. It has also gathered views from local authorities and businesses on the potential for cost-recovery, explored challenges with the current registration system through an enhanced registration pilot in Wales, and trialled a new approach to regulation through National Level Regulation ('NLR') pilots with large supermarkets in England. 

However, the FSA has advised its Board that these measures alone are not sufficient to create a sustainable system for the future, and that further structural reform is needed.

National level regulation pilots

A central element of the programme's foundation is the work already undertaken through the NLR pilots with large supermarkets in England. These pilots trialled a new approach to regulation at a national level, and the FSA intends to build on the lessons learned from them as it moves into the design and appraisal of policy options.

The FSA has indicated that it will initially consider how a national system of regulation could function in the retail sector, reflecting the value that the pilots in the retail sector brought and the work already completed by the previous Senior Stakeholder Forum on next steps following the NLR pilot.

The FSA will then assess how a national approach might apply to large businesses beyond the retail sector by engaging with other sectors and conducting an initial discovery on their operating models.

What this means for large retailers

Although the programme is at an early stage, there are several practical steps that large retailers and supermarkets should be considering now.

• Engage with the FSA's working groups and technical advisory forums: The FSA has indicated that it will use working groups and technical advisory forums to develop initial proposals, with concentrated phases of wider stakeholder engagement planned over the next 12 months. Large retailers should engage proactively as the detailed design phase begins, given that the retail sector will be the initial focus of the national regulation workstream.

• Monitor the national regulation workstream: The FSA intends to consider the retail sector first, before assessing how a national approach might apply to large businesses in other sectors. Retailers operating national or multi-site models should follow the progress of this workstream closely, as it will address fundamental questions about how national regulation is structured, who the competent authority will be, and what enforcement powers will apply.

• Review and stress test existing Primary Authority arrangements: The role of Primary Authority Partnerships may evolve significantly under the new framework. Large retailers with existing PAPs should assess how any changes might affect their current arrangements and consider the implications for their broader regulatory compliance strategy.

• Consider data readiness: Data ownership, integrity and standards will be central to the new model. Large retailers should assess the quality and accessibility of their internal compliance data, and consider whether their current data systems and governance arrangements are capable of supporting the centralised, data-led approach envisaged by the programme. 

• Factor potential new costs into forward planning: The future model may involve new registration, licensing or other fees. Large retailers should factor this possibility into their planning, while noting that the FSA has acknowledged the context of rising operating costs across the sector and that businesses have been clear they would oppose paying f without demonstrable added value.

• Coordinate engagement: Large retailers should consider nominating a single point of contact or dedicated team for engagement with the programme, to ensure a coherent and strategic response. Businesses have told the FSA that they prefer coordinated "change moments" rather than frequent piecemeal updates, and effective internal coordination will be essential to managing participation in consultations alongside other competing change pressures.

Next steps and timeline

The key milestones are as follows:

• April 2026: Programme formally established.
• June 2026: Detailed workplan published; legislative mapping exercise update provided to the FSA Board.
• 2026 to 2027: Working groups and technical advisory forums convened, with the national regulation workstream initially focused on the retail sector. Concentrated phases of wider stakeholder engagement planned over the next 12 months.
• Ongoing: Regular updates to the FSA Board at subsequent meetings, with reform proposals brought forward under each workstream in line with the detailed workplan.

We will follow the development of this programme and provide updates in our next edition of Food for Thought.