Social sustainability, the FSSC 24000 certification scheme

In the increasingly complex landscape of organizational sustainability, the social responsibility represents a dimension so far underestimated, beyond the circuits — unfortunately still limited — of fair and solidarity supply chains (Dongo et al., 2019) and the even rarer SA 8000 certification. The FSSC Foundation (Foundation for Food Safety Certification), a non-profit organization based in the Netherlands already known for the certification scheme of food safety management systems FSSC 22000, has extended its scope by developing the FSSC 24000 certification scheme, dedicated to social management systems (Social Management System, SMS).

The scheme was published in October 2022, in Version 1.0 still in force, as a structured tool to verify that organizations ensure working conditions safe and fair, comply with ethical requirements of business and apply the due diligence in managing their own supply chain (FSSC, 2022).

Unlike other social evaluation tools, compliance FSSC 24000 stands out for being aligned with theapproach of management systems ISO, integrating the PDCA cycle (Plan-Do-Check-Act) and risk-based approach in a system subject to audits by third parties and internationally recognized (FSSC, 2026a).

Due diligence, the directives in the European Union

The introduction of FSSC 24000 takes place in a rapidly evolving European and global regulatory context, characterized by increasing attention to corporate responsibility towards human rights and of social sustainability. The legal framework reference in the European Union is defined by two directives, both amended in 2026:

- the Corporate Sustainability Reporting Directive (CSRD, directive 2022/2464, transposed in Italy with legislative decree 6 September 2024, no. 125) introduced extended sustainability reporting obligations, which include indicators related to workers' rights, diversity, and working conditions (Dongo et al., 2022);

- the Corporate Sustainability Due Diligence Directive (CSDDD, directive 2024/1760) in turn requires companies to identify, prevent, and mitigate negative impacts on human rights and the environment along their value chains (Dongo, 2024). Its transposition in Italy is still pending: the government delegation is contained in Annex A to the law of 17 March 2026, no. 36 (European delegation law 2025).

Both regulations have been amended by Directive (EU) 2026/470, which entered into force on 18 March 2026, transposing thel first of the six simplification packages presented by the European Commission (Omnibus I, dedicated to sustainability. Dongo, 2025), after the postponement already established by Directive (EU) 2025/794, implemented in Italy with law 8 August 2025, no. 118, which amended legislative decree 125/2024.

The simplifications introduced by the package Omnibus I

The simplifications introduced following the transposition of the package Omnibus I substantially reduce the number of obligated entities and rewrite some substantial mechanisms of due diligence:

• the CSRD it now only applies to companies with more than 1,000 employees e one net turnover greater than 450 million euros, that is the revenues from sales of products and services rendered net of discounts, VAT and other directly related taxes (Directive 2013/34/EU, Article 2, point 5);
• the CSDDD in turn now applies only to Union companies with more than 5,000 employees on average e a global net turnover exceeding 1.5 billion euros, or to companies from third countries with net turnover in the Union exceeding 1.5 billion euros (Directive 2024/1760, Article 2, paragraph 5).

At the level of contents, the two acts retain distinct natures:

• the CSRD imposes an information obligation, to be fulfilled in a dedicated section of the management report according to the European Sustainability Reporting Standards, with external verification in the form of limited assurance; the possibility of introducing in the future a reasonable assurance has been removed;
• the CSDDD instead introduces a duty of means, consisting of eight requirements: integration of due diligence in risk management policies and systems; identification and assessment of negative impacts; prevention of potential impacts and cessation of actual impacts; remediation; stakeholder involvement; reporting mechanism and complaint procedure; monitoring of effectiveness; public communication (Directive 2024/1760, Article 5).

Three changes affect the content of these obligations:

– theidentification of impacts now takes place in two phases, a preliminary survey based solely on reasonably available information and an in-depth assessment limited to areas where impacts are more likely and severe (Article 8, paragraph 2);

– requests for information to business partners are allowed only if necessary and, towards partners with fewer than 5,000 employees, only when the data cannot be reasonably obtained otherwise (Article 8, paragraph 2 bis);

– the obligation to adopt a transition plan for climate change mitigation has been removed, while the harmonized regime of civil liability it has been replaced by a referral to national law, with full compensation rights and a ban on overcompensation (article 29).

The framework of obligations and deadlines is summarized as follows.

	CSRD (EU Directive 2022/2464)	CSDDD (EU Directive 2024/1760)
Nature of the obligation	sustainability reporting in the management report	due diligence on human rights and the environment in the value chain
Union companies	net turnover over 450 million euros and more than 1,000 employees on average (cumulative criteria)	more than 5,000 employees on average and global net turnover over 1.5 billion euros
Franchising and licensing	not foreseen	royalties in the Union over 75 million euros and global net turnover over 275 million euros
Third-country companies	net turnover in the Union over 450 million euros, with a subsidiary or branch in the Union over 200 million euros	net turnover in the Union over 1.5 billion euros
Periodic update	annual	policy of due diligence at least every 24 months; effectiveness evaluation at least every 5 years
External verification	limited assurance mandatory	optional third-party independent verification, supporting the obligations
Sanctions	left to Member States	financial penalties, with a maximum limit of 3% of the global net turnover
Transposition	19 March 2027	26 July 2028
First application	financial years starting from 1 January 2027	from 26 July 2029; annual communication for financial years starting from 1 January 2030

Transitionally, for financial years starting between 1 January 2025 and 31 December 2026, Member States may exempt companies that do not meet the new thresholds from reporting.

The FSSC 24000 certification scheme

Regulatory foundations and structure

FSSC 24000 is a voluntary certification scheme based on the technical specification BSI/PAS 24000:2022 (Publicly Available Specification), published by British Standards Institution, and the Additional Requirements of the FSSC 24000 Scheme, determined by Board of Stakeholders of the Foundation itself. This is accompanied by the BoS Decision List, dynamic document that prevails over existing rules or clarifies their scope, with defined transition periods (FSSC, 2022).

the PAS 24000:2022 defines the minimum requirements for the establishment, implementation, maintenance, and continual improvement of a social management system, using the process approach, the PDCA cycle, and risk-based thinking. The harmonized structure (Harmonized Structure) allows smooth alignment with other ISO standards, such as ISO 9001, ISO 14001, and FSSC 22000 LINK TO NEW ARTICLE, and therefore the implementation of integrated management systems (FSSC, 2026a).

The scheme FSSC 24000 is divided into five parts, plus two appendices (definitions and normative references) and three annexes that are also mandatory:

1. context and scope of certification;
2. requirements for organizations subjected to audit;
3. requirements for the certification process;
4. requirements for certification bodies;
5. requirements for accreditation bodies.

Scope of application

The FSSC 24000 certification targets manufacturing and processing — food e non-food — and related services that primarily include distribution wholesale and retail (including through e-commerce), as well as the logistics. Excluding tobacco supply chains and various others (furs, weapons, explosives and ammunition, nuclear fuel).

the multi-site certification by sampling is allowed only in services, not in manufacturing, where each site must be certified individually. Chains up to twenty sites are fully audited; beyond that number, the annual audit may be limited to a sample, provided that over the three-year cycle all sites are nonetheless visited (Part 3, clause 5.3).

Theaudits covers theentire site and all workers — permanent, temporary, part-time — including non-employees under the organization's control, contractors included, as well as provided or imposed accommodations and warehouses off-site of the same legal entity. A warehouse also serving other clients, including other group companies, requires separate certification (Part 3, clauses 4.2 and 5.2.2).

FSSC 24000 and FSSC 22000 remain independent schemes: certification can concern one, the other, or both (FSSC, 2025a).

Certification process

The path of certification is structured into the following phases:

• understanding of requirements;
• operational implementation;
• selection of an authorized certification body;
• certification audit with closure of non-conformities;
• maintenance of compliance through annual surveillance audits over the three-year cycle (FSSC, 2025b).

Theinitial audit is divided into two stages: Stage 1, documentary and preparatory in nature, and Stage 2, to verify the effective implementation of the system. The interval between the two cannot exceed six months; beyond that term, Stage 1 must be repeated. The first surveillance audit, in turn, cannot be scheduled more than twelve months from the certification decision date, under penalty of certificate suspension (FSSC, 2022).

the duration of the audit is calculated based on the total number of workers and site area, with a minimum of one man-day (and a maximum reduction of 20%, if documented and justified). The number of workers to be interviewed and personal files to be examined varies from 4, for sites up to 49 employees, up to 30 for more than 2,000. Interviews must be conducted confidentially, without supervisors or management, in a language understood by the worker.

The certificate is valid for three years and is subject to audits surveillance annual and a recertification audit at the end of the third year. Certified organizations are included in a public registry available on the FSSC website, updated daily, ensuring transparency and visibility towards clients and stakeholders (FSSC, 2025b).

Certification bodies and auditor qualification

The robustness of the scheme is guaranteed by stringent requirements for certification bodies and by an auditor qualification among the highest in the sector. The control bodies must:

• be accredited according to the standard ISO/IEC 17021-1 by an accreditation body signatory to the multilateral recognition agreement;
• adhere to theAPSCA (Association of Professional Social Compliance Auditors);
• obtain a specific license from the FSSC Foundation (FSSC, 2026a; FSSC, 2026b).

The auditors must be employees or contracted by an authorized certification body and affiliated with APSCA. To lead an FSSC 24000 audit, holding the CSCA designation is mandatory (Certified Social Compliance Auditor. FSSC, 2022; FSSC, 2026b). APSCA oversees 84 member companies and over 5,300 auditors in more than 100 countries, who conduct almost 200,000 audits per year (FSSC, 2026b).

A further safeguard of independence is mandatory rotation: no auditor may operate for more than two three-year cycles at the same certified organization, neither as lead auditor nor as co-auditor, and must then stay out for at least one year before returning (FSSC, 2022).

Unannounced audit and integrity program

As with FSSC 22000, FSSC 24000 also requires at least one audits surveillance without notice, every three years, after the initial certification audit. The respective procedure provides that the audit plan is not shared before the opening meeting and the inspection of the premises begins within an hour of the auditor's arrival; refusing to undergo the audit results in the suspension of the certificate within three working days and withdrawal if the verification is not carried out within six months.

The FSSC Integrity Program represents an additional element of assurance: through a continuous monitoring system that includes training, mentoring, document reviews, evaluations at the certification bodies' offices, and witnessed audits, the Foundation ensures compliance with standards and consistency of certification results. The program, inherited from the consolidated experience with FSSC 22000, constitutes the cornerstone of market confidence in the scheme (FSSC, 2026a).

Advantages and burdens related to the adoption of the scheme

Advantages

FSSC 24000 certification offers organizations strategic and operational advantages of various kinds:

• demonstrate commitment to social sustainability, in compliance with Directive (EU) 2024/825 on (social and) environmental claims, transposed in Italy with Legislative Decree 30/2026, without incurring the risk of challenges for unfair commercial practices (greenwashing) now subject in Italy to fines up to 10 million euros (Dongo et al., 2026);
• The international recognition — benchmarking SSCI of Consumer Goods Forum, endorsement by Global ACI, inclusion in the ITC Standards Map, acceptance by EcoVadis since December 2025 — facilitates access to global markets;
• the reduction ofaudit fatigue allows meeting the requirements of compliance social of multiple clients without hosting repeated second-party audits, reducing operational disruptions;
• the structure harmonized with ISO standards allowsintegration with existing management systems, optimizing resources and audit times.

From the point of view of risk management, the systematic approach of FSSC 24000 helps identify and manage risks related to human rights, labor practices, and business ethics, contributing to brand protection. The difference compared to traditional social audits, as highlighted by the Foundation's technical management, lies in the shift from episodic preparation for audits to a permanent management system, where the analysis of the organization's specific risks adds its own controls to the basic ones (FSSC, 2026b).

The implementation ultimately positions organizations ahead of regulatory obligations, reducing regulatory risk and strengthening the relationship with buyer, who can thus consider the greater reliability of certified suppliers (as lower-risk partners).

Burdens

The adoption of the FSSC 24000 scheme also involves significant charges to be realistically considered. The first is represented by implementation costs: setting up a social management system compliant with PAS 24000:2022 and additional requirements requires investments in training, procedure revision, social risk mapping as well as, often, support from external consultants. Small and medium enterprises may find the adjustment challenging, despite having support tools and guidance documents made available for free by the Foundation (FSSC, 2025b).

I certification costs must be considered on two levels. The Foundation's fees include a charge of 330 euros for each audit report uploaded on the platform, owed by the certified organization through its certification body, with a surcharge per site in multi-site certifications, and an annual fee borne by the certification body (CB) ranging between 7,500 and 15,500 euros depending on the volume of reports (FSSC, 2026c). To these is added — and this is the main item — the remuneration for the audit activity, determined by the days calculated according to the scheme tables. Unannounced audits then impose a constant operational readiness, with resources dedicated to internal monitoring and document management.

The severity of the non-compliance regime must finally be considered, graded into minor, major, and critical. Major non-compliances must be defined within 28 calendar days from the last day of the audit, under penalty of suspension of the certificate or full repetition of Stage 2. Critical ones — use of child labor, forced labor, inhumane treatment, safety violations exposing workers to imminent danger, attempted auditor bribery, concealment of production sites — result in suspension of the certificatewithin three working days and withdrawal if not resolved within six months. If they emerge during the initial certification, the audit has failed and must be fully repeated (FSSC, 2022).

Conclusions

The FSSC 24000 scheme represents a significant step in the evolution of social sustainability governance tools in consumer goods supply chains. Its strength lies in the ability to combine a systemic approach, aligned with the harmonized ISO structure, with rigorous social performance criteria and one of the strongest certification governance in the sector, ensured by integration with APSCA and the Foundation's integrity program.

The paradox of the moment deserves attention. Just as the European legislator restricts the pool of companies directly subject to the obligations of due diligencethe demand for sustainability — which includes social sustainability — is gaining ground in the market and in turn requires the adoption of a third-party certification scheme, such as FSSC 22000, suitable to demonstrate social guarantees throughout the supply chains.

The spread of the scheme is still in its early stages. Interest is evidenced by over 500 registrants for the informational webinar in February 2026 and the first certifications in new markets — the US company RCB International, supplier of essential oils, obtained certification in October 2025 after a process started the previous year — but the numbers are far from the more than 42,000 organizations certified FSSC 22000. Success will depend on the ability of organizations to realistically assess the investmentsnecessary and to integrate the social management system with existing processes, and on the market's ability to recognize the value of a structured and independent verification compared to evaluations of compliance traditional social.

Dario Dongo

References

European Union regulatory sources

Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022 amending Regulation (EU) No 537/2014, Directives 2004/109/EC, 2006/43/EC and 2013/34/EU, as regards corporate sustainability reporting. Consolidated text: 18/03/2026. http://data.europa.eu/eli/dir/2022/2464/2026-03-18

Directive (EU) 2024/1760 of the European Parliament and of the Council of 13 June 2024 on corporate sustainability due diligence and amending Directive (EU) 2019/1937 and Regulation (EU) 2023/2859. Consolidated text: 18/03/2026. http://data.europa.eu/eli/dir/2024/1760/2026-03-18

Directive (EU) 2025/794 of the European Parliament and of the Council of 14 April 2025 amending Directives (EU) 2022/2464 and (EU) 2024/1760 as regards the dates from which Member States are to apply certain corporate sustainability reporting and due diligence requirements. Official Journal of the European Union, L, 16.4.2025. http://data.europa.eu/eli/dir/2025/794/oj

Directive (EU) 2026/470 of the European Parliament and of the Council of 24 February 2026 amending Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 and (EU) 2024/1760. Official Journal of the European Union, L, 26.2.2026. http://data.europa.eu/eli/dir/2026/470/oj

Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition through better protection against unfair practices and through better information. http://data.europa.eu/eli/dir/2024/825/oj

National regulatory sources

Legislative Decree 18 August 2015, No. 139. Implementation of Directive 2013/34/EU relating to financial statements, consolidated financial statements and related reports of certain types of companies, amending Directive 2006/43/EC and repealing Directives 78/660/EEC and 83/349/EEC, as regards the discipline of the financial statements and consolidated financial statements for joint-stock companies and other entities identified by law (15G00153). Normattiva (last update to the act published on 03/05/2026). https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2015-08-18;139!vig=

Legislative decree 6 September 2024, no. 125. Implementation of Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022, amending Regulation (EU) No 537/2014, Directive 2004/109/EC, Directive 2006/43/EC, and Directive 2013/34/EU concerning sustainability corporate reporting (24G00145). Normattiva (last update to the act published on 08/09/2025). https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2024-09-06;125!vig=

Law 8 August 2025, no. 118. Conversion into law, with amendments, of the decree-law 30 June 2025, no. 95, containing urgent provisions for the financing of economic activities and businesses, as well as social measures and matters related to infrastructure, transport, and territorial entities (25G00126). Normattiva. https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:2025-08-08;118!vig=

Law 17 March 2026, no. 36. Delegation to the Government for the transposition of European directives and the implementation of other acts of the European Union – European delegation law 2025 (26G00053). Normattiva. https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:2026-03-17;36!vig=

Legislative decree 20 February 2026, no. 30. Implementation of Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024, amending Directives 2005/29/EC and 2011/83/EU regarding consumer empowerment for the green transition by improving protection against unfair practices and information (26G00047). Normattiva. https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2026-02-20;30!vig=

Scheme documents and institutional sources

BSI. (2022). PAS 24000:2022. Social management system — Specification. British Standards Institution. https://www.fssc.com/wp-content/uploads/2022/11/PAS24000_2022_Social-Management-System.pdf

FSSC. (2022). FSSC 24000 Scheme. Social Management System Certification. Version 1.0, October 2022. Foundation for Food Safety Certification. https://www.fssc.com/wp-content/uploads/2022/12/FSSC-24000-Scheme-Version-1.0_2022.pdf

FSSC. (2025a). FSSC 24000 Version 1.0 FAQ. Foundation for Food Safety Certification. https://www.fssc.com/fssc-24000/fssc-24000-faq/

FSSC. (2025b). How to achieve FSSC 24000 certification. A simple guide. Foundation for Food Safety Certification. https://www.fssc.com/insights/fssc-24000-certification-guide/

FSSC. (2026a). FSSC 24000. Delivering trust and impact for global social responsibility. Foundation for Food Safety Certification. https://www.fssc.com/fssc-24000/

FSSC. (2026b, February). Insights Webinar FSSC 24000. Ethics and systems in action for trusted social compliance [Webinar summary]. Foundation for Food Safety Certification. https://www.fssc.com/insights/insights-webinar-fssc-24000-ethics-and-systems-in-action-for-trusted-social-compliance/

FSSC. (2026c). Requirements for licensed CBs. Foundation for Food Safety Certification. https://www.fssc.com/certification-bodies/requirements-licensed-cbs/

The Consumer Goods Forum & Foundation FSSC. (2024). Joint press release. FSSC 24000 achieves SSCI recognition. https://www.fssc.com/insights/joint-press-release-fssc-24000-achieves-ssci-recognition/

Legal insights

Dongo, D., Baldelli, G. (2018, December 22). Fairtrade, ABC. The kind of Christmas we would like to live every single day. FT (Food Times). https://www.foodtimes.eu/it/pianeta/fair-trade-abc-il-natale-che-vorremmo-ogni-santo-giorno/

Dongo, D., Bosani, E. (2022, November 18). Corporate Sustainability Reporting. The obligation for ESG disclosure for companies begins. FT (Food Times). https://www.foodtimes.eu/it/pianeta/corporate-sustainability-reporting-al-via-lobbligo-di-rendicontazione-esg-per-le-imprese/

Dongo, D. (2024, September 23): Corporate Sustainability Due Diligence Directive (EU) No 2024/1760, the ABC. FT (Food Times). https://www.foodtimes.eu/it/pianeta/corporate-sustainability-due-diligence-directive-eu-no-2024-1760-labc/

Dongo, D. (2025, February 16). DOSSIER – and simplifications, CSR and due diligence at risk? FT (Food Times). https://www.foodtimes.eu/it/pianeta/omnibus-csr-due-diligence-a-rischio/

Dongo, D., Della Penna A.A. (2026, May 15). Environmental claims and unfair commercial practices. FT (Food Times). https://www.foodtimes.eu/it/consumatori-e-salute/direttiva-asserzioni-ambientali-pratiche-sleali/