Annual Local Authority Performance

1. Summary

1.1      The paper updates the Board on Local Authority (LA) performance in enforcing food law for the financial year 2024/25 and complements the regular reporting to the Business Committee.  It also provides information and statistics on the delivery of animal Feed Official Controls, and rollout information regarding the Food Standards Delivery Model (FSDM) in England and Northern Ireland.

1.2      The Board is asked to consider and comment on:

• LA performance

• The rollout of the FSDM, monitoring and performance management approach 

2. Introduction

2.1      LAs enforce compliance with food safety and standards legislation for most food businesses and must do so in accordance with the Food Law Codes of Practice (the Code).  In England and Wales, the same is true for animal feed safety and standards.  The FSA has statutory duties to monitor and report on their performance.

2.2      LAs have worked hard over the last few years to get through the backlog of interventions which built up during the pandemic, and to get back on track with the requirements of the Code.  This is evidenced through the national intervention statistics which are gradually improving, highlighting the risk-based approach LAs are employing to address their backlogs.  However, there remains a large backlog for interventions at lower risk establishments.

2.3      Work continues on potential improvements to the regulatory framework.  This paper updates on some key developments in this work and provides updates from recent engagement events with LAs as part of our approach to regulatory reform.  A fuller update on the future of regulation work will be brought to the Board in December 2025.

3. Update on LA performance

Food hygiene intervention data

3.1      The pattern of delivery by LAs changes throughout the year.  Similar to previous years, the percentage of interventions carried out at higher risk establishments (rated A, B, C) fell from April 2024 into October, but all levels subsequently improved in April 2025.  Lower risk establishments (rated D, E) have seen continued improvement in each bi-annual return from October 2023 onwards as LAs work to catch up on backlogs (Annex 1).

3.2      The overall percentage of due food hygiene interventions carried out at establishments (A to E) has increased across all three countries, from approximately 52% in both April and October 2024 to 62% in April 2025.  The largest improvements are seen across C, D and E-rated establishments – most notably England seeing a 14 ppt increase in their E-rated interventions carried out to 42%.  Whilst A and B rated establishments have largely recovered to pre-pandemic levels and remain similar to rates seen at the end of the Recovery Plan, C-rated establishments remain minimally lower.  D and E-rated establishments, though seeing continued positive improvement remain notably below pre-pandemic levels, which themselves did not fully align to the Code.  Annex 1 shows LA performance in delivering the hygiene interventions for establishments in each risk category.  Charts 1 to 5 show performance for each country risk rating since 2019/20.

3.3      Local Authorities (LAs) continue to face increasing pressure due to the sustained rise in new business registrations.  In 2024/25, there were 96,283 new registrations, up from 90,613 in 2023/24.  This growth is driven by both genuine new business openings and re-registrations resulting from changes in ownership.  At the same time, the number of unrated establishments —those yet to receive a first inspection—has decreased from its peak of 77,000 in April 2021, to around 39,000 in April 2025.  While this reduction suggests progress in addressing inspection backlogs, the remaining volume still represents a significant level of unknown public health risk.

3.4      Although full-time equivalent (FTE) resources dedicated to food hygiene have improved since the pandemic, most notably in England, the overall number of Environmental Health (EH) and Trading Standards (TS) officers remains substantially below levels seen more than a decade ago.  LAs continue to report ongoing resourcing challenges, which limit their ability to respond effectively to increasing demand.

3.5      Despite the inspection backlogs, Food Hygiene Rating Scheme (FHRS) data trends show no evidence of a drop in establishment compliance (see charts 9 and 10).  Although percentages vary in each of the three countries, the overall three-country data indicate a stable level of establishments achieving a rating of ‘3 – generally satisfactory’ or better, which has remained at 97% for the last four years.  The overall proportion of rated establishments with the top of rating of ‘5 – very good’ has increased consistently from 72% in March 2020 to 77%.  In England and Wales, the proportion of top-rated establishments has consistently increased since March 2020 (to 77% and 74% respectively).  In Northern Ireland, the proportion of top-rated establishments peaked at 84% in June 2022 and now stands at 82%.

Food standards intervention data

3.6      Overall, LAs continue to make progress with backlogs of interventions at all establishments at a national level compared to April 2024.  There are three risk ratings for food standards: A to C.  Progress is notably slower at B and C-rated establishments; these figures indicate that LAs are adopting a risk-based approach to the delivery of food standards official controls, focusing on those businesses which pose a higher risk to consumers.  To note, due to 12 LAs having transitioned to the FSDM prior to the 31 March 2025 and being exempt from providing a data return in April 2025, we do not have a full dataset for food standards in England.  However, the data is sufficiently complete to be indicative of recent trends.

3.7      LAs continue to struggle to catch up on backlogs at B and C-rated establishments, a situation which is exacerbated by increases in the number of new food businesses registrations.  Charts 7 and 8 show Wales and Northern Ireland making more progress than England in B-rated establishments, but Northern Ireland in particular reports a 21.5% decrease in their C-rated interventions being carried out.  As LAs implement the new FSDM in England and Northern Ireland this year, the profile of the backlog will change, as some establishments will be considered higher risk under the new system and some lower than before.  As a result, we may see a short-term worsening of figures immediately following implementation in relation to high-risk establishment for the first 12 months, with a knock-on effect leading to a reduction in delivery rates at non high risk over the following few years as the establishments now considered high risk take priority.

New FSDM implementation

3.8      The FSA has just introduced a new delivery model for LAs to address long-standing concerns with how effective food standards controls were.  This model, developed in partnership with LAs and the food industry, went live on 1 April 2025.  As of 30 July, 151 LAs across both England and Northern Ireland (97%) have reported to us that they are live with the new model, with 89 of these LAs (59%) recording official control data via a temporary solution while they await an MIS update.  All LAs in Northern Ireland have implemented the new model.  A further 4 LAs have not demonstrated that they have made acceptable progress in the adoption of the new model, and the performance management team are working closely with them to secure required improvement utilising the FSA’s established escalation process where appropriate. 

3.9      We acknowledge the significant challenges encountered during the rollout of the new FSDM and commend the hard work of LAs in overcoming them.  These challenges primarily stem from the diverse landscape of Management Information Systems (MIS) used across LAs in England and Northern Ireland.  Each LA typically operates systems provided by different IT vendors or develops its own in-house solutions, tailored to meet local requirements.  This diversity in system architecture and configuration presents substantial barriers to implementing consistent updates.  The lack of standardisation across platforms, coupled with varying timelines for implementation by system providers, has made it difficult to achieve uniform progress.

3.10   Alongside the introduction of the new food standards delivery model, we are replacing the current LA survey-based reporting system with a new data return approach.  This will enable LAs to run reports via their MIS systems and submit them to the FSA thereby reducing the administrative burden of LAs putting data into questionnaires.  The ability of a LA to report data is dependent on the LA MIS providers developing reporting tools following the implementation of the new model.  The data submitted by LAs will be fed into an insight engine which uses new technologies to improve data quality.  LAs use different MIS systems and coding, the insight engine will help reconcile and standardise the data for reporting purposes.  We have written to LAs that transitioned to the new food standards delivery model before the 31st of March and explained that a data return will be required in October 2025, which will allow an early test of the process.  We will continue to work with the remaining LAs over the next 6 months to ensure all LAs are able to provide a food standards data return in April 2026.

3.11   In Wales, the consultation on adopting the new FSDM closed on 19 May and the summary of responses was published on 11 August. In total fifteen individual responses were received, with 10 from LAs, plus responses from Environmental Health Wales and Trading Standards Wales (each representing all LAs in Wales), a professional body and two industry representatives.  Respondents agreed the current delivery model for food standards official controls requires changing in Wales and expressed the need for there to be further clarity in the proposed new model to ensure consistent application.  Some concerns were raised regarding resourcing issues which is already a known challenge and forms part of the Resourcing workstreams detailed below.  We will now seek to advise the Minister to implement the FSDM in Wales.

Resources

3.12   There was an increase in the overall reported allocated FTE resource for food hygiene in all three countries since April 2024 and increases in occupied FTE resource in England and Wales, with Northern Ireland reporting a very minor decrease.  In relation to Food Standards, Northern Ireland saw small increases in both their allocated and occupied FTE from April 2024, whilst Wales saw a minor increase in allocated resource but a minor decrease in occupied resource – these changes were all relatively minor and levels remain stable.  England, however, evidenced an increase into April 2024 which has since fallen in 2025 to figures approaching those reported in 2024.  However, this remains well below levels of resource from 10 years ago and limits the system’s ability to recover at the pace we would expect.  The variations in each country can be seen in tables 4 and 5.

3.13   The Board asked us to develop a tool to help LAs determine the resource they need to deliver their services in accordance with the relevant Code of Practice.  A hygiene resource tool has already been built and has been through User Acceptance Testing – LA feedback was very positive.  The tool has been validated by LAs, who will be the primary users, and we plan to roll this out to LAs after the summer, giving them the option of using it as part of their 2026/27 service plan.

3.14   We will now move to working with LAs to undertake time and motion studies for food standards and feed delivery that will allow us to build a similar tool for these services and for unitary services (where services deliver hygiene and standards in parallel).  The timelines for delivery of this will be dependent on capacity in local authorities to undertake this work and the complexity of a combined model.

3.15   We have continued to work with our partners on the qualifications required to undertake roles in this sector.  A new governance procedure has been developed that covers how we consider new and existing qualifications to ensure they are and remain fit for purpose.  We plan to test the procedure with a new food qualification that is currently being developed by the Chartered Trading Standards Institute before we formally launch it.  Given the broader resourcing challenges, it will likely take several years and additional interventions and funding before sufficient additional capacity is in place to enable LAs to fully comply with the Food Law Code of Practice, particularly in relation to food standards official controls.   

Feed Delivery and Data

3.16   In England and Wales, feed official controls are delivered by LAs.  This is funded directly by the FSA in England and through a ring-fenced budget in Wales.  Delivery is co-ordinated by National Trading Standards in England and by the FSA in Wales through the Feed Governance Group in Wales.

3.17   Table 6 in Annex 3 provides the number of establishments with planned and completed official controls in England and Wales over the last three years.  The planned programme takes account of the formal arrangements for earned recognition allowed for in the Feed Law Code of Practice.

3.18   In 2024-25, English and Welsh LAs fully delivered the planned level of interventions.  In addition to this, LAs also increased both the number of samples taken, and the number of consignments of imported feed checked under the programme.

Complaints data, Enforcement Actions and Sampling

3.19   LAs reported a minor increase of 316 complaints received (0.5%) to 61,235 in 2024/25 in relation to food hygiene establishments, compared to an increase of 627 for food standards (5.6%).  Similarly, the number of formal enforcement actions reported for food hygiene in 2024/25 was 6,199, a 5% increase on the previous year.  Though not directly comparable, food standards also recorded a 3% increase on the previous year.  This represents an increase on pre-pandemic levels of 30% and 48%, respectively.  These two data sets and the anecdotal information from LAs on reduction in compliance requiring more enforcement activity, often at perceived lower risk establishments, reenforces the importance of all inspections being undertaken in protecting consumers.

3.20   Sampling is an integral part of the food safety system and utilised effectively, reduces risk to consumers.  National sampling activity, which began to recover post-pandemic into 2022/23, has since fallen for two consecutive years by 6% in 2023/24 and a further 9% in 2024/25.  This is largely influenced by England, where between 2023/24 and 2024/25 saw a 14% decrease in sampling volumes, compared to a minor 2% decrease in Wales.  Northern Ireland recorded a 4% increase.  65 LAs recorded taking 0 hygiene samples (all in England), and 58 recorded taking 0 standards samples (56 in England, 2 in Wales).  With numerous LAs reporting a lack of sampling budget and insufficient resources to take samples as the cause and viewed alongside the broader demands on LAs described above, the reduction in sampling activity highlights a system under significant strain.

4. Reforms being introduced by FSA

4.1      The FSA continues to make improvements to help address the challenges faced by local authorities.  As described above, the new FSDM is being implemented.  We also published a consultation in February 2025 on proposed amendments to the Food Law Code of Practice and Practice Guidance relating to the Food Hygiene Delivery Model.  The proposed changes mean that local authorities will be able to identify the highest risk premises at the point of registration and target their resources accordingly.  They will also have increased flexibility where possible at lower risk premises to use a wider range of checks and balances based on local knowledge.  We have also formally recognised new food standards qualifications which, if used by local authorities, may contribute to tackling the resourcing challenge that we have previously reported.  Following the collation of responses, a summary report has been published and final amendments to the Code and Practice Guidance are being developed at present.  Advice will be provided to the Ministers across the 3 countries following the review of responses for each proposal, including the proposal to introduce the FSDM in Wales.

4.2      We have launched a new workstream to explore an enhanced system of registration as requested by the Welsh Minister in the Collaborative Agreement.  Whilst we are leading this work, we are reliant on the support of our key partners in Welsh Government, the Welsh Local Government Association and Directors of Public Protection Wales.  As a first step, we are working with pilot local authorities to collect information that will provide evidence on whether there is a need to strengthen the registration process.  We will provide regular updates to the Board ahead of sharing final recommendations to the Welsh Minister in the Spring.  

5. Feedback from LAs

5.1      Throughout May, June, and July, a series of face-to-face and online engagement events were held with LAs to communicate and consult on key policy areas and update on current workstreams.  These events were highly successful, reaching 381 officers in total (up from 271 in 2024) and receiving very positive feedback, with the majority of participants stating they were satisfied or very satisfied with the content presented.  The key themes for the events were:

• Cost recovery – Continued support for us to explore cost recovery in England, with the recognition that each of the policy options are complex and nuanced.

• Competency Framework – support received for the revisions we have proposed to the competency framework and assessment procedure, including renaming it as a competency standard.  

5.2      Resourcing tool - continued support for the rollout of the optional tool for LAs to use when resource and service planning.  Hygiene tool will be launched in autumn with standards, dual service (hygiene and standards) and feed programmed in for development in 2026.

5.3      LA training update – for England, insights provided on the current live training programme and LAs given an opportunity to input on future training needs.  Wales and Northern Ireland have their own training programmes.

• Data collection project – update on the method and proposed frequency of data collection to eventually replace the current manual process was shared.  Initial concern on quarterly data collection and the burden of the process was raised, which will need to balance against the Board’s request for more timely data when setting an upload frequency when the service goes live.

5.4      KPI reporting – a workshop was held with LAs asking for feedback on the FSA proposal to report publicly on individual LA performance.  Concerns in the quality of data, cost to publish, and whether there is public interest in the information were consistent themes that will need to be considered before any decisions are taken.

5.5      We value the attendance at the events, and we have written to LAs providing responses to their feedback and any questions raised, reassuring them it will be considered in the next stages of each workstream.

6. Update on performance monitoring of local authorities

6.1      Targeted performance management interventions have not only driven service improvement but also enabled strategic workforce investment and capacity building.  Currently, there are 94 open engagements with authorities (across England and Wales) who are either in the process of giving an assurance that they are delivering in accordance with the Code or have plans in place to do so and are being monitored to ensure proposed improvements are delivered.  There are 8 cases in escalation (7 England and 1 Wales), the most common reason for escalation being a lack of assurance that the LA has robust plans in place to realign with the Code.  A key contributing factor as previously reported to the Board, is a limited pipeline of people coming into the food safety profession and a significant reduction in competent and qualified staff to recruit and train new officers.  It should be noted that this is not solely due to financial pressures but also due to challenges with existing training routes and a lack of visibility of the profession as a career option.

6.2      The Performance Management approach has secured improvements in service delivery and led to the closure of 198 cases since July 2023 where there is a strong level of assurance that they have or will realign to delivering in accordance with the Code.  A LA’s performance can fluctuate, sometimes due to factors beyond their control (incidents, staff changes etc.) which can lead to closed cases being re-opened when the biannual returns are analysed.  Several consistent themes across England and Wales have emerged in how LAs are responding to the challenges of delivering official controls (which inform our future engagements) including:

• Commitment to workforce expansion.

• A greater commitment to explore and adopt the flexibilities available with the Code of practice.

• Maximising existing capability, utilising skills and expertise of existing officers enabling them to undertake a broader range of official control activities.

6.3      Analysis across 61 LAs in England where performance improvements have been secured demonstrates a tangible commitment to workforce development and service sustainability.  Key outcomes include:

• Recruitment of 89 FTE staff, comprising fully competent or qualified professionals, trainees, and apprentices.  These roles have been supported through:

  • Additional funding secured by the authorities.

  • Posts previously at risk of removal being retained and actively recruited to.

• · Engagement of 30 additional FTE contractors, primarily to:

  • Address service backlogs accumulated during the COVID-19 pandemic.

  • Support the long-term sustainability and resilience of service delivery.

7. Conclusions

7.1      The data show that LAs have continued to make progress in returning to the requirements of the Code in relation to interventions, having nearly reached pre-pandemic levels for higher risk rated establishments.  Though positive improvement has been seen in lower risk establishments, particularly in food hygiene, levels remain notably below that of pre-pandemic.  We continue to be concerned over high volume of unrated establishments and how long it could take LAs to get back on track.  That said, FHRS data gives us some assurance that food hygiene standards remain high and that the challenges on interventions have not led to a deterioration in business compliance overall.  We do not have national data on which to draw corresponding conclusions for food standards.

7.2      The deterioration in the level of sampling is a further symptom of the financial strain that the system is under.  Sampling plays a key role in enforcement, as well as contributing to the wider understanding of risks within the system.  We currently have access to only limited sampling data (with the exception of NI), so it remains difficult to determine any impact this may have in the future.

7.3      We need to continue to engage with LAs, professional bodies and other government departments to quantify and map the workforce profile for environmental health and trading standards in food teams.  We need to understand whether there is a tipping point at which a lack of capacity and capability in the system will make the current system undeliverable, and if so, what additional interventions might be required to manage the associated risks.

7.4      Modest increases in available resources do not necessarily equate to a rise in the number of competent and qualified officers available to deliver official controls.  These increases are largely due to the growing trend among LAs to invest in developing their own workforce through traineeships and apprenticeships.  Although this is a welcome and more sustainable long-term strategy, it is funding-dependent and there will be further delays before these new individuals are fully trained and able to make additional contributions to official control delivery.

7.5      Meanwhile, LAs continue to report to us that they are concerned about the loss of expertise and capacity to train new officers and apprentices with people leaving the profession at retirement age or due to workload pressures.  They simultaneously report that there is not enough visibility of food safety as a career option and confusion about routes to qualification.

7.6      It is becoming clear that while some progress is being made, the number of food establishments continues to grow, as evidenced by the ongoing rise in new business registrations.

7.7      At the same time, reductions in sampling volumes and the continued shortfall in interventions at lower-risk establishments—compared to pre-pandemic levels—suggest that LAs are still struggling to meet their statutory obligations.  Further interventions are therefore necessary if we are to see a sustainable pipeline for new officers and the official control programme fully delivered.   

7.8      There is a complex interdependency between these issues.  We are considering how we can best sequence and prioritise the work we have discussed with stakeholders to ensure that we are targeting the issues in the system in the right way.  Ultimately, we are seeking to make the system more sustainable in the future.  However, we must acknowledge that the FSA is facing its own resourcing pressures, and we need to be realistic in our planning around this.  We are in the process of assessing where our resources can have the biggest impact on these challenges in the system and will return to the Board when we are able to provide an update.

7.9      The Board is asked to:

• Consider LA performance in the delivery of official food and feed controls in the past year.

• Note the update on the rollout of the FSDM. 

Annex 1

Charts 1 to 5: Food hygiene

Chart 1: Percentage of food hygiene A-rated interventions carried out April 2020 to April 2025

Chart 2: Percentage of food hygiene B-rated interventions carried out April 2020 to April 2025

Chart 3: Percentage of food hygiene C-rated interventions carried out April 2020 to April 2025

Chart 4: Percentage of food hygiene D-rated interventions carried out April 2020 to April 2025

Chart 5: Percentage of food hygiene E-rated interventions carried out April 2020 to April 2025

Charts 6 to 8: Food standards*

* 12 local authorities were exempt from submitting their food standards returns due to having transitioned to the FSDM prior to the 31 March 2025

Chart 6: Percentage of food standards A-rated interventions carried out April 2020 to April 2025

Chart 7: Percentage of food standards B-rated interventions carried out April 2020 to April 2025

Chart 8: Percentage of food standards C-rated interventions carried out April 2020 to April 2025

Table 1: Due food hygiene interventions outstanding at the end of the reporting period

 

April 2020	A	B	C	D	E	Total
England	62	1,075	6,463	17,055	17,581	42,236
Wales	2	41	804	764	728	2,339
Northern Ireland	1	17	373	685	730	1,806
Total	65	1,133	7,640	18,504	19,039	46,381
Total A to C	65	1133	7640			8,838
April 2023	A	B	C	D*	E*	Total
England	17	191	5,523
Wales	1	3	2,254
Northern Ireland	0	6	74
Total A to C	18	200	7,851			8,069
April 2024	A	B	C	D	E	Total
England	15	212	4,723	31,210	54,635	90,795
Wales	1	3	343	1,720	4,929	6,996
Northern Ireland	0	0	127	997	1,969	3,093
Total	16	215	5,193	33,927	61,533	100,884
Total A to C	16	215	5,193			5,424
April 2025	A	B	C	D	E	Total
England	16	322	4,506	20,767	40,313	92,867
Wales	0	5	467	1,085	3,870	5,427
Northern Ireland	0	3	82	863	919	1,867
Total	16	330	5,055	22,715	45,102	73,128
Total A to C	16	330	5,055			5,401

 

*There was no expectation for interventions to be carried out at all D and E-rated establishments in the COVID Recovery Plan.  Data was not collected.

Table 2: Due food standards interventions outstanding at the end of the reporting period

 

April 2020	A	B	C	Total
England	911	68,976	62,814	132,701
Wales	35	2265	2055	4355
Northern Ireland	13	203	1435	1651
Total	959	71,444	66,304	138,707
Total A	959			959
April 2023	A	B*	C*	Total
England	542			542
Wales	6			6
Northern Ireland	0			0
Total A	548			548
April 2024	A	B*	C*
England	288	59,121	71,398	130,807
Wales	11	2,986	3,791	6,788
Northern Ireland	0	139	1,040	1179
Total	299	62,246	76,229	138,774
Total A	299			299
April 2025	A	B	C
England	127	55,025	65,103	120,255
Wales	7	2,065	3,492	5,564
Northern Ireland	3	149	833	985
Total	137	57,239	69,428	126,804
Total A	137			137

 

*There was no expectation for interventions to be carried out at all B and C-rated establishments in the COVID Recovery Plan.  Data was not collected.

Table 3: The number of unrated registrations in each country (food hygiene data)

 

	England	Wales	NI	Total
Apr-20	29,021	1,388	559	30,968
Apr-21	70,635	5,102	1,299	77,036
Apr-22	47,068	3,308	737	51,113
Jul-22	45,406	2,902	549	48,857
Oct-22	40,344	2,602	459	43,405
Jan-23	36,732	2,295	505	39,532
Apr-23	36,595	2,352	510	39,454
Oct-23	39,070	2,263	679	42,012
Apr-24	39,007	1,746	430	41,183
Oct-24	40,162	1,880	412	42,454
Apr-25	36,690	1,765	297	38,752

 

Chart 9: Percentage of FHRS ratings 3 or above for each country from March 2020 to now

Chart 10: Percentage of FHRS ratings 5 for each country from March 2020 to now

Annex 2

Chart 11: Food hygiene FTE professional posts occupied and available to undertake official food controls April 2020 to April 2025

Chart 12: Food standards FTE professional posts occupied and available to undertake official food controls April 2020 to April 2025*

* 12 local authorities were exempt from submitting their food standards returns due to having transitioned to the FSDM prior to the 31 March 2025

Table 4: FTE Resources April 2024 and 2025 for three countries: Food hygiene 

 

	Country	FTE Allocated	FTE Occupied and available
April 2024	England	1,396	1,258
	Wales	163	142
	Northern Ireland	64	59
	Total	1,623	1,459
April 2025	England	1,429	1,288
	Wales	164	152
	Northern Ireland	65	57
	Total	1,658	1,497

 

Table 5: FTE Resources April 2024 and 2025 for three countries: Food standards*

 

	Country	FTE Allocated	FTE Occupied and available
April 2024	England	348	304
	Wales	68	64
	Northern Ireland	29	27
	Total	446	394
April 2025	England	300	273
	Wales	69	62
	Northern Ireland	32	29
	Total	402	365

* 12 local authorities were exempt from submitting their food standards returns due to having transitioned to the FSDM prior to the 31 March 2025

Annex 3

Table 6: Planned and Completed Feed Official Controls in England and Wales

England & Wales Planned & Completed Official Controls

*establishment types broadly listed in descending order of inherent risk

NB. Where more controls have been completed than planned, this can be the result of varying factors, such as the identification and inspection of new businesses and those that have ceased trading being recorded as such