For Quality Managers in food and feed, few roles sit closer to risk than yours. You are accountable to regulators, scrutinised by auditors, relied upon by operations, and expected by leadership to “keep the business safe” often with limited time, data, or internal bandwidth. And even highly mature systems encounter gaps under new regulatory or audit expectations.”
One of the most persistent sources of audit stress is not a lack of effort or expertise. It is confusion around a deceptively simple question:
“What’s the difference between what regulators expect and what auditors actually look for?”
Understanding, and closing, that gap is what separates organisations that merely pass audits from those that are genuinely audit-ready, year-round.
This guide is designed to help you do exactly that.
Why This Distinction Matters More Than Ever
Regulatory scrutiny and certification audits are converging, but they are not the same thing.
Regulators focus on legal compliance, consumer protection, and due diligence.
Auditors assess conformity, system effectiveness, and consistency against a defined standard.
In practice, many organisations assume that compliance with one automatically satisfies the other.
It rarely does.
Certification audits do not replace regulatory oversight, but they increasingly serve as a confidence indicator of system maturity.
As regulatory frameworks grow more complex (spanning food safety, feed safety, chemical controls, origin, sustainability, and claims), auditors are increasingly acting as proxies for regulatory confidence. They look for evidence that your systems are robust enough to withstand regulatory scrutiny at any point, not just during an audit window.
For Quality Managers, this creates a dual responsibility:
- Meet regulatory obligations across markets and products
- Demonstrate those obligations clearly, consistently, and in an auditable way
The gap between those two is where most non-conformities live.
| Regulatory trigger to watch: Increased focus on due diligence, traceability depth, and management accountability means regulators are increasingly interested in how decisions are made: not just whether procedures exist. |
Regulators vs. Auditors: The Practical Difference
Let’s start by demystifying the roles.
What Regulators Expect
While enforcement models differ by jurisdiction, generally regulators are concerned with outcomes and legality. Their primary question is:
“Can you demonstrate that you are meeting the law and protecting public health?”
They typically expect:
- Compliance with applicable legislation (food/feed law, materials, labelling, contaminants, additives, claims)
- Evidence of due diligence and risk-based decision-making
- Traceability and recall capability
- Timely corrective action when issues arise
- Accountability at senior management level
Regulatory inspections are often reactive, triggered by complaints, incidents, intelligence, or market surveillance, and can focus narrowly on a specific risk or product.
Importantly, regulators do not usually require your systems to follow a particular structure. They care less how you manage compliance, and more whether it works.
What Auditors Look For
Auditors, by contrast, are assessing conformity to a defined standard (e.g. BRCGS, FSSC 22000, ISO). Their central question is:
“Can this organisation consistently deliver safe, compliant product using a controlled, repeatable system?”
Auditors look for:
- Clearly defined management systems
- Documented procedures aligned to the standard
- Evidence that procedures are implemented in practice
- Records that demonstrate consistency over time
- Internal verification, review, and improvement
- Alignment between policy, practice, and evidence
Audits are predictable, structured, and comparative (even when unannounced). Findings are benchmarked against clause requirements and scoring frameworks, not solely against legal thresholds.
In short:
Regulators care about compliance and outcomes
Auditors care about control, consistency, and evidence
Both matter but confusing them leads to risk.
The Most Common Gaps Quality Managers Face
Across food and feed businesses, the same gaps appear again and again. They are rarely about intent or effort. They are almost always about translation: turning regulatory compliance into auditable systems.
Below are three of the most common.
| Need clarity before your next audit? A short, confidential conversation with a FoodChain ID expert can help you understand where regulatory expectations and audit requirements may be diverging in your systems, and where that creates real risk. Identifying gaps early often prevents them becoming findings later. Speak with a FoodChain ID expert: https://www.foodchainid.com/contact/ |
Gap 1: “We Are Compliant.” But Can’t Prove It Consistently
Many organisations rely on expert knowledge held by individuals. Regulatory compliance may exist in practice, but it is not always systematised.
Typical symptoms:
- Regulatory checks done ad hoc or in spreadsheets owned by one person
- Decisions justified verbally but not documented
- Supplier assurances accepted without structured verification
- Knowledge gaps when key staff are absent
What auditors see:
Inconsistent records, undocumented rationale, or reliance on “tribal knowledge”.
How to close the gap:
Translate regulatory obligations into controlled, owned processes:
- Maintain a documented regulatory inventory by product and market
- Record decision-making rationale, not just outcomes
- Define ownership and review frequency
- Ensure continuity beyond individuals
Auditors are not questioning your expertise; they are testing whether it is embedded into the system.
Gap 2: Documentation Exists. But Evidence Doesn’t Match Reality
Another common issue is misalignment between documented procedures and actual practice.
Typical symptoms:
- Procedures written for the audit, not for operations
- Records completed retrospectively
- Training documented but behaviours unchanged
- Different practices across sites using the same system
What auditors see:
“Say–do” gaps: where the system looks compliant on paper, but evidence tells a different story.
How to close the gap:
Design documentation to reflect how the business really works, then verify it:
- Simplify procedures to what operators actually do
- Test understanding through observation, not just training records
- Align internal audits to behavioural evidence
- Use corrective actions to improve systems, not just close findings
Auditors are increasingly trained to look beyond paperwork to operational reality.
Gap 3: Traceability Works. Until It’s Tested
Traceability is a regulatory requirement and a certification cornerstone, yet it often fails under pressure.
Typical symptoms:
- Traceability exercises done infrequently or narrowly
- Supplier data incomplete or inconsistent
- Finished product traceability not linked to raw material risk
- Mock recalls that focus on speed, not accuracy
What auditors see:
Traceability that exists in theory, but lacks depth, linkage, or confidence.
How to close the gap:
Strengthen traceability as a risk-based system, not a one-off test:
- Link traceability scope to product and supplier risk
- Verify upstream data quality, not just internal records
- Include reconciliation, not just “can we find it”
- Use outcomes to improve supplier engagement and controls
Effective traceability demonstrates both regulatory compliance and audit maturity.
Where FoodChain ID’s Dual Expertise Makes the Difference
Closing these gaps requires more than checklists. It requires an understanding of how regulation, certification, and operational reality intersect.
This is where FoodChain ID’s model is deliberately different.
Because FoodChain ID operates across certification, regulatory interpretation, and managed compliance, we often see where misalignment occurs long before it appears as a non-conformance.
FoodChain ID operates across three interconnected areas:
- Certification and audit expertise
- Technical training and regulatory interpretation
- Managed compliance and ongoing support
This dual (often triple) perspective allows organisations to move beyond reactive audit preparation and toward predictive compliance readiness.
Rather than asking, “How do we pass the audit?”
The question becomes, “How do we design systems that regulators trust and auditors can clearly verify?”
That shift reduces risk, saves time, and builds confidence across the organisation.
A Practical Framework: From Compliance to Audit Confidence
Quality Managers who navigate audits successfully tend to apply the same underlying principles, regardless of standard or sector.
1. Interpret Regulation Once: Apply It Systematically
Avoid repeating regulatory interpretation site by site or product by product. Centralise understanding, then deploy it consistently through:
- Templates
- Decision trees
- Standardised risk assessments
This reduces inconsistency and audit exposure.
2. Build Evidence into Daily Operations
Evidence should be a by-product of doing the job, not an audit-week scramble.
- Integrate checks into normal workflows
- Use existing operational data where possible
- Avoid duplicate records created “just for audit”
Auditors recognise mature systems when evidence flows naturally.
3. Treat Audits as Verification, Not Validation
An audit should confirm system effectiveness; not be the only time it is tested.
- Use internal audits to challenge assumptions
- Review trends, not just individual findings
- Involve senior management meaningfully
This aligns closely with both regulatory expectations and certification principles.
What rarely works is adding more procedures, more forms, or more training without addressing how decisions are made and reinforced day-to-day.
Real-World Example: Closing the Gap in Practice
Composite example based on multiple client engagements.
A multi-site food manufacturer believed it had strong regulatory controls. All sites used the same procedures and training materials.
Audit outcomes told a different story.
Findings revealed:
- Inconsistent supplier approval decisions
- Variable confidence in regulatory interpretation at site level
- Uneven documentation of risk assessments
The issue was not knowledge: it was system translation.
By restructuring regulatory requirements into a single, controlled framework, supported by targeted training, clearer expectations, and consistent evidence standards, the organisation reduced variation in how regulatory decisions were made at site level.
Importantly, this was reinforced through a positive culture, embedding accountability and confidence. This ensured regulatory expectations were interpreted consistently, supervisory behaviours were aligned, and evidence was generated through everyday practices rather than individual judgement.
As a result, audit outcomes became more consistent across sites, repeat findings reduced, and management gained clearer visibility of where regulatory and operational risk genuinely sat.
Most importantly, Quality Managers regained time and clarity.
What “Good” Looks Like to Auditors (and Regulators)
When systems are working well, auditors typically observe:
- Clear linkage between regulatory obligations and procedures
- Confident explanations from staff, not rehearsed answers
- Records that show learning and improvement over time
- Management review that addresses real risks, not just KPIs
Regulators, in turn, see:
- Demonstrable due diligence
- Clear accountability
- Faster, more credible responses when issues arise
Both outcomes stem from the same foundation: well-designed, well-owned systems.
| Best Practice Checklist Before your next audit or regulatory review, it’s worth stepping back and asking: Have we clearly mapped our regulatory obligations to specific products, markets, and suppliers? Can we show how those mappings are kept up to date? When regulatory or quality decisions are made, do we consistently document the rationale behind them, not just the final outcome or approval? Is compliance evidence generated naturally through day-to-day operations, or are records often completed retrospectively in preparation for audit? Do our internal audits test how well people understand and apply requirements in practice, rather than focusing solely on whether documents exist? Does management review focus on trends, emerging risks, and system effectiveness or is it primarily a review of KPIs and past performance? |
Final Thought: From Survival to Strategic Advantage
For Quality Managers, audits should not feel like survival exercises. When regulatory expectations and auditor requirements are properly aligned, audits become confirmation, not confrontation.
The most resilient organisations are those that:
- Understand the difference between compliance and conformity
- Design systems that satisfy both
- Use expert support where complexity or scale demands it
FoodChain ID works with Quality leaders to simplify that complexity, without losing credibility, through certification expertise, technical training, and managed compliance support. For many Quality Managers, the challenge is not knowing what good looks like; it is having the time, tools, and support to implement it consistently across sites and suppliers.
Are You Confident Your Systems Will Stand Up to Both Regulators and Auditors?
When regulatory expectations and audit requirements are properly aligned, audits become confirmation, not confrontation.
When that alignment breaks down, gaps surface as findings, stress increases, and confidence erodes.
If you want an objective view of how your systems perform against both regulatory expectations and audit scrutiny, FoodChain ID can help.
A short, confidential conversation with our experts can help you:
- Identify where regulatory compliance may not yet be fully auditable
- Clarify which gaps represent real risk versus low-impact noise
- Strengthen evidence, traceability, and accountability before your next audit or inspection
Speak with a FoodChain ID expert about preparing your systems for regulatory and audit confidence. https://www.foodchainid.com/contact/