Food fraud and food defence: A guide to PAS 96:2026 key changes
28 May 2026 | Richard Leathers, Global Quality Lead, and Louise Harris, Safety and Quality Specialist
Food fraud and other forms of attack are significant threats to any food or drink business operator, with many associated food safety risks. Even when the issue is not one of safety, fraud such as misrepresentation or substitution can have huge reputational and financial costs for implicated businesses and brands.
Staying up to date on the latest guidance and best practice will help to protect your business, brands and consumers. That’s why we have summarised the key changes in the new 2026 version of PAS 96 (‘Food defence – Protection and prevention from deliberate acts – Guide’) here for our members and clients.
The original 2017 version of PAS 96 was reviewed starting in 2024, and the draft new version underwent public consultation in December 2025 / January 2026. The final new version – PAS 96:2026 – has just been issued, with significant input from Campden BRI.
As members of the Steering Group for this review and update of PAS 96, we are well placed to summarise the key changes as well as to support your implementation of this guidance and its latest updates.
Key updates in the new 2026 PAS 96 guidance
- New title (‘Food defence – Protection and prevention from deliberate acts – Guide’)
- Simplified rationale and introduction
- Case study updates:
- Two of the less relevant case studies have been removed to streamline the document, while the remaining case studies and examples have been reviewed, updated and strengthened.
- Simplified information for case study introductions.
- Reordered threats from most likely (cybercrime) to least likely (extortion) and added new case studies for all types of threats
- Revised figure for supply chain and TACCP outline
- The term supply chain seems a huge oversimplification in the food industry, where thousands of ingredients are sourced from multiple suppliers (using agents, traders, brokers, cooperatives, logistics and transport hubs). A chain is linear, strong, stress-resistant and reliable. For this reason, in the updated PAS, the term “chain” is frequently replaced by “network” to better describe the complexity food business operators (FBOs) often face.
- Inclusion of additional guidance on when to review the threat assessment and protective measures
- Additions to the section on “complementary approaches” to food defence
- TACCP alignment:
- Added guidance on the application of TACCP aligned to the TACCP flow diagram.
- "Critical controls" replaced with "Proportionate controls" to align with TACCP terminology.
- Clarification and standardisation of terminology:
- Thorough revision of the technical content to clearly distinguish between risks, threats and vulnerabilities, eliminating any conflicting language throughout the guide.
- Added definitions for attack, protective arrangements, risk & vulnerability.
- Change in language to align with standard food industry terminology, e.g. 'judge' replaced with 'assess', 'Whistleblowing' replaced with 'Confidential reporting system', and food industry terminology tweaked in case studies.
- Updated references throughout the document to replace redundant links and to provide accessible websites for further reading on cited case studies
How we can help you to protect your business
We provide hands on support for businesses who want to better prepare for and address the threat of food fraud, malicious attacks and broader food crime. For just one example, see our case study – An independent food integrity review for 2 Sisters Food Group.
As such, we can help you to implement, validate and verify effective food safety management systems to protect your business.
Download our FREE Beating Food Crime eBook today!
Win the fight against food crime – successfully defend your business against food fraud and malicious attacks.
We help businesses to identify emerging risks and trends through horizon scanning, and provide support with devising and adapting your management systems and monitoring plans based on the changing risk landscape.
As members of the Steering Group for this review and update of PAS 96, we are best placed to support your implementation of this guidance and its latest updates.
Alongside this practical support, we provide a wide range of relevant training and can also analyse your products and materials to test for potential adulteration and other food fraud.
For more on food fraud and food defence, download our ‘Beating Food Crime’ eBook.
About Richard Leathers
Richard Leathers joined Campden BRI in September 2011, and has worked in the food industry for 4 decades.
Richard started working with Dairy Crest and subsequently worked for both Heinz, Unilever, Best Foods and Kanes Foods. Working in the areas of HACCP and Quality Management Systems, Richard also has experience within the fresh produce sector, as well as analysis systems in the milling / baking areas, and is a BRCGS qualified lead auditor.
Richard has contributed to several publications and guidelines, including those for TACCP, VACCP and HACCP / Risk Evaluation and is also trained at advanced level by EHEDG (European Hygienic Engineering Design Group).
We can help with PAS 96 and TACCP / VACCP
For best practice guidance and support with food fraud and food defence, get in touch.
Training: Food defence and food fraud
Get the training you need to successfully defend your business against food fraud and malicious attacks.
