The requirement that applies today
Top management makes sure the system is continually updated. The food safety team evaluates the system at planned intervals and considers whether the hazard analysis, the hazard control plan and the PRPs need review. The updating is based on internal and external communication, other information about the system's suitability, adequacy and effectiveness, the analysis of verification results, and the output of management review. The updating activities are recorded and reported as input to the review.
ISO 22000:2018, 10.3 Update of the food safety management system; ISO/DIS 22000:2026, 10.4 Update of the food safety management system.
What the draft does
Renumbered from 10.3 to 10.4: The public contents show update of the system at 10.4, where the current edition has it at 10.3. The wording appears to be retained, which is an inference from the contents because the draft text is sold by ISO and not held here.
Source: public contents and foreword at 10.4, retrieved 2026-10-19.
Why this clause matters
This is the clause that makes a management system a living thing rather than a certificate. It is also the clause that governs adopting the revision: the update is planned, evaluated and recorded. The draft moves it from 10.3 to 10.4, so the numbering in current procedures will be out of date.
Suggested evidence to discuss with your auditor
For 10.4, these are the artefacts we suggest discussing with your auditor. The standard publishes no evidence list, so this is our reading, not a requirement.
- A scheduled evaluation of the system with the inputs listed in the clause
- A record of what was updated and why
- Evidence that the update was reported to the review
- A customer notice or communication when the certificate or scope changes
Where systems usually fall short
- The system reviewed only when an audit is due
- Updates made without a record of the decision
How to prepare
Put a system update on the calendar for the transition, with the inputs listed in the clause. Treat it as the formal adoption step: what changed, what was re-analysed, what was re-approved and when it takes effect.
Dates
Cross-references
Source
Clause 10.4. Current edition: ISO 22000:2018. Draft: ISO/DIS 22000:2026. Retrieved 2026-10-19. The full DIS text for 10.4 is sold by ISO and not held here; the sources page lists what is.
Not legal advice; does not certify; our words, not the standard's, and the planning date is an estimate.