A public consultation on the proposed revisions to the MSC Chain of Custody Standard was held between 31 March and 13 June 2026.
Next steps
All feedback from the consultation will be reviewed and will help us to understand where our proposals are effective, and where further refinement is required.
Feedback will be considered alongside insights from mock audits. These audits are used to understand the cumulative impact of the proposed revisions on the audit process, and to assess how feasible the proposals are for certificate holders to implement.
A report summarising the consultation feedback will be published later in 2026.
Publishing the revised Standard
The Chain of Custody Review is due to be completed in 2027.
- Early 2027 – Revised Standard and other program documents published
- Late 2027 - Revised Standard in effect 6 months after publication
Any revised program documents will be effective six months after they have been released. Existing certificate holders will be required to transition to the updated requirements once they are in effect.
Proposed revisions developed
The consultation focused on proposed changes to the MSC Chain of Custody Standard and Certification Requirements. The proposals include clarifications to requirements and processes to ensure audits are more consistent and to improve usability for auditors and certificate holders. Proposals were developed to strengthen traceability and assurance, while helping certificate holders demonstrate compliance with evolving traceability regulations.
Key revisions proposed include:
- A restructured, single version of the Standard: The three current models of the Chain of Custody Standard (Default, Group and Consumer Facing (CFO)) have been combined into one single document. This intends to resolve inconsistencies between the models and make the Standard clearer for certificate holders and auditors.
- Certificate holders to demonstrate they can access ‘key data elements’: A new requirement to strengthen traceability across the supply chain. Certificate holders would be required to demonstrate to auditors that they can access traceability data (key data elements – KDEs), corresponding to their position in the supply chain.
- Regular internal traceback exercises: A new requirement for certificate holders to complete one internal traceback exercise, using a template provided by MSC, between each audit. This is intended to help businesses strengthen their traceability systems e.g. ensuring there are no gaps in the record-keeping process and help them demonstrate compliance with regulatory and market traceability requirements.
- Modified and standardised risk-assessments: The MSC-defined risk assessment criteria have been revised to align with best practice and established risk factors, and the risk categories have been simplified to low, medium and high.
The revised risk assessment is now to be completed by auditors for all organisations – previously only required for the Group and CFO model. These changes aim to clarify the audit process for certificate holders, help prioritise assurance
activities, such as unannounced audits and DNA testing, and provide better oversight of risk across the entire Chain of Custody certification program.
Key documents
You can read a full summary of the proposals and view the draft revised Chain of Custody Standard and Certification Requirements below.
Please note these proposals are subject to change following feedback from the consultation and further testing.
- Summary of Proposed Changes
- Draft MSC Chain of Custody Standard
- Standard mapping tool (Comparison between existing Standard and proposed revisions)
- Draft Chain of Custody Certification Requirements
- Certification Requirements mapping tool (Comparison between existing Certification Requirements and proposed revisions)
Watch our webinar
Our recent webinar explains the proposed changes to the Standard, with a focus on the structural changes, traceability and program assurance.
Contact us
If you have any questions, please contact [email protected] or your regional MSC representative.
