Last Updated on December 1, 2025 by Melissa Lazaro

Why Internal Audits Matter During the Move to BRC V9

When teams begin preparing for BRC V9, many focus heavily on updating documents — policies, procedures, training forms, and checklists. That work matters, but it’s only one side of the transition. The real question is: Is the updated system being followed consistently on the floor?

Internal audits are where you find that answer.

In my experience working with companies through transitions, the sites that prioritize internal audits early avoid last-minute surprises, rushed fixes, and stressful pre-audit pressure. The ones that treat it as a “final step” usually spend the weeks before certification scrambling.

By the end of this guide, you’ll know how internal audits should shift under BRC V9, what needs reviewing, and how to structure your audit process so it’s practical, evidence-driven, and aligned with certification expectations.

Reframing Internal Audits for V9: What Changes and Why It Matters

Internal auditing under BRC V9 isn’t just checking whether documents exist — it’s confirming whether the intent of the requirements is being met in practice. The standard places stronger expectations on:

• Verification instead of assumption
• Evidence instead of narrative
• Trend analysis instead of isolated results
• Competence instead of just training attendance

One of the biggest mistakes I’ve seen during V8 to V9 transitions is using outdated audit checklists. The result? Teams miss key areas like cybersecurity, culture metrics, or updated allergen controls — and only realize it during the external audit.

Pro Tip

Update the audit framework early, even if not all documents are finalized yet. An evolving checklist is better than an outdated one.

Updated Scope and Audit Criteria Aligned with BRC V9 Requirements

As you update your audit program, your scope should reflect the new and strengthened clauses in V9. That means reviewing:

• Food safety culture evidence (measurable actions, not just a policy)
• Allergen labelling accuracy and verification
• Cybersecurity vulnerabilities and data protection
• Food defence and fraud mitigation evidence
• Traceability maturity and justification statements

A client example: their allergen procedure was updated on paper, but operators were still following the old visual cues for label checks. Internal audit caught it — not the certification auditor.

That’s exactly what internal audits are meant to do.

Building the Audit Plan for the Transition Period

Instead of waiting until everything is updated, build a phased audit plan tied to transition readiness. A risk-based schedule works best.

Prioritize audits for:

1. High-risk processes (allergens, foreign body controls, CCP monitoring)
2. New requirements (cybersecurity, culture, TACCP/VACCP updates)
3. Areas that historically generate non-conformities

Schedule follow-up audits for high-risk gaps and areas undergoing change.

Pro Tip

Audit any newly updated procedure within 30–60 days to verify implementation — not just documentation.

Common Pitfall

Conducting one large internal audit right before certification and missing development and follow-up time.

Developing New or Updated Internal Audit Checklists

Your checklist should reflect the intent behind requirements — not just clause wording. That means moving away from yes/no questions and toward:

• Observation prompts
• Implementation checks
• Competency verification
• Traceability proof points
• Evidence justification

Example shift:

Old Audit Question	V9 Improvement
“Is allergen cleaning documented?”	“Show evidence of allergen cleaning validation, review dates, and trending.”

Auditors will expect depth — not superficial compliance.

Conducting Internal Audits: Practical Techniques for V9 Alignment

Internal audits during the transition should feel more like mini certification audits. That means using:

• Document review
• Interviews
• Floor verification
• Traceability walkthroughs
• Process challenges

Focus on consistency and capability — not just paperwork.

A recent site audit I supported revealed something familiar: the documentation was excellent, but operators used outdated packaging verification steps because no one updated their work instructions. The internal audit caught the issue early — and fixing it prevented an external non-conformity.

Managing Audit Findings and Corrective Actions During Transition

Not all findings carry the same weight. Prioritize based on food safety risk, compliance level, and operational complexity.

Each corrective action should include:

• Root cause analysis
• Action plan
• Owner
• Implementation timeline
• Verification method
• Evidence of effectiveness

Avoid the trap of “fixing the form.” Fix the system.

Verification and Follow-Up Before Certification

Follow-up is where most transition plans fall short. If actions don’t have closure — they don’t count.

Before your external audit, confirm:

• Findings are closed
• Evidence is verified
• Changes are implemented — not just written
• Training and competency records match updated processes
• A final internal verification audit was completed

Ideally, this happens 8–12 weeks before certification, not days before.

Template & Toolkit Checklist: What You Should Have in Place

Before closing the transition audit cycle, ensure you have:

• Updated internal audit schedule
• V9-aligned checklists
• Competency evidence for internal auditors
• Corrective action tracking and verification
• Audit reports with objective evidence
• A final readiness or pre-audit assessment

This forms your internal audit evidence pack — auditors will appreciate it.

FAQs

1. Do we need to audit the full system again for V9?
Yes — but priority and timing should follow risk and implementation status.

2. Can we reuse our V8 checklists?
Only if updated — unchanged V8 checklists will miss key areas.

3. Who should perform transition internal audits?
Competent internal auditors or trained external support — cross-functional involvement strengthens results.

Conclusion: Internal Audits Are Your Best Transition Safety Net

Internal audits give you clarity. They confirm whether your updated system works as intended and whether your team is truly prepared for V9 expectations — not just on paper, but in real operations.

If you’re moving into implementation now, the next logical step is building or updating your internal audit schedule and checklists — and planning verification follow-ups before certification.