What is the primary objective of FSSC 22000?

**FSSC 22000 aims to certify Food Safety Management Systems (FSMS) ensuring safe food across the supply chain.** It combines **ISO 22000:2018**, sector-specific **PRPs**, and **Additional Requirements** for consistent, auditable food safety via GFSI-benchmarked certification, supporting global trade and reducing duplication.

Who is legally or professionally required to comply with FSSC 22000?

**No organizations are legally required to comply with FSSC 22000, as it is a voluntary certification scheme.** Professionally, food chain entities in categories B-K (manufacturing, packaging, logistics) pursue it for **GFSI recognition**, retailer mandates, and export market access, with 40,000+ certified sites worldwide.

Does FSSC 22000 require an external audit or third-party certification?

**Yes, FSSC 22000 mandates external audits by licensed Certification Bodies (CBs) for certification.** Includes Stage 1 (documentation) and Stage 2 (implementation), with minimum 2-day audits, 50% operational focus, annual surveillance, and recertification every 3 years per **ISO 22003-1:2022**.

How often should an assessment for FSSC 22000 be performed?

**FSSC 22000 requires annual internal audits and management reviews, plus CB surveillance audits yearly.** Recertification occurs every 3 years; unannounced audits possible. Organizations must notify CBs within **3 working days** of serious events impacting FSMS.

What are the consequences of non-compliance with FSSC 22000?

**Non-compliance with FSSC 22000 results in certification suspension, withdrawal, or market exclusion.** CBs issue nonconformities with closure timelines; repeated failures lead to lost **GFSI status**, supply chain de-listing, recalls, and reputational damage without legal fines.

Can FSSC 22000 be mapped to other international frameworks?

**Yes, FSSC 22000 integrates seamlessly with ISO management systems due to its harmonized structure.** Its **PDCA cycle**, leadership, and operational clauses align with broader systems, enabling shared processes for audits, documentation, and continual improvement.

What is the first step to begin implementing FSSC 22000?

**The first step is conducting a gap analysis against ISO 22000, relevant PRPs, and FSSC Additional Requirements.** Follow with scope definition per **ISO 22003-1 categories**, executive sponsorship meeting, and project planning to identify PRP needs and category alignment.

What is the primary objective of 23 NYCRR 500?

**23 NYCRR 500 aims to protect nonpublic information and ensure operational integrity for New York financial services entities.** It establishes minimum risk-based cybersecurity requirements for Covered Entities, including banks, insurers, and licensees, through a documented program addressing governance, risk assessments, technical controls, and incident response to safeguard against cyber threats.

Who is legally or professionally required to comply with 23 NYCRR 500?

**23 NYCRR 500 applies to all Covered Entities licensed or operating under New York Banking, Insurance, or Financial Services Law.** This includes state-chartered banks, insurers, mortgage brokers, virtual currency licensees, HMOs, and New York branches of foreign banks handling nonpublic information; limited exemptions exist for small entities meeting revenue/employee thresholds.

Does 23 NYCRR 500 require an external audit or third-party certification?

**23 NYCRR 500 mandates independent audits only for Class A Companies based on revenue and employee thresholds.** Class A entities (e.g., >$20M NY revenue and >2,000 employees or >$1B global revenue) require enhanced controls like independent audits; others rely on internal evidence for annual certification and NYDFS examinations, with no universal third-party certification.

How often should an assessment for 23 NYCRR 500 be performed?

**Risk assessments under 23 NYCRR 500 must be conducted annually and updated upon material changes.** Section 500.9 requires periodic documented assessments of threats, vulnerabilities, and controls, integrated with enterprise risk management, to inform program design, with continuous updates for events like M&A or TPSP changes.

What are the consequences of non-compliance with 23 NYCRR 500?

**Non-compliance with 23 NYCRR 500 results in multimillion-dollar fines, consent orders, and remedial programs.** NYDFS has issued penalties like $30M to Robinhood Crypto and $4.25M to OneMain Financial for governance failures, TPSP oversight lapses, and technical deficiencies, plus reputational damage and operational mandates.

Can 23 NYCRR 500 be mapped to other international frameworks?

**Yes, 23 NYCRR 500 aligns well with frameworks like NIST CSF and CRI Profile.** NYDFS guidance accepts NIST or equivalent methodologies for risk assessments, penetration testing, and controls, enabling integrated compliance with shared elements like governance, MFA, encryption, and incident response.

What is the first step to begin implementing 23 NYCRR 500?

**The first step for 23 NYCRR 500 implementation is determining Covered Entity status and appointing a qualified CISO.** Use NYDFS flowcharts for exemptions, then conduct a targeted risk assessment on critical assets and TPSPs, followed by building an evidence repository for annual certification.

FSSC 22000 vs 23 NYCRR 500

Standards Comparison

FSSC 22000

Voluntary

2023

GFSI-benchmarked scheme for food safety management systems

23 NYCRR 500

Mandatory

2017

NY regulation for financial services cybersecurity compliance

Quick Verdict

FSSC 22000 delivers GFSI-recognized food safety certification for global supply chains, while 23 NYCRR 500 mandates cybersecurity controls for NY financial firms. Food companies pursue market access; financial entities avoid multimillion fines.

Food Safety

FSSC 22000

Food Safety System Certification 22000 Version 6

Cost

€€€€

Complexity

High

Implementation Time

6-12 months

Key Features

GFSI-benchmarked FSMS certification scheme
Integrates ISO 22000 with sector PRPs
Mandates food defense and fraud mitigation
Requires allergen validation and environmental monitoring
Dynamic updates via BoS decisions

Financial Services

23 NYCRR 500

23 NYCRR Part 500 Cybersecurity Regulation

Cost

€€€€

Complexity

High

Implementation Time

18-24 months

Key Features

Annual CEO/CISO dual compliance certification
72-hour cybersecurity incident notification to NYDFS
Phishing-resistant MFA for privileged and remote access
Comprehensive third-party service provider oversight
Risk-based annual penetration testing requirements

Detailed Analysis

A comprehensive look at the specific requirements, scope, and impact of each standard.

FSSC 22000 Details

What It Is

FSSC 22000 (Food Safety System Certification 22000 Version 6) is a GFSI-benchmarked certification scheme for Food Safety Management Systems (FSMS). It applies across food chain categories like manufacturing, packaging, and logistics. The primary purpose is to ensure safe food provision through independent third-party audits, using a PDCA-based risk management approach anchored in ISO 22000:2018.

Key Components

**Three pillarsISO 22000:2018 clauses 4-10, sector-specific PRPs (e.g., ISO/TS 22002 series), FSSC Additional Requirements (17 items covering defense, fraud, allergens).
Over 100 requirements integrated into auditable framework.
Built on HACCP principles with PRPs, OPRPs, CCPs.
Certification via licensed Certification Bodies (CBs) per ISO 22003-1:2022.

Why Organizations Use It

Provides market access to global buyers, reduces audit duplication, enhances supply chain trust. Drives risk reduction in adulteration, contamination. Builds stakeholder confidence via public register of 40,000+ certified sites.

Implementation Overview

Phased approach: gap analysis, FSMS design, PRP/HACCP rollout, internal audits, CB certification (Stage 1/2 audits). Suits all sizes in food chain; 6-24 months typical, with annual surveillance.

23 NYCRR 500 Details

What It Is

23 NYCRR Part 500 is the New York Department of Financial Services (NYDFS) Cybersecurity Regulation, a mandatory state regulation for financial services entities in New York. Its primary purpose is to protect nonpublic information (NPI) and ensure operational integrity via a risk-based cybersecurity program with prescriptive controls.

Key Components

14 core requirements including cybersecurity program, policy, CISO governance, MFA, encryption, access privileges, asset management, TPSP oversight, penetration testing, incident response, and 72-hour reporting.
Built on risk assessment foundation; annual CEO/CISO certification; five-year record retention.
Class A Companies (high revenue/employees) face enhanced audits and controls.

Why Organizations Use It

Mandatory for NY-licensed financial entities to avoid multimillion-dollar fines and consent orders.
Enhances resilience, reduces incident risk, builds stakeholder trust.
Provides competitive edge through robust governance and vendor management.

Implementation Overview

Phased roadmap: gap analysis, risk assessment, asset inventory, MFA rollout, TPSP contracts.
Applies to banks, insurers, licensees in NY; tailored by size/complexity.
No universal certification but DFS examinations and annual filings required. (178 words)

Key Differences

Aspect	FSSC 22000	23 NYCRR 500
Scope	Food safety management systems across food chain	Cybersecurity for financial services information systems
Industry	Global food manufacturing, packaging, logistics	NYDFS-regulated banks, insurers, financial entities
Nature	GFSI-benchmarked voluntary certification scheme	Mandatory state regulation with enforcement
Testing	CB audits, PRP verification, annual recertification	Annual pen testing, vulnerability scans, risk assessments
Penalties	Loss of certification, market access denial	Fines, consent orders, license revocation

Scope

FSSC 22000

Food safety management systems across food chain

23 NYCRR 500

Cybersecurity for financial services information systems

Industry

FSSC 22000

Global food manufacturing, packaging, logistics

23 NYCRR 500

NYDFS-regulated banks, insurers, financial entities

Nature

FSSC 22000

GFSI-benchmarked voluntary certification scheme

23 NYCRR 500

Mandatory state regulation with enforcement

Testing

FSSC 22000

CB audits, PRP verification, annual recertification

23 NYCRR 500

Annual pen testing, vulnerability scans, risk assessments

Penalties

FSSC 22000

Loss of certification, market access denial

23 NYCRR 500

Fines, consent orders, license revocation

Frequently Asked Questions

Common questions about FSSC 22000 and 23 NYCRR 500

FSSC 22000 FAQ

23 NYCRR 500 FAQ

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