Training records an auditor can check
Updated Facts as of September 2026
Short answer
An auditor wants a per-person record, not a folder of signature sheets: who was instructed, on which version of the material, on what date, and with what result. Keep that record as a by-product of delivering the training, tie it to who was required to do what, and make sure one site's file can be shown during the visit.

The request is always the same
Auditors and inspectors are unimaginative in a useful way. Whatever the scheme or the sector, the training part of the visit opens with the same request: show me who was instructed, on what, when, and how you know it landed.
Companies that hold that as a per-person record with a date and a version answer in the room. Companies holding a shared drive full of scanned signature sheets spend two days reconstructing something that ends up being an argument rather than a record.
Clause numbers in this guide are as of September 2026: IFS Food version 8 and BRCGS Food Safety Issue 9.
Four visitors, four document requests
The four visitors a Benelux operator meets ask for different documents, and only two of them name a format.
| Visitor | What they ask for | Format prescribed? |
|---|---|---|
| VCA auditor | Dated lists of toolbox topics with attendance, plus your own instruction programme next to the diplomas | Yes, lists per site |
| IFS or BRCGS auditor | Participants with signatures, date, duration, content and trainer (IFS 3.3.3), proof of effectiveness, and a documented competency assessment for CCP work (BRCGS 7.1.2) | Yes, the fields are named |
| Social inspector (BE) or Arbeidsinspectie (NL) | Evidence that workers were informed and instructed for their tasks, and that compliance is supervised | Belgium: the signed onthaal document per starter. Netherlands: none |
| FAVV (Belgian food) | Your own training arrangements inside the self-checking system (autocontrole) | Your own documents become the standard |
The VCA auditor is the most literal of the four: the scheme spells out the document request, and a folder of valid diplomas answers only part of it. The VCA guide walks through the questions, and the toolbox guide covers the attendance lists.
The inspector is the one who surprises people. Dutch law names no document at all, which cuts both ways: nobody can reject your record for being the wrong shape, and nobody can help you if you have none. Belgian law is the opposite and names one very specific document, the onthaal record signed per starter. What each country requires is set out in workplace instruction law in Belgium and the Netherlands.
Four records, and the one nobody keeps
Four categories carry almost all the weight.
- The per-person completion record. Name, course, date, version of the material. Everything else is built from this unit, and it is where an auditor drills in when a rollup looks too tidy.
- Version history of the material. What the procedure said in March, what it says now, and when it changed. Without it, "trained on the cleaning procedure" is a topic, not evidence.
- The assignment record. Who was required to do what, from when. It turns a completion list into a coverage statement, because it makes the people who did not complete visible rather than absent.
- The integrity of the record. Whether a completion is a timestamp the system attached to a person and a version, or a date somebody typed into a column later.
The fourth is the one nobody keeps, and it decides a contested audit. An auditor who suspects a file was assembled the week before the visit will test it, usually by picking a name and asking for the trace behind it. A record produced by the system that delivered the training survives that. A spreadsheet last modified two days ago does not, and no amount of correct content rescues it.
Why screenshots fail the test
The common shortcut is the screenshot file: head office asks each site manager for proof, pastes the images into a document and hands that over. It fails for three reasons.
- It is not authoritative. An image can be cropped, edited or taken on the wrong day. It is a statement about a record, not the record.
- It cannot be questioned. The auditor's follow-up, "only the people who started after March", cannot be asked of a picture.
- It does not scale. Twelve months of topics across many sites is hundreds of images, assembled by hand, and one missing page reads as one missing person.
The screenshot file is what you build when the underlying system cannot show its own record. The fix is the system, not a better document.
Audit-ready is a stopwatch, not a filing cabinet
Audit readiness has three parts, and they are not equally hard. The records exist and are current: most organisations manage this. The records can be read by somebody else, per person, per site and per version, with the dates intact: many manage this too, after some work. And the file appears while the auditor is still sitting there. Almost nobody manages the third, and it sets the tone of the rest of the visit. An auditor who waits four days for a list does not conclude that your filing is slow. They conclude that the record was not there, and they look harder at everything else.
The design consequence: the record has to be a by-product of delivering the training, not an administrative act performed afterwards by someone with a deadline.
Version-tagged completion, and why the border changes the record
Tie every completion to the version of the document it came from. It costs nothing when the course is built from the procedure, and it answers the question that decides an incident file: was this person instructed on the method in force that day, or on the one it replaced.
The country you operate in changes what else the record must contain. In Belgium the onthaal adds a per-person, signed document that group attendance cannot produce. In the Netherlands no form is prescribed, but article 8 lid 4 asks you to supervise compliance on a continuing basis, and supervision without data is an assertion. If you operate on both sides of the border, build for the Belgian requirement and the Dutch one is covered. The reverse does not hold.
Four numbers to check before an auditor does
Run a monthly self-audit on the record rather than the content. Four numbers are enough.
- Share of sites current on every required topic. Not average completion, which hides the tail: the share of locations with nothing overdue.
- Time to show one site's file. Pick a site at random, ask for its file the way an auditor would, and time it. It is the only number measured with a clock, and the one that predicts how the visit feels.
- Record completeness. The share of completions carrying every field you would be asked for: person, date, version, result. A record without the version is one you cannot use after an incident.
- Onthaal coverage for starters. Everyone who started last month, with a per-person record behind their induction.
The first number tells you how the programme is doing. The other three tell you how the audit will go.
Setting it up before the request arrives
Four steps, in this order
- Mark which content is compliance content: safety instruction, hygiene, allergen procedures, site rules, onthaal. Only that set needs the full record discipline.
- Make completion mean more than opened: attach a knowledge check, so what you hold per person is a result rather than a signature.
- Keep the per-person record as a standing view you filter by site, course and version, not a report you build on request.
- Let each site show its own file, so an unannounced inspector does not wait for a call to head office.
Pretending everything is compliance content is how the discipline dies, which is why the first step comes first.
Recertification is a cadence you own
Almost nothing in this field carries a legally fixed refresh interval. The personal VCA diplomas run ten years and then require a new exam. Beyond that, the intervals in your programme are yours: you set them, and the finding comes when you quietly stop meeting them. How often training must be repeated sets out the intervals per framework.
How Aristotl handles it
Aristotl makes the record a by-product of the training. Your existing procedures become courses of 3-5 minutes done on the worker's own phone, each with a knowledge check, and nothing reaches the floor until your team reviews and publishes it. Completion is recorded as the person finishes, per person, per site and per version, and is viewable in the platform by site, region and team. A site manager can see their own site, so the file an inspector asks for is at the site, not at head office.
Certifications sit next to the courses: each has a validity period, its renewal window opens automatically before it expires, and external certificates such as a VCA diploma are recorded with issuer, dates and the proof document. Each certificate has its own verify link you can hand to an auditor. For checklists on the floor, the day log with its proof exports per site and per day as CSV or PDF.
What it does not replace: the signed onthaal document and the competency assessment on critical control points stay with the named people who own them.
Take the site you are audited on next and one topic you would be asked about, and time how long it takes to show that site's file today.
Sources
- IFS Food, version 8, clause 3.3.3 (training records and effectiveness)
- BRCGS Food Safety, Issue 9, clause 7.1.2 (competency of staff at CCPs)
- VCA checklist, chapter 3 and question 4.1
- Codex over het welzijn op het werk, art. I.2-11 and I.2-15 (onthaal)
- Arbeidsomstandighedenwet, artikel 8
- FAVV: autocontrole (Royal Decree of 14 November 2003)
Frequently asked questions
No. Arbowet article 8 requires effective information and instruction adapted to each worker's tasks, and lid 4 requires the employer to supervise compliance, but it names no document. Without a record of your own you cannot show that article 8 was met, so the freedom of form is not a freedom to keep nothing.
Read more: What Belgian and Dutch law require for workplace instruction
No. IFS clause 3.3.3 asks for the attendance record (participants with signatures, date, duration, content and trainer) and, in the same clause, a documented procedure that demonstrates the training was effective. A signature covers the first half only.
Read more: Did the training work? Measuring effectiveness beyond completion
Usually the onthaal document: for every starting worker, a document signed by the designated member of the hierarchical line showing that the necessary information and instructions on wellbeing at work were given. It is per person and signed, so group attendance cannot produce it.
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