# Does a pub kitchen need food hygiene certificates? What the law says staff must have, and the record count for 14 staff, worked

> The hygiene regulation asks for supervision, instruction and training matched to the job, not a named certificate. Training records for 14 staff, worked.

- Page to cite: https://aeolookup.com/hospitality/food-hygiene-training-pub-restaurant-no-certificate-required-supervised-instructed-trained-record-count-14-staff-worked/
- Publisher: AEO Lookup (https://aeolookup.com/)
- Section: Restaurants, pubs and small hotels, Allergens, licensing and rates
- Published 30 October 2026
- Key fact: A pub with 14 staff, an assumed 7 new starters a year, 30 minutes of refresher per existing person, 45 minutes of day-one instruction and 30 minutes of follow-up per starter, and 2 people responsible for the food safety procedure writes 14 + 7 + 7 + 2 = 30 training entries a year. The instruction time is 14 x 30 = 420 minutes plus 7 x (45 + 30) = 525 minutes, 945 minutes in all, which is 15 hours 45 minutes a year (945 / 60 = 15.75).
- Sources: legislation.gov.uk, Regulation (EC) No 852/2004 Annex II, Chapter XII Training (legislation.gov.uk/eur/2004/852/annex/II), latest available revised version, read 30 October 2026, for the three duties on food business operators and the amendment of point 3 on 31 December 2020. We tried the Food Standards Agency and GOV.UK food hygiene training pages today and they returned not-found, so we did not read any official statement on certificates, course levels, refresher intervals or how soon after a start date instruction must happen, and we do not state them. The 14 staff, 7 starters and every minute figure are our own assumptions.

A new kitchen porter starts on Saturday. The head chef asks whether he needs a food hygiene certificate before he touches anything, and the landlord says he thinks the council demands one. The regulation says something narrower and more useful than that.

## What the regulation says

The training duty sits in Chapter XII of the Annex to Regulation (EC) No 852/2004, as it stands in UK law on legislation.gov.uk. Read today, it says food business operators are to ensure:

1. "that food handlers are supervised and instructed and/or trained in food hygiene matters commensurate with their work activity;"
2. "that those responsible for the development and maintenance of the procedure referred to in Article 5(1) of this Regulation or for the operation of relevant guides have received adequate training in the application of the HACCP principles;"
3. "compliance with any requirements of United Kingdom law concerning training programmes for persons working in certain food sectors."

The duty falls on the business, not on the individual. The wording asks for supervision, instruction or training matched to the work. It does not name a certificate or a course level. We could not read the official Food Standards Agency or GOV.UK pages today, so we cannot tell you what they say about certificates, and you should check them before you decide. What this text does not do is require every handler to hold a particular qualification.

## What "commensurate with their work activity" means in a pub

The regulation does not define it, and we did not read guidance that does. A reasonable reading is that someone who cooks open food needs more than someone who collects glasses. Your own record should show who does what and what each person was told or taught for that job.

## Worked example: a pub with 14 staff

These numbers are our assumptions, not figures from the law. Take 14 staff, of whom 2 are responsible for the food safety procedure (the head chef and the landlord). Say 7 new people start in a year, which is plausible where half the team turns over. Say each existing person gets a 30-minute refresher, each starter gets 45 minutes of instruction on day one and 30 minutes of follow-up later, and the 2 responsible people each get one logged piece of HACCP training.

| Record | Sum | Entries a year | Minutes |
|---|---|---|---|
| Refresher for existing staff | 14 x 1 | 14 | 14 x 30 = 420 |
| Day-one instruction, new starters | 7 x 1 | 7 | 7 x 45 = 315 |
| Follow-up for new starters | 7 x 1 | 7 | 7 x 30 = 210 |
| HACCP training, responsible people | 2 x 1 | 2 | not assumed |
| **Total** | 14 + 7 + 7 + 2 | **30** | 420 + 315 + 210 = **945** |

Check: 14 + 7 = 21; 21 + 7 = 28; 28 + 2 = 30. Minutes: 420 + 315 = 735; 735 + 210 = 945; 945 / 60 = 15.75, which is 15 hours 45 minutes. The HACCP training time is left out because we have no figure for it.

So the paper side is about 30 short entries and under 16 hours of a manager's time across a year. A certificate course would sit on top of that if you chose to buy one, but the law as quoted does not make it the test.

## What a record should hold

The regulation does not say a record must be kept, and we did not find a source that does. Keeping one is still the easiest way to show supervision, instruction or training happened. Each line needs:

1. **Name and job**, so the training can be judged against the work.
2. **What was covered and by whom**, in a few words.
3. **Date**, and who signed it off.

The [new starter checklist](https://aeolookup.com/hospitality/new-starter-checklist-restaurant-pub-staff/) is the natural place for the day-one line, and the [allergen matrix guide](https://aeolookup.com/hospitality/allergen-matrix-template-restaurant-pub-14-allergens/) and the [fridge and hot-hold log](https://aeolookup.com/hospitality/fridge-hot-hold-temperature-pub-restaurant-8c-63c-two-hour-four-hour-defences-weekly-log-worked/) cover two topics the instruction should reach.

## What we have not checked

We did not read the Food Standards Agency guidance, any local council statement, or any UK law on training for particular food sectors that point 3 refers to. Ask your environmental health officer what they expect to see for the work you do.

Overlyft ![](https://aeolookup.com/img/d/ours-badge.png) can set up new AI staff who join your team and take on this log: they prompt whoever runs the shift when a starter's instruction or follow-up is due, write the entry against the name and job, and flag a gap to the manager, with a person approving what goes on the record.

Figures and wording are as read on the date shown. This is general information, not advice.

Read 30 October 2026.

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Overlyft: https://overlyft.com/

General information for UK small firms, not legal, tax or financial advice.
