Compliance and factory audits in Bangladesh
CMB Sourcing Ltd. makes knitwear and caps in its own factory and places everything else with an audited partner factory, named to you in writing, with its reports in your hands before production starts. How to check them, what to read beyond the grade, and the laws behind your buyers’ questions.
- Factory
- Named in writing before production
- Documents
- Audit reports and certificates, before production starts
- Social audits
- amfori BSCI, WRAP, Sedex SMETA, SA8000 and others
- Building safety
- Checked on the public International Accord factory list
- Subcontracting
- Only to sites you approve in writing
- Cotton origin
- Yarn and fabric records kept with the order
In short
An audit certifies one factory on one day. Compliance is choosing a factory whose audits your buyers accept, checking they are genuine and current, keeping your order in that building, and holding the records that prove where the cotton came from. An amfori BSCI rating of C, D or E means a follow-up audit 2 to 12 months after the full one.

Three things buyers mean by compliance
When a buyer asks whether an order is compliant, they usually mean three different things at once, and each is proved in a different way. The factory: that the site making the goods treats its workers lawfully and is structurally safe, proved by audits and inspections. The product: that the garment meets the labelling, chemical and safety rules of your market, proved by testing and correct labels. And the supply chain: that nothing upstream, including the cotton, involved forced or child labour, proved by records.
This page covers the first and the third. Product rules differ by country and are set out on our market pages, with the tests each one needs; how garments are inspected is on our quality control page.
How we match your order to a compliant factory
We make knitwear and caps in our own factory and source everything else, so for most orders our job is to choose the right factory and prove it. The order of the steps matters: the factory is chosen for its audits first and its price second, never the other way round.
- Start from your requirements: your code of conduct, or your retailer’s supplier manual, and the audits it accepts
- Shortlist only factories holding those audits, current on the day we check, for the product you are making
- Check each audit ID or certificate number with the body that issued it, not only the copy the factory sends
- Check building-safety status on the International Accord’s public factory list where the factory is covered
- Name the factory, with its address, in writing before production starts
- Send you the audit reports and certificates before production starts
| Audit | How long it lasts | How to verify it |
|---|---|---|
| amfori BSCI | A two-year cycle: after an A or B rating the next full audit is due within two years; a C, D or E needs a follow-up audit 2 to 12 months after the full audit. | Ask for the amfori audit ID. amfori members can open the full report on the amfori Sustainability Platform. |
| Sedex SMETA | No fixed expiry. Most buyers ask for a new audit every 12 months. | The factory shares its Sedex reference (ZS/ZC number) and audit report with your company on the Sedex platform. |
| WRAP | One year. Since 1 March 2026 WRAP issues an annual Certification of Compliance with no Gold or Platinum levels; older Platinum certificates run to their printed expiry. | Search the facility name on the certified-facilities list at wrapcompliance.org. |
| SA8000 | 3-year certificate with surveillance audits every 6 to 12 months. | SAAS publishes the list of certified facilities. |
| SLCP verified assessment | A new verified assessment every year. | Ask the factory to share its verified assessment through the SLCP Gateway or an accredited host such as Worldly. |
| Better Work Bangladesh | Annual assessment cycle for enrolled factories. | Ask whether the factory is enrolled and for its latest Better Work assessment. |
| RMG Sustainability Council (RSC) | Initial inspection, then follow-up inspections until every finding is fixed. | Search the factory on the International Accord’s public Bangladesh factory list, which shows remediation progress. |
All the certifications and audits that apply in Bangladesh
Where each piece of proof stops
No single document proves that an order is compliant. Each check is made by a different body, looks at a different thing and stops at a clear edge, and the gap between two of them is usually where a compliance team’s question lands. The table sets out the file for an order that way: who issues each piece, what it shows, and what it cannot.
Two of the edges cause most of the surprises. A social audit and a building-safety inspection are different checks by different people: the first looks at how workers are treated, the second at the building, and a good result on one says nothing about the other. And a transaction certificate for organic or recycled material follows a shipment, not a factory: it is issued by the supplier’s certification body for that specific shipment, and GOTS allows it to be issued up to six months after the shipment date, so it can arrive after the goods.
Tick each row against the documents and records you have for the order. A row you cannot tick is a question to raise before production starts, not after the goods have shipped.
| Proof | Who issues it | What it shows | What it cannot show |
|---|---|---|---|
| Social audit report (amfori BSCI, SMETA, WRAP, SA8000) | An independent audit firm or certification body, under the scheme’s rules | Working conditions at one site, on the audit dates | Other sites, anything since the audit, the building’s structure |
| Building-safety inspection and corrective action plan | The RMG Sustainability Council (RSC), for factories covered by the International Accord | Fire, electrical, structural and boiler safety, and progress on the fixes | Wages, hours or how workers are treated |
| Factory licence | The Department of Inspection for Factories and Establishments (DIFE) | That the factory may operate, at that address | Whether it meets your code of conduct |
| Inline inspection | Us, at the named factory, while your goods are sewn | That your order is being made in that building | Working conditions: it is a quality check |
| Cotton origin records | Cotton merchant, spinner and fabric mill, kept on the order file | Where the fibre in your fabric was grown | Conditions at the mills themselves |
| Transaction certificate (organic or recycled) | The supplier’s certification body | That one listed shipment contains certified material | Any other shipment, or goods not listed on it |
Reading an audit report, not just the grade
A grade is a summary, and summaries hide things. An amfori BSCI audit rates a factory from A to E across its performance areas; A and B are good results, while C, D and E require a corrective action plan and a follow-up audit between two and twelve months after the full audit. A Sedex SMETA audit gives no grade at all, only a list of non-compliances. In both cases the useful questions are the same: when was the audit, was it announced or semi-announced, what was found, and have the findings been closed with evidence.
Look for the findings that matter most in Bangladesh: working hours and overtime records, wage calculations against the legal minimum, fire exits and alarms, and whether a trade union or participation committee exists. A B-rated factory with an overtime finding that has been fixed and verified can be a better choice than an A-rated factory whose audit is nearly two years old.
BSCI, WRAP, SMETA or SA8000 compared
Unauthorised subcontracting: the risk audits miss
An audit certifies one building. The risk that audits cannot see is an order quietly moved to a different, unaudited site when the audited factory is full or a deadline is tight. A 2015 survey by NYU Stern’s Center for Business and Human Rights found informal subcontractors made up 32 per cent of the factories surveyed in two Dhaka sub-districts; the industry disputed parts of that research, but the risk it describes is real and it is the one your compliance team will ask about.
Our controls are practical. Your order is placed with a named factory under a written commitment that no part of it moves elsewhere without your approval. We inspect inline at that factory while your goods are being sewn, which is also how an order that has moved gets noticed. And where a process genuinely has to happen elsewhere, such as embroidery, printing or washing, the site is named to you and its documents shared like the main factory’s.
The laws behind your buyers’ questions
Most of the questions you will be asked come from a handful of laws. Few smaller brands are directly in scope, but their retailers are, and the requests flow down the chain to you and then to us. The table below shows who each law applies to and what it translates into for a supplier.
| Law | Who it applies to | What your buyers will ask for |
|---|---|---|
| UK Modern Slavery Act 2015, section 54 | Organisations doing business in the UK with turnover of £36 million or more | An annual statement; from suppliers, the factory name, audits and fibre origin |
| Germany: Supply Chain Due Diligence Act (LkSG) | Companies in Germany with at least 1,000 employees | Risk analysis, a grievance channel and evidence that audit findings were fixed |
| EU Corporate Sustainability Due Diligence Directive, as amended in 2026 | Companies with more than 5,000 employees and over €1.5 billion turnover; compliance from July 2029 | Mapped supply chains and due diligence that flows down to suppliers |
| EU Forced Labour Regulation (EU) 2024/3015 | Every product placed on the EU market, with no size threshold, from 14 December 2027 | Evidence that forced labour played no part at any stage, fibre included |
| US Uyghur Forced Labor Prevention Act | Every importer into the United States | Traceable cotton origin; goods with Xinjiang inputs are presumed made with forced labour |
| Canada: Fighting Against Forced Labour and Child Labour in Supply Chains Act | Entities above the Act’s size thresholds | An annual report by 31 May on steps taken to reduce the risk |
Cotton traceability
Bangladesh grows very little cotton and imports most of what it spins, so where the fibre came from has to be shown with documents rather than assumed. That matters most for the United States, where goods with any input from Xinjiang are presumed to involve forced labour, and increasingly for the EU once its forced labour ban applies. We collect these records with the fabric and keep them on the order file.
- Cotton origin declaration naming the country the fibre came from
- Yarn and fabric purchase invoices, from mill to factory
- Production records tying fabric rolls to your cutting tickets
- Transaction certificates where the fabric is certified organic or recycled
What we will not claim
We hold no audits or certificates ourselves, and we will never present a factory’s certificate as ours or a certificate from one factory as covering another. An audit is a snapshot of one site on one day, so we do not describe any factory as fully compliant or risk-free. If your code of conduct requires something no suitable factory can show, we tell you before you are committed, not after.
Sources
Checked . Rules and figures change, so confirm anything that affects your pricing.
Show all 21 sourcesHide the sources
- amfori — BSCI audit rating guide (opens in a new tab)
- amfori: amfori BSCI System Manual, 2022 edition (Figure 6: one follow-up audit between month 2 and 12 after a C, D or E rating) (opens in a new tab)
- International Accord — Bangladesh factory list and remediation status (opens in a new tab)
- NYU Stern Center for Business and Human Rights — Beyond the Tip of the Iceberg: Bangladesh’s Forgotten Apparel Workers (2015) (opens in a new tab)
- legislation.gov.uk — Modern Slavery Act 2015, section 54 (£36m turnover threshold in the 2015 Regulations) (opens in a new tab)
- CSR in Deutschland (Federal Government) — German Supply Chain Act (opens in a new tab)
- EUR-Lex: Directive (EU) 2024/1760 on corporate sustainability due diligence, consolidated text of 18 March 2026 (Article 2: more than 5,000 employees and EUR 1.5 billion turnover; Article 37: applied from 26 July 2029) (opens in a new tab)
- Clifford Chance — Omnibus I: the EU concludes CSDDD and CSRD reforms (February 2026) (opens in a new tab)
- Linklaters — EU Forced Labour Regulation published in the Official Journal (opens in a new tab)
- CBP — Uyghur Forced Labor Prevention Act (opens in a new tab)
- Justice Laws Canada — Fighting Against Forced Labour and Child Labour in Supply Chains Act (opens in a new tab)
- International Accord — Bangladesh: fire, electrical, structural and boiler safety, implemented by the RMG Sustainability Council (RSC) (opens in a new tab)
- Cascale (How to Higg) — Higg FEM verification programme: self-assessment verified by a Cascale-approved verifier, on site or off site (opens in a new tab)
- U.S. Customs and Border Protection — CTPAT eligibility requirements for foreign manufacturers (incorporated in Mexico or Canada) (opens in a new tab)
- U.S. Customs and Border Protection — CTPAT Minimum Security Criteria for U.S. importers, October 2021 (criterion 3.5: due diligence on outsourced business partners by visits, questionnaires and similar) (opens in a new tab)
- The Financial Express (27 September 2020) — DIFE inspects factories under the Bangladesh Labour Act 2006 and Labour Rules 2015 (opens in a new tab)
- DIFE, Labour Inspection Management Application (LIMA): licence verification by licence or registration number (page in Bengali, read 2 November 2026) (opens in a new tab)
- DIFE, LIMA: remediation tracking, factory dashboard and factory profiles: filters by district, sector, name, registration number and status; each factory’s inspection reports, corrective action plan, escalation status and remediation progress (read 2 November 2026) (opens in a new tab)
- Laws of Bangladesh (Legislative and Parliamentary Affairs Division): Bangladesh Labour Act 2006, section 90A, safety committee in every establishment with 50 or more workers, as replaced by the Bangladesh Labour (Amendment) Act 2026 (Act 43 of 2026), section 26 (opens in a new tab)
- Laws of Bangladesh: Bangladesh Labour Act 2006, section 205, participation committee: 50 or more workers, worker representatives not fewer than the employer’s, (6) elected from the workers (2018), (6A) acting until a union is formed (2013), (12) not needed where a trade union exists and (13) certified copies on payment of a fee (both added 2018) (opens in a new tab)
- Global Standard gGmbH (GOTS), Q&A: a Transaction Certificate is issued by the supplier’s certifier for a specific shipment; TCs may be issued up to six months from the date of shipment (opens in a new tab)
Compliance and audits: common questions.
Which audit should I ask the factory for?
Ask for the one your largest customer accepts, because a second audit costs the factory time and money and rarely tells you more. European retailers most often ask for amfori BSCI, UK retailers for a Sedex SMETA report, and US retailers for WRAP; SA8000 is the most demanding and is valued by brands with a strong ethical position. Many buyers now also accept an SLCP verified assessment, which is designed to replace repeated brand audits. If you have no customer requirement yet, a recent amfori BSCI or SMETA audit with its findings closed is a sound starting point that most buyers recognise. Whatever you choose, ask for the full report, not just the certificate or grade, and check the audit ID with the body that issued it. We shortlist factories already holding the audit you need, so you are not paying for a new one.
Can I see the audit reports before I place an order?
Yes, and you should. Once we have shortlisted the factory for your product, we send the latest social audit report, its building-safety status, the relevant certificates with their numbers and the factory’s licences, before production starts. Some audit schemes share full reports only through their own platforms: amfori members can open BSCI reports on the amfori Sustainability Platform, and SMETA reports are shared through Sedex, so if your company is a member we can arrange access that way. If you are not, the factory can share the report directly, and the audit ID lets you confirm it is genuine. Read the findings and the dates, not only the grade. If anything in the report concerns you, raise it before production: that is the point at which a corrective action can still be agreed, or a different factory chosen, without delaying your order.
How do you stop my order being subcontracted?
Three ways, all in writing and on the ground. First, your order is placed with a factory named to you, with its address, before production, and our agreement with that factory says no part of the order moves to another site without your written approval. Second, we inspect inline at that factory while your goods are being cut and sewn, so production that is not happening where it should be is noticed while it can still be stopped. Third, any process that genuinely happens elsewhere, such as printing, embroidery or washing, is named to you as a separate site, and its documents are shared like the main factory’s. You are also welcome to send your own auditor or a third-party inspector at any stage of production. Their findings go on the order file beside ours.
Do new EU and US laws affect a small brand?
Directly, often not; indirectly, almost always. The EU due diligence directive now applies only to very large companies, from July 2029, and Germany’s LkSG to firms with at least 1,000 employees there. But if you sell to retailers above those thresholds, they must ask their suppliers the same questions, so the requests arrive with you. Two laws apply regardless of size. The US Uyghur Forced Labor Prevention Act applies to every importer, and goods with Xinjiang inputs can be detained at the border until origin is proved. The EU Forced Labour Regulation, from 14 December 2027, will allow products made with forced labour to be banned and withdrawn whoever sells them. For a small brand the practical answer is the same: a named factory, current audits and cotton origin records, which you should ask for on every order.
How do brands prove clothing contains no Xinjiang cotton under the Uyghur Forced Labor Prevention Act?
With records that trace the cotton from the bale to the finished garment, because under the US Uyghur Forced Labor Prevention Act the importer must prove it. Since 21 June 2022, goods made wholly or in part in Xinjiang, or by an entity on the UFLPA Entity List, are presumed to be made with forced labour and refused entry. Bangladesh imports most of the cotton it spins, so origin has to be shown, not assumed. The core file is a cotton origin declaration naming the growing country, bale-level records from the cotton merchant, yarn and fabric invoices from mill to factory, and production records tying fabric rolls to your cutting tickets. Screen every spinning and fabric mill against the Entity List, which grew to 187 entities on 3 August 2026. If CBP detains a shipment, the importer has 30 days to respond, and an exception needs clear and convincing evidence. We keep these records on the order file.
What is a social compliance audit, and what does the auditor check?
A social compliance audit is an on-site assessment of one factory’s working conditions against a code of conduct and local labour law, carried out by an independent audit firm. The auditor gathers evidence from three sources and cross-checks them: documents such as wage, working-hour and age records, a walk through the site looking at exits, alarms, chemical storage and machine guarding, and private interviews with workers the auditor chooses. An amfori BSCI audit rates the factory across 13 performance areas; a Sedex SMETA audit covers labour standards and health and safety, with environment and business ethics added in the 4-pillar version. The visit ends with a closing meeting and a list of findings to correct. What it cannot do is certify the building’s structure, which in Bangladesh is inspected separately, or see an order moved to another site. Read the findings, and check that the audit names the factory making your goods.
What is a corrective action plan after a factory audit?
A corrective action plan is the factory’s written list of the audit’s findings, each with the action agreed, a deadline and, later, the evidence that it was fixed. Under amfori BSCI, a factory rated C, D or E must draw up its improvement plan within 60 days of the audit, and a follow-up audit takes place between two and twelve months after the full audit. A Sedex SMETA report grades each finding as business critical, critical, major or minor and ends with a corrective action plan in place of an overall score. Building-safety inspections work the same way: the International Accord publishes each covered factory’s plan and its remediation progress. Read each finding, its severity, the date and whether it was closed with evidence at a follow-up. A factory with a C and a closed plan is often a better choice than one with a B and open findings.
Do I need my own supplier code of conduct as a small brand?
No, a small brand does not need to write its own code of conduct: adopting a recognised one tells a factory what you expect and matches the audits it already holds. The ETI Base Code, which Sedex SMETA audits are based on, has nine clauses founded on International Labour Organization conventions: employment is freely chosen, freedom of association is respected, working conditions are safe and hygienic, child labour is not used, living wages are paid, working hours are not excessive, there is no discrimination, regular employment is provided, and no harsh or inhumane treatment is allowed. The amfori Code of Conduct plays the same role for amfori BSCI audits. Name the code you adopt in your purchase order, add a clause that no part of the order moves to another site without your written approval, and ask for the audit report that tests the factory against it.
What is the difference between an announced and an unannounced factory audit?
An announced audit takes place on a date the factory knows in advance, a semi-announced audit on an unknown day inside a window the factory has been told, and an unannounced audit with no notice. The less warning a factory has, the closer the audit is to a normal working day, so the announcement type is one of the first things to read on a report. amfori BSCI books semi-announced audits by default: the window must be at least four weeks long and start at least two weeks after the request. Sedex recommends semi-announced or unannounced SMETA audits unless there is a valid reason for an announced one, and WRAP-certified facilities remain subject to random unannounced assessments. For forced-labour due diligence, US Customs and Border Protection says audits should be unannounced and independent. The report states which type it was, so given two similar reports, prefer the one with less notice.
Besides a social audit, which other factory audits do garment buyers ask for in Bangladesh?
Four more come up, and each is proved by a different document. Building safety: factories that supply brands signed to the International Accord’s Bangladesh Safety Agreement are inspected for fire, electrical, structural and boiler safety by the RMG Sustainability Council (RSC), which carries out the agreement in Bangladesh, and the Accord’s public factory list shows each covered factory’s inspection reports and remediation progress. Environment: the Higg Facility Environmental Module (FEM) is a factory’s self-assessment of its energy use, greenhouse gas emissions, water and waste, checked by a Cascale-approved verifier either on site or off site, so ask for the verified module and which kind of verification it had. Supply-chain security: CTPAT is a voluntary US Customs programme whose foreign manufacturer members must be incorporated in Mexico or Canada, so a factory in Bangladesh cannot join it; if your US customer is a member, CTPAT’s criteria require it to check, by visits or questionnaires, that its overseas suppliers meet the programme’s security criteria, so expect a security questionnaire or a visit to the factory instead. And the legal floor: the Department of Inspection for Factories and Establishments (DIFE) enforces the Bangladesh Labour Act 2006 and the Bangladesh Labour Rules 2015, inspects factories on the spot and sets deadlines for fixing violations, so ask for the factory’s current licence and check that its address matches the building. Our certifications page lists each of these with how to verify it.
Can I check a Bangladesh factory’s licence and government inspection status online?
Yes, on the online portal of the Department of Inspection for Factories and Establishments (DIFE), called LIMA, the Labour Inspection Management Application. Its licence verification page returns a factory’s current status when you enter its licence or registration number, so ask the factory for that number and check it yourself rather than relying on a scanned copy. The same portal publishes a remediation tracking dashboard for the factories it follows, searchable by district, sector, name and registration number, which shows each factory’s inspection and corrective action plan records, its escalation status and its remediation progress; it can also be filtered by status, such as open, closed, relocated, inside an export processing zone or working with the Accord. The portal opens in Bengali, with a switch to English at the top of the page. Two cautions. A licence shows that the factory may operate, not that it meets your code of conduct, so it sits beside the social audit, not in place of it. And a licence held by a sister unit is not a licence for the building making your goods, so match the name and address to the factory named on your order.
What are a factory’s safety committee and participation committee, and what should I ask to see?
They are two committees the Bangladesh Labour Act 2006 requires, and social audits commonly look at both. Every establishment with 50 or more workers must form a safety committee and make it work, in the way the labour rules set out; it tells the owner about the risks, accidents, dangerous occurrences and diseases it identifies (section 90A, as replaced by the Bangladesh Labour (Amendment) Act 2026). An establishment where at least 50 workers are normally employed must also form a participation committee of worker and management representatives (section 205). The workers’ representatives are elected from the workforce and may not be fewer than management’s, and where there is no trade union they may act for workers’ interests until one is formed; where a trade union exists, no participation committee is needed, and copies of a committee’s certificate and records can be obtained for the fee the government sets (section 205(13)). Ask for the record of the last committee election, the members’ names and the minutes of recent meetings, and read what the social audit found about each committee. A committee that exists only on paper, or whose worker members were picked by management rather than elected, is a finding to close before production, not a formality.
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