What Would It Take to Fix Fashion’s Audit Fatigue?

Gabriel Amouyal has spent the best part of 20 years auditing supply chains. As audit services director at global supply chain compliance firm Qima, he’s seen it all, auditing hundreds of facilities across Asia’s textile industry, including fabric mills and garment factories in China, India, Bangladesh, and South Korea.

Audits, he says, are fashion’s best defense against allegations of wrongdoing, from environmental degradation to human rights abuses. “Audits have a key role to play because that’s firsthand information,” he explains. “You go on site, you get access to the people in the supply chain. It’s a tool for assessing the risks and adverse impacts, [and] it’s a tool that will support mitigation and prevention afterward.”

But pressure is mounting for the multi-billion-dollar auditing industry. A new wave of legislation from the EU — covering everything from due diligence and forced labor to greenwashing — means that fashion brands are increasingly reliant on audits to prove compliance in their supply chains. At the same time, audited and certified supply chains have been hit with a slew of scandals in recent years, calling into question whether audits are enough and raising questions about what a better system could look like.

The recent controversies span social and environmental claims, exposing gaps in the industry’s general approach to auditing and certifications, as much as specific standards or programs. In 2024, an investigation by NGO Earthsight alleged that there were links between Better Cotton Initiative-certified farms and illegal deforestation, land grabbing, and violence towards local communities. In response, Better Cotton Initiative (BCI) said that an independent audit into allegations found no breach of standards, but recommended that improvements could be made when it came to the certification’s criteria and assessment guidance.

Then, an ongoing probe into Made in Italy supply chains revealed evidence of worker exploitation in luxury subcontractors. Meanwhile, recent Peta protests about the ethics of wool have raised some doubts over the strength of the Responsible Wool Standard (RWS) and Nativa certifications, after the animal rights group found that there was violent handling of sheep at two farms in South Africa. Textile Exchange, the non-profit that develops and governs the RWS, said in a statement that the certifications of both farms have now been suspended following an investigation into the allegations.

In hopes of finding a better path forward, Vogue Business reached out to leading auditors to understand their — often-overlooked — perspective. What needs to change to move forward? And how can the industry help auditors live up to their promises?

A lack of nuance

One of the major challenges is that audits, rather than being able to give the whole picture, simply provide brands — and therefore consumers — with a snapshot of the situation on the ground at a given time. “It’s a very structured framework, which gives you insight into what’s happening on a given day, or over two or three days, depending on how much time you’re spending on the site,” explains Naurin Muzaffar, the founder of US-based auditing and consultancy firm Innovatus.

Typically, suppliers are given advance notice of an audit, whether that’s a specific date or a time frame in which the inspection will take place, allowing them time to prepare and perform at their best. “If I’ve booked an audit for 10 days’ time, the bosses in the factory will have everything clean [and] tidy for those 10 days before the auditor arrives,” says Ellias Mussa, a former auditor for fast fashion retailer I Saw It First, who is now a social advocacy worker for the Fashion Workers Advice Bureau Leicester (FAB-L). It’s why Muzaffar prefers unannounced visits where possible: “You want to be able to see the system running as naturally as possible.”

The structured nature of auditing frameworks also means that it can be difficult to flag any suspicions, unless they can be backed up with hard evidence. “Worker voices are systematically underrecorded through the auditing process, so [audits] end up being a document check,” says Anna Bryher, policy lead at non-profit campaigning group Labour Behind the Label. A recent report by Labour Behind the Label discovered labor violations in Pakistan, including garment workers not being paid the legal minimum wage, despite audits suggesting otherwise. Issues like this can easily slip through the net, especially because standardized audits tend to only offer space for a “pass or fail”, rather than a more nuanced approach, she adds.

Bryher argues that community-based monitoring — which would involve input from labor rights organizations and trade unions — should be used alongside the traditional auditing process, in order to provide a fuller picture of the situation on the ground. This could also help create pathways toward remediation, as well as just highlighting issues. “We’re calling for a shift from a compliance-centered due diligence toward remedy-centered due diligence that puts workers more central to the system,” explains Bryher. “Brands need to change who they’re listening to, rather than just listening to the suppliers and what they tell them about their records. They need to actually ensure worker voice evidence is respected and included in the way they audit a factory.”

Audit fatigue

Between rapidly shifting regulations, an increased emphasis on audits, and more bureaucracy related to digital product passports (DPPs), suppliers say they are spending more time verifying claims than doing what they were hired for — especially when each brand has different requirements, systems, and auditors. One factory manager in Lahore, Pakistan, cited in the Labour Behind the Label report, said that his facility had been audited for 220 days in the past year, with many of the major suppliers now having dedicated teams in charge of working with auditors — a cost smaller suppliers struggle to bear.

There is arguably now an overreliance on auditing within the fashion industry. “What we tend to do is spend a lot of time trying to find out what the problem is, and not enough time addressing it,” says Muzaffar. “The question is, do we really need all of us to go in independently and do the same thing again and again? Obviously not.”

Instead of duplicating audit reports, Qima’s Amouyal says there is a need for brands to identify where the risks actually are in their supply chain, and redirect resources to those areas. “When there is a lower risk, [maybe brands] avoid re-auditing the same [factories] and reuse existing audit reports [commissioned by other brands or suppliers],” he says.

Organizations like Sedex (Supplier Ethical Data Exchange) allow suppliers to commission their own audits, which can be made available to other brands. Meanwhile, member-led initiatives like Amfori BSCI (Business Social Compliance Initiative) and ICS (Initiative for Compliance and Sustainability) allow brands to request audits, which are then shared with other companies sourcing from the same facility. Collective auditing means that brands can then focus their efforts further down the supply chain. “Tier 1 suppliers are audited the most; we need to make sure that we are going to sites that are the most risky,” he explains.

Audit fatigue is symptomatic of a broader issue: fashion’s obsession with gathering data has overtaken its original purpose. On the environmental side, suppliers are now being asked to provide large amounts of data by brands, from carbon emissions to water usage. But not enough work is actually being done to help manufacturers, textile mills and farmers make improvements based on that data. “We keep collecting that data; we ask suppliers to fill in those forms and online portals,” says Innovatus’s Muzaffar. Unless brands prove that they are willing to act on audit findings and data collection, suppliers will continue to feel squeezed. “Suppliers keep on doing that, but nothing comes back to the supplier.”

The need for remediation

Much like traceability efforts and regenerative agriculture sourcing, the best-case scenario is that brands shorten their supply chains and form direct relationships with suppliers built on mutual trust, rather than top-down extraction. “The way a manufacturer will respond to a brand directly — there is no comparison to how they would be with a third party,” says Muzaffar.

Audits are especially effective when suppliers feel safe showing auditors the whole truth. To create the conditions for this, brands need to prove loyalty — that they won’t just “move to another supplier” if this one falls short on compliance — and a willingness to support remediation efforts, says Amouyal.

With more pervasive issues, this often means supporting suppliers long term, and recognizing that there isn’t necessarily a quick fix. “If we find an issue of child labor, that means we need to make sure that there is a long-term plan which goes a bit further, as well as a corrective plan after an audit,” he explains, noting that collaboration — either with other brands or NGOs working on the ground — is essential. “It’s about engaging with the relevant stakeholders; not doing it by yourself, but sometimes at industry level.”

For Mussa, brands employing in-house auditors that work directly with factories can be more effective. “If [in-house auditors] find [an issue] in the factory, they will work with them to rectify everything,” he says. In the vast majority of cases, though, brands simply do not have the resources required to directly audit their entire supply chain themselves, and if every brand did this, factories would be overrun. There is also a concern around companies turning a blind eye when “marking their own homework”, says Muzaffar. That’s why, in her view, brands need to adopt a combination of both in-house and external audits, ensuring that there are “checks and balances” in place.

The main shift required is a matter of perspective, says Amouyal. Audits should not be seen as a silver bullet, or a solution in and of themselves, but one part of a multi-pronged approach to supply chain management. “By itself, [audits are] not going to be a magic tool and resolve all [of the fashion industry’s] issues,” he concludes. “There are other tools that also need to be used.”