What Buyer Social Audits Flag Most in Indian Garment Units: SMETA, Higg FSLM, WRAP (2025 Data)
As of 20 Oct 2026, the published 2025 data points the same way: overtime beyond legal limits, social-security contributions, missing machine guards, unused PPE and badly marked or blocked emergency exits. SLCP found overtime breaches in 52% of facilities across its 10,700 assessments, the basis of Higg FSLM. In WRAP's nearly 6,300 audits, health and safety held 57% of non-compliances.
Last checked: 20 Oct 2026
For owners of Indian export garment units. Figures come only from Sedex, SLCP, WRAP and DQS publications; global unless marked "India". Not legal advice.
Verified against
- SLCP, Impact Report: A decade of driving decent work (2025 data), pp. 10–11, 19–21, and the release page
- SLCP, Impact Report 2024, pp. 16–17 (2024 data, for the year-on-year comparison)
- WRAP, Condensed Pre-Audit Self-Assessment, April 2026 edition, Appendix C "Common Non-compliances Found in WRAP Audits" and note 12
- ESCP, India's manufacturing momentum, 29 Jun 2026, with WRAP's India audit data for 2025
- DQS, CAPR, follow-up and sharing in the Sedex SMETA audit, 10 Jun 2026, top 10 findings from DQS's SMETA audits in 2025
- Sedex, Introduction to occupational health and safety, updated 13 Oct 2026, and The Complete SMETA Audit Guide
- Sedex, SMETA 7.0 Annex 4: The SMETA Workplace Requirements, Aug 2025 v1.1, requirement 1.D (copy hosted by VWA)
- Cascale, An Introduction to Higg FSLM
- Checked 20 Oct 2026.
What each scheme's 2025 data says
| Source (published) | Scheme | Sample, 2025 | Where findings concentrate (%) | Headline (2025) |
|---|---|---|---|---|
| SLCP Impact Report (Jun 2026) | SLCP CAF, used by Higg FSLM | 10,700 assessments; India 1,350 (13%) | Wages & Benefits 40%, Health & Safety 33%, Working Hours 17% | 91% of facilities had at least one legal non-compliance; average 10 per assessment |
| WRAP PASA, Appendix C (Apr 2026) | WRAP | Nearly 6,300 audits | Health & Safety 57%, Security 21%, Hours of Work 12%, Local laws 7% | These four principles held 97% of all non-compliances |
| WRAP India data via ESCP (Jun 2026) | WRAP, India | 346 suppliers certified, 406 audits (past year) | Of audits with findings: Health & Safety 63%, Security 16%, Local laws 6% (ESCP wording) | India CAP rate 16% against 37% globally |
| DQS blog (Jun 2026) | SMETA, DQS audits only | Count not published | Ranking only | 6 of the top 10 findings are health and safety |
| Sedex blog (updated Oct 2026) | SMETA, all audits | Count not published | — | Over 85% of SMETA audits found health, safety or hygiene issues, with more than 30,000 serious findings |
A country-by-country ranking of SMETA findings was not found in Sedex's public material, and SLCP publishes no India-only top 10 (checked 20 Oct 2026).
Higg FSLM sits on this data: Cascale says "the FSLM assessment is based on the Converged Assessment Framework (CAF) developed by the SLCP". So the SLCP figures are the best public proxy for Higg FSLM findings.
The top 10 findings and what to check tomorrow
Ordered by how many datasets name the issue and how high they rank it. The underlying rows are in a downloadable CSV.
| # | Finding | Who reports it (2025 data) | What to check on your floor tomorrow |
|---|---|---|---|
| 1 | Overtime beyond legal limits (daily, weekly, monthly) | SLCP #1, 52% of facilities; SLCP #2, monthly limits, 45%; WRAP Hours of Work list | Pull last month's register for 10 operators and compare each total with your state's overtime cap |
| 2 | Social-security contributions not collected, forwarded or registered | SLCP #3, 41%; #4, 39%; #5, workers not registered, 29% | Match last month's PF and ESI challans against the muster roll, including contract workers |
| 3 | Machine guards missing or not maintained | SLCP #6, 27%; DQS #3, "eye or needle guards on sewing machines"; WRAP Health & Safety list | Walk one sewing line and count machines without needle or eye guards; check belt guards in cutting and finishing |
| 4 | PPE issued but not used, or not in place | SLCP #8, 24%; DQS #4; WRAP's first Health & Safety item | Look at the cutting table (mesh gloves) and the boiler or ironing area at the start of a shift |
| 5 | Emergency exits not marked and lit, blocked or locked; no evacuation plan | DQS #1 and #7; WRAP Health & Safety list | Open every exit door during working hours, check the signs light up, and confirm a route map hangs on each floor |
| 6 | Weekly rest day not given | SLCP #9, 15% (a 14% decrease on 2024, per SLCP); WRAP: "at least one rest day after six consecutive working days" | Scan peak-month attendance for anyone with seven straight days marked present |
| 7 | Chemicals stored outside legal requirements; MSDS missing or out of date | SLCP #10, 13%; WRAP Health & Safety list | Check the spot-cleaning and dye store: labelled containers and an MSDS for each chemical |
| 8 | Signs not in workers' language; electrical panels unlabelled or unguarded; first-aid box incomplete | WRAP Health & Safety list; DQS #6 and #9 ("no rubber mats in front of electricity panels") | Read your safety signs as a migrant operator would; open the first-aid box and check expiry dates |
| 9 | Worker committee exists but workers don't know it; no communicated grievance procedure | DQS #2 and #10; SLCP #7, freedom to form a union, 25% | Ask three operators who their committee representative is and how they would raise a complaint |
| 10 | Security gaps: access to sensitive areas, seal control, ID badges, CCTV retention | WRAP Security, 21% of non-compliances (India: 16%, on ESCP's audits-with-findings basis) | For US-bound goods, check the recorder holds 30 consecutive days of 24/7 footage of packing, loading and gates |
Where the schemes differ
SMETA has no pass or fail. Each finding is graded Business Critical, Critical, Major or Minor, and it is tested against both Indian law and the ETI Base Code, where "the higher standard always prevails". A follow-up audit "generally takes place within six months" of the first one, per the same Sedex guide.
SLCP and Higg FSLM do not score you; they verify data. The numbers above count legal non-compliances recorded in that data.
WRAP is a certification. Audits are unannounced within a four-week window and cover all shifts, including overnight, per note 14 of the April 2026 PASA.
Of the documents checked, only WRAP's PASA requires CCTV (checked 20 Oct 2026). Note 12: US exporters "must maintain at least 30 consecutive days of 24/7 CCTV footage" of cargo, packing and entry points.
SMETA treats cameras the other way: Workplace Requirement 1.D says surveillance, "if used", must not be "excessive or for the purpose of controlling or intimidating workers" (SMETA 7.0 Annex 4, Aug 2025 v1.1). The clause-by-clause reading is in what buyer audits say about CCTV.
What a repeat finding costs: a worked ₹ example
Sedex charges "£185 per audit" for SMETA audits from 1 Jul 2025, in a notice to its approved audit companies. Everything else below is an assumption; ask your audit firm for its rates.
| Item | ₹ | Basis |
|---|---|---|
| Sedex fee, if passed on for the follow-up | ≈ 21,300 | £185; assume ₹115 per £ and that the fee applies |
| Follow-up audit, one auditor-day | 35,000 | Assume; quotes vary by firm and city |
| Owner and compliance manager time, 2 days | 20,000 | Assume ₹5,000 per person per day |
| Cost of one follow-up audit to close a finding | ≈ 76,300 | Sum |
| Needle guards for a 40-machine line | 8,000 | Assume ₹200 per guard |
On these assumptions, fitting guards before the audit costs about a tenth of what the follow-up does.
Where Indian garment units trip
Peak season. Overtime breaches cluster in the dispatch push. SLCP's 2024 report found a 0.8 correlation between excessive overtime and use of subcontractors (SLCP Impact Report 2024, p. 18). How the auditor tests hours records is covered in SMETA, amfori BSCI and WCA hours audits.
Size. In SLCP's 2025 data, facilities with fewer than 250 employees averaged 2 more legal non-compliances than larger ones.
First audits. Facilities that have used SLCP's CAF for five years averaged 8.3 legal non-compliances, 1.7 fewer than new users, per the 2025 report.
Heat. In 16% of SLCP facilities the indoor temperature maintained was 31°C or higher (2025 data). That matters for ironing and finishing floors in an Indian summer.
Fire. Exits and evacuation routes run through most of the top 10; the owner's fire walk is in fire in a cotton godown or garment unit. The wider risk picture is in the textile owner's risk list.
What the data cannot tell you
Apart from WRAP's India split, these are global counts, and DQS ranks only its own audits without counts. A camera shows a blocked exit or a guard missing from a machine, but it cannot show PF challans, overtime consent or whether workers trust the grievance box.
Where Mama fits
Mama reads a unit's existing cameras and reports machine running and idle time to the owner each morning, counting machines, not naming people. For a camera plan, leave an email or phone in the form below.
FAQ
What is the most common SMETA non-compliance?
Health and safety. Sedex says over 85% of SMETA audits in 2025 found health, safety or hygiene issues. In DQS's 2025 SMETA audits, the top finding was emergency exits not properly marked and lit.
What does Higg FSLM check for health and safety?
Higg FSLM uses SLCP's CAF questions. In 2025 the health and safety items in SLCP's top 10 legal non-compliances were machine guards (27% of facilities), PPE measures (24%) and chemical storage (13%).
Does WRAP require CCTV?
For facilities exporting to the US, yes: 30 consecutive days of 24/7 footage of cargo, packing and entry points, per WRAP's April 2026 PASA. Missing that retention is on WRAP's list of common security findings.