FSC Sweden / Kolbjörn Örjavik
Transaction Verification Loops
Transaction Verification (TV) loops are structured, data-driven verification processes that compare sales and purchase records across FSC supply chains. In a TV loop, Assurance Services International (ASI) collects and analyzes transaction data from certificate holders to detect inconsistencies - such as mismatched volumes or irregular trade patterns - that may indicate false or inaccurate FSC claims. This process enables FSC and ASI to identify potential integrity risks, verify high-risk supply chain clusters, and take action to protect the credibility of FSC-certified product flows.
What a TV Loop Achieves
TV loops help FSC maintain traceability and protect the credibility of FSC-certified products by identifying volume inconsistencies, uncovering false claims, and revealing systemic integrity risks. They also strengthen FSC’s ability to ensure fair participation in certification and support targeted improvements in supply chain oversight.
The Three Phases of a TV Loop
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Phase 1 — TV Data Collection and Analysis
- Certification bodies request sales and purchase data from certificate holders within the loop’s defined scope and timeframe.
- ASI analyzes the aggregated data to detect supply chain clusters showing potential volume mismatches or false claims.
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Phase 2 — Transaction Verification
- ASI conducts detailed document reviews to verify suspected inconsistencies.
- High-risk supply chains or certificate holders are identified for thorough review.
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Phase 3 — TV Recommendations and Actions
- ASI provides FSC and certification bodies with recommendations for suspensions, terminations, or blockages, if applicable.
- Findings include observations to strengthen FSC system controls and prevent future risks.
What happens after the TV Loop?
Once a TV loop is completed, the findings are reviewed by FSC together with ASI and the relevant certification bodies. Depending on the outcomes, FSC may take a range of follow-up actions to protect the integrity of the FSC system.
These actions can include requests for corrective measures, certificate blockages, suspensions, or terminations where false or unsupported FSC claims are confirmed.
In parallel, insights from TV loops are used to strengthen FSC system controls, refine risk-based oversight, and help prevent similar integrity risks in the future.
Transparency and public reporting
Where relevant, FSC publishes public communications summarizing investigation outcomes and any resulting enforcement measures, in line with FSC's transparency commitments.
Relevant normative documents
TV loops operate under the FSC Transaction Verification Procedure and related Chain of Custody requirements. These documents define how data is collected, analyzed, verified, and acted upon.
FSC-PRO-10-201 — Transaction Verification Procedure: Defines how FSC, ASI, and certification bodies conduct TV loops, match transactions, and identify false claims.
FSC-STD-40-004 — Chain of Custody: Requirements for controlling inputs, volumes, and FSC claims.
FSC-STD-20-011 — Chain of Custody Evaluations: Evaluation and audit requirements for certification bodies.
FSC-STD-20-001 — General Requirements for Certification Bodies: Responsibilities, decision-making rules, and quality systems.
Advice Notes (FSC-DIR-40-004 & FSC-DIR-20-011): Additional instructions on false claims, high-risk profiles, and evaluation requirements.
FAQ
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How does FSC decide why and where to start a TV investigation?
FSC and ASI decide where to start a Transaction Verification (TV) investigation based on risk of false claims, as specified in Transaction Verification Procedure (PRO) V(1-0) FSC-PRO-10-201. Priority is given to supply chains and regions where there are indications of integrity issues, using inputs such as complaints, audit findings, data analysis, testing results, and reports from certification bodies and other sources.
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How many TV investigations have been there already?
As of 6 June 2026, there have been 23 transaction verification loops, starting in 2017.
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How do certificate holders forward transaction data?
Certificate holders submit their data using pre-defined formats supplied by ASI through their certification bodies. The format requires information on volumes bought and sold, as well as unique identifiers such as invoice numbers.
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How do certificate holders know if they are subject to transaction verification?
Certification bodies notify the affected certificate holders, providing clear instructions, timelines and requirements of the specified transaction verification loop.
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Who processes transaction verification data, and how is confidentiality handled?
Certification bodies collect and process relevant transaction data from their client certificate holders for the TV investigation.
Certification bodies are required to manage information obtained during certification activities through legally enforceable commitments and to have procedures in place to protect records and safeguard confidentiality.
This means that confidentiality arrangements are handled between the certification body and its client certificate holders as part of the certification relationship. Certificate holders with questions or concerns about transaction verification, including confidentiality or non-disclosure arrangements, should contact their Certification Body directly.
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Who processes the data?
Certification Bodies provide the transaction data to ASI for investigation through verification that FSC output claims made by certificate holders are accurate and match with the FSC input claims. This check-and-balance system is essential for a third-party certification system like FSC, which cannot be waived.
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What happens if data from two trading parties does not match?
When ASI verifies that transactions do not match between trading partners, ASI informs the applicable certificate holders’ Certification Bodies to request additional information for further investigation.
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Does FSC have access to the submitted data and is it stored?
In carrying out transaction verification, FSC does not expect or require receiving, accessing or processing Transaction Verification data. However, FSC does receive all relevant information and data regarding non-conformities identified via ASI investigations, so that FSC can take the appropriate measures to protect the FSC scheme and FSC’s reputation. FSC has the appropriate legal agreements with ASI, certification bodies, and certificate holders to handle such data and information.
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Are transaction verification requirements the same everywhere in the world?
Yes, they are the same everywhere in the world. However, based on a risk analysis and evidence of false claims, FSC and ASI will mainly focus transaction verification loops on certain regions and supply chains, where likelihood of false claims is high.
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What happens if a certificate holder refuses to provide transaction data to their certification body?
The refusal to provide transaction data represents a breach of the contractual agreement between the organization and the certification body. If the information is not provided within the time frame requested by the certification body, the certificate holder will be issued a CAR or have their certificate suspended and/or terminated.
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What information must be provided to fulfil the transaction verification requirement?
The data required for each TV loop may vary but generally will include information on trading partner (e.g. name, FSC CoC code), quantity, units, FSC claim type and species. Other data may be requested such as transaction identifier (e.g. invoice number), transaction date, description of products, country of origin, etc. No financial information will be required. The data will be collected on a sample basis, usually relating to a specific species, product type or timeframe in a specified format. The size of the sample requested will be determined by FSC and ASI based on risk. Auditors may also request access to shipping documents, invoices, or similar for confirmation.
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Is data from a TV investigation real-time data?
No, requested transactions will be from a previous specific period of time.
For more detailed information on how Transaction Verification loops are conducted, including methods, outcomes, and data handling, please refer to ASI’s FAQ on Transaction Verification.
ASI FAQ on Transaction Verification Loops
ASI FAQ on Data Handling and Protection during Transaction Verification