HRS 1:2026 — Annex F
Fee model
Public consultation draft — draft v0.1 — issued 2026-09-07
This is a consultation draft, not an operative standard
The scheme described here is not yet certifying. No certificates have been issued and the Approved Supplier Register is not yet populated. Nothing in this document may be relied on as evidence of certification.
It is published for comment before it is finalised, because a certification standard that cannot be read by the people it governs is not a standard. Clause 12.2 commits us to publishing it; we would rather publish it early and be corrected.
Comments are invited until 2 November 2026. See How to respond. Passages marked ⚖️ are open questions on which we are specifically seeking views. Passages marked 📋 will be reconciled against OIC/SMIIC standards before issue.
This document is a scheme design. It is not a fatwa and does not purport to state Islamic law; questions of Shari'ah are for our Shari'ah Committee, whose rulings will be published with their reasoning.
Companion to HRS 1:2026 draft v0.2, clause 12.2 (fees must be published).
All figures below are placeholders marked a published figure. Pricing is a commercial decision. What this annex fixes is the structure and the integrity constraints — the parts that, if got wrong, damage the scheme regardless of the numbers chosen.
F1. Four things the fee model must do
- Cover the real cost of a real audit. A fee that cannot fund two audits a year, one of them unannounced (HRS 1 cl. 10.2), silently converts the scheme into a paper mill. If the number does not fund the visits, the number is wrong — not the visit schedule.
- Not price out the establishments the mark is most for. A small family kebab house is exactly where certification carries most consumer value and least ability to pay.
- Not create capture. See F4. This is the constraint most schemes discover too late.
- Be published in full (cl. 12.2). Published fees prevent the single most corrosive practice in certification: quiet discounts to large or difficult clients.
F2. Structure
F2.1 Components
| Component | Basis | Note |
|---|---|---|
| Application fee | Flat, per site | Non-refundable. Covers document review. Deters unserious applications |
| Initial audit fee | Banded by size — see F2.2 | The real cost driver is auditor-days |
| Annual certification fee | Banded | Covers register maintenance, mark licence, surveillance |
| Surveillance audits | Included in the annual fee | Must be included, never charged per visit — see F4.2 |
| Re-audit after non-conformity | Flat, at cost | Charged, so the cost of failure sits with the establishment |
| Supplier registration (Annex B) | Banded by category | Route 1 desk verification priced below Route 2 assessment, but not so far below that weak certificates become the cheap door — see Annex B, B9.4 |
| Provisional status | Application fee only | Deliberately cheap: it is a pipeline, not a product |
F2.2 Size bands — by covers, not turnover
| Band | Scale | Typical auditor-days/yr |
|---|---|---|
| 1 | ≤ 30 covers, or takeaway/delivery only | ~1.0 |
| 2 | 31–100 covers | ~1.5 |
| 3 | 101–250 covers | ~2.0 |
| 4 | 250+ covers, hotel F&B, banqueting, central kitchen | ~3.0+ |
| 5 | Multi-site group | Per site, with a group discount on shared systems only |
Covers, not turnover. Turnover requires the establishment to disclose financials it will resist disclosing and may misstate; covers are countable by the auditor on the day. Audit effort tracks kitchen complexity and menu breadth far more closely than revenue.
F2.3 Fee levels
Fee levels are not yet set. They will be derived from measured audit cost — see F1 — and published in full before certification opens (clause 12.2). No fee will be agreed privately, and any launch programme will be published, time-limited, and open to all applicants.
Two relationships are already fixed:
- Class B costs more than Class A at the same band. Annex A sections 6 and 7 add real audit time. Pricing them identically would make Class A subsidise Class B.
- Surveillance audits are included in the annual fee, never charged per visit. See F4.2.
F3. What must not be charged for
- Reading the standard, the checklist, or the register. Free and public (cl. 12.2).
- Making a public report or a complaint (Annex G).
- Appeals. A fee to appeal is a fee to be heard, and converts G4 into a filter on the appellant's wealth rather than the merits.
- Consultancy to prepare for our own audit. Not a pricing choice — clause 12.1 prohibits it outright, at any price.
The last one will be the hardest commercially. Establishments will ask us to help them pass, and there is real money in it. Taking it would make every subsequent certificate we issue arguable, and §15.10.3 of the Wiley handbook records self-certifying bodies as a named cause of lost credibility. Refer them to independent consultants; keep a public list of several; take nothing from it.
F4. Integrity constraints — the part that is not negotiable
F4.1 Revenue concentration limit
No single client, group, or related set of clients shall exceed a published percentage of annual certification revenue. We propose 15% and invite comment on whether that is the right level. On breach: disclosed to the Technical Committee, and a plan to reduce it.
A certifier that cannot afford to fail its biggest client will not fail its biggest client. This is the mechanism behind "some HCBs find themselves forced to accept non-halal laws" (Wiley §15.10.2) — it is rarely corruption, usually just arithmetic.
F4.2 Surveillance audits are never charged per visit
If an unannounced audit generates an invoice, every unannounced audit becomes a decision with a revenue consequence, and the ones that do not happen will be the ones that were least convenient. Bundle them into the annual fee so that the decision to visit costs nothing.
F4.3 No success-contingent pricing
No element of any fee may depend on the outcome. No refunds for failure, no discounts for a clean audit, no bonus to auditors linked to pass rates or to client retention.
F4.4 Auditor remuneration is not linked to client volume
Auditors are salaried or on fixed day rates. An auditor paid per certificate issued is being paid to issue certificates.
F4.5 Published, uniform, no private discounts
The fee schedule is public. Any deviation — a launch offer, a pilot rate — is published as a named, time-limited, open-to-all programme, or it does not happen.
F6. Consultation questions
- All numbers. Requires costing: auditor day rate, travel, register hosting, committee honoraria, trademark and legal, insurance.
- Band boundaries — confirm 30/100/250 covers against the actual Baku market distribution.
- Class B premium — what multiple of Class A? F2.3 argues it must be greater than 1.0.
- Concentration limit percentage (F4.1) — 15% suggested; at launch, with few clients, it will be structurally impossible to meet. Set a launch derogation with a date by which it binds, and publish that.
- Supplier fees vs. restaurant fees — suppliers are fewer, higher-value, and gate everything. Underpricing them starves the scheme; overpricing them stalls the bootstrap.
- Currency and VAT treatment; whether foreign suppliers (Annex B Route 3) are priced in USD.
F7. In preparation
- F-F1 Costing model — auditor-days per band, evidenced by pilot audits
- F-F2 Published fee schedule
- F-F3 Launch cohort programme terms
- F-F4 Revenue concentration monitoring report to the Technical Committee