If you’ve read SA8000:2026 closely, you may have noticed something a little different about two criteria: D4.2 (living wage) and D4.4 (reasonable working hours). Instead of simply saying what an organization “shall” do, like most other criteria, these two say the organization shall “respect” personnel’s rights. It’s a small wording choice, but it’s deliberate — and it tells you something important about how these two topics are meant to be handled. This post walks through what that word means, and how it plays out in real audits.
Where “respect” comes from
SA8000:2026 aligns much more explicitly with the UN Guiding Principles on Business and Human Rights (UNGPs) than earlier versions of the Standard did. One of the clearest examples: every clause in the Decent Work Performance section now opens with human rights principles that we say governments must protect and businesses must respect. That division of responsibilities comes directly from the UNGPs, and SA8000 has built it into the Standard’s structure.
You’ll find this “respect” language in the first criteria of every clause, but the remaining criteria are usually “shall” statements spelling out what respecting that right looks like in practice. Wages and hours are the two places where SAI decided to keep the “respect” wording front and center.
So what does “respect” actually mean?
In principle, the expectations for businesses are the same as elsewhere in the Standard. SA8000 defines “respect” the same way the UNGPs do: avoid causing or contributing to harm, and address harm you do cause, contribute to, or are closely tied to. Paying people too little to live on, or working them unreasonable hours, prevents people from being able to fully enjoy their basic rights. So respecting these rights means paying at least a living wage and keeping hours within reasonable limits, and building the systems to keep doing that over time, just like any other part of the Standard.
So why is the language different here? It’s an acknowledgment that plenty of organizations run into real, structural roadblocks trying to meet these two requirements — problems that don’t go away just because a company tries hard. In those situations, an organization is expected to do everything it possibly can inside its own operations. But if that’s genuinely not enough, it cannot simply stop there. It has to look outward: use whatever influence it has, and build more influence where it can, to try to change the conditions standing in the way. That might mean pushing back on buyers over unrealistic prices and deadlines, working with local government to expand public services that reduce workers’ cost of living, or teaming up with other companies in the same industry (in a pre-competitive forum) to tackle a shared problem none of them can fix alone.
To be clear, this expectation technically applies anywhere a company can’t fully fix a problem on its own. But wages and hours are the two topics where that’s not just a possibility, it’s the norm in many industries and locations.
How this plays out in certification
The Procedure 200 Supplement lays out the audit protocols for SA8000:2026 generally. To get or stay certified, an organization needs to fully meet the Standard’s requirements through its own actions (with a little room for minor issues). But, if an organization is not the sole cause of a problem (because there are other substantive contributors) certification can still move forward, as long as the company can show it has solid systems in place to manage the risk and is genuinely making progress.
This applies to all Standard criteria, and it means that a gap in meeting the requirements doesn’t automatically sink an organization’s certification. It’s still flagged as a nonconformity, and it’s still classified based on how serious the harm is and how likely it is to happen (or how widespread it is if already happening). But if the company can show it has good systems in place and is making real progress, that nonconformity doesn’t have to block certification. (This is a simplified explanation — if you want the full technical detail, read Procedure 200 Supplement.)
SAI recently published Notification 3: Wages and Hours Expectations, which spells out in greater detail how auditors should assess these two topics within the Procedure 200 Supplement framework. To qualify for this kind of extended timeline, an organization needs to show its work. Specifically, it needs to:
- Regularly check its wages and hours against solid, credible benchmarks, and keep that analysis up to date
- Take an honest look at its own resources — what it has, and what it could reasonably shift around — to help close the gap
- Show real evidence of the outside factors making the gap hard to close alone
- Put an actual improvement plan in place, and follow through on it
Both the Procedure 200 Supplement and Notification 3 can be found in the SAAS Resource Library.
Two examples
Here’s what this looks like on the ground. (These are simplified, illustrative examples. SA8000 conformity assessment (certification) bodies have full discretion over nonconformities, their classifications, and closure timelines.)
Example 1: A company that’s genuinely trying
Company A runs the numbers and finds that everyone earns above the legal minimum wage, but 20% of workers fall short of the living wage benchmark. Digging deeper, they find this gap is concentrated among contract workers (who don’t get benefits) and new hires. So they take action: cutting costs where they safely can, restructuring pay, boosting the value of in-kind benefits, and checking in with workers along the way about what changes actually matter to them.
After all that, the gap narrows to 8% — it’s now entirely contract workers, and the company can’t find any more short-term fixes. So they build a multi-year plan to gradually raise contract worker pay, with a check-in every six months, while being upfront that they can’t guarantee it’ll fully close the gap considering inflation.
Along the way, they learn something useful: a big driver of these workers’ living costs is health care. Since contract workers are self-employed and part-time, they can’t just add them to a company health plan. Instead, they start mapping local organizations that help workers access affordable health care, and plan to connect their contract workers with those resources within three months. They also start tracking government health policy developments, looking for chances to advocate for change.
What this means for certification: Company A is doing everything right on the management side — but it still hasn’t reached full compliance on D4.2, since some workers aren’t earning a living wage. So it gets a nonconformity. But because the company can clearly show it’s exhausted its own options and the remaining gap comes down to outside factors, that nonconformity would likely be classified as “caused with other contributors” — meaning certification can still move forward. As long as Company A keeps showing strong systems and real progress at future audits, it could stay certified in this state for up to five years, after which it would need to have closed the gap fully.
Example 2: A company falling short
During a Stage 2 audit of Company B, workers tell the audit team that base pay meets the legal minimum — but most say they depend heavily on overtime just to cover rent, food, and school costs. Payroll records confirm wages are technically legal, but pay slips show 30–40% of workers’ total income comes from overtime.
When auditors ask management about living wage calculations, there’s nothing to show: no documented methodology, no evidence they’ve talked to workers about cost of living, no plan to close any gap. Worker representatives confirm wages have never been formally discussed, despite repeated informal complaints. There’s no sign anyone has assessed the risk that heavy overtime dependence creates for these workers.
What this means for certification: Company B isn’t meeting the living wage requirement, and it isn’t running any kind of management system to address it either. That’s not a “trying but falling short” situation — it’s a straightforward gap with no real effort behind it. So the nonconformity is classified as “solely caused by the organization.” If Company B were seeking certification, it couldn’t be certified until this is resolved. If it were already certified, it would have just four months to close the gap or lose certification altogether.
The takeaway
Using the word “respect” on the wages and hours criteria in SA8000:2026 reflects SAI’s recognition that these two issues are genuinely difficult to resolve, not a reason to lower expectations. Organizations are expected to do everything within their power, and when that’s genuinely not enough, to use their influence to push for change beyond their own operations. Notification 3 gives auditors more guidance to tell the difference between a company doing that work and a company that has not.
Have questions about how this applies to your organization? Reach out to your conformity assessment body, or contact SAI directly at sa8000@sa-intl.org.
