Why Structure Defines Credibility in Certification Bodies
If you’ve ever been through an accreditation audit, you know auditors don’t just look at your procedures—they look at who does what and how decisions flow. That’s exactly what Clause 6 of ISO/IEC 17021-1 is about.
In my experience working with certification bodies preparing for ANAB and UKAS assessments, the biggest problem isn’t missing documents—it’s unclear accountability. When roles overlap or decision authority isn’t well-defined, impartiality gets questioned.
This section helps you understand how to build a structure that’s transparent, accountable, and easy for auditors to follow. By the end, you’ll know how to map responsibilities, create separation of duties, and prove that your certification decisions are made independently.
Clause 6 sets the foundation for how a certification body should be organized. Think of it as your internal blueprint—it ensures your CB’s structure supports impartiality, competence, and accountability.
Here’s a quick breakdown:
Clause 6.1 – You must be a legal entity that takes full responsibility for certification decisions.
Clause 6.2 – Your structure must protect impartiality and avoid conflicts of interest.
Clause 6.3 – Roles and responsibilities must be clearly defined and assigned.
Pro Tip: Keep your org chart simple and up to date. A one-page visual that shows decision lines and reporting relationships often does more for clarity than ten pages of text.
Common mistake: Your org chart and your documented procedures must tell the same story. If the chart says one thing and the procedure says another, expect an audit finding.
This clause sounds basic, but it’s crucial. A certification body must be a legal entity—a company or organization that’s accountable for its certification activities and decisions.
Here’s how to show compliance:
Have proper business registration or incorporation papers.
Define your governing board or top management and their responsibilities.
Clearly state in your policy who’s legally responsible for certification outcomes.
I worked with a CB that operated under a parent company offering both consulting and certification services. To meet Clause 6.1, they created a governance charter separating those two activities and clarified accountability through a dedicated certification director. It eliminated perceived conflicts overnight.
Pro Tip: If you operate under a larger organization, set boundaries—documented, signed, and traceable—between your CB and any other business functions.
This is where things get interesting. Clause 6.2 ensures your structure actively protects impartiality.
What auditors want to see is separation between:
Audit activities
Certification decisions
Sales or business development
That separation prevents bias and protects credibility.
Here’s what I recommend:
Assign impartiality oversight to an independent committee.
Make sure audit results are reviewed by someone not involved in sales or audit delivery.
Review your structure annually to confirm it still supports impartiality as you grow.
A CB I supported once had its Sales Manager reporting directly to the Technical Manager—who also approved certification decisions. The accreditation body saw a conflict. The fix? Realigning reporting lines so that technical decisions became fully independent.
Common pitfall: Don’t assume small CBs get exceptions. Even two-person teams must show role separation—sometimes through external reviewers.
Pro Tip: Define impartiality responsibilities directly in job descriptions. It shows awareness and proactive control.
Clause 6.3 takes structure one step further—making sure every role within your CB knows exactly what they can and cannot do.
That includes auditors, reviewers, decision-makers, and administrative staff. Each must have defined authority and responsibility, documented and communicated.
How to comply:
Create clear job descriptions with defined duties.
Maintain an Authority Matrix that lists who can audit, review, and approve certifications.
Keep delegation records signed and dated.
During one assessment, an accreditation auditor asked who had authority to suspend certifications. The CB instantly produced its Authority Matrix—it saved them a nonconformity.
Pro Tip: Review this matrix annually, especially if your team or structure changes. It’s a simple document that proves management control and prevents confusion during audits.
Keywords: ISO/IEC 17021-1 6.3, authority matrix, defined responsibilities, certification roles
Governance vs. Management – Balancing Oversight and Execution
Clause 6 also helps clarify something many CBs mix up—governance and management.
Governance (like your board or impartiality committee) ensures oversight and impartiality.
Management (like your CEO or Technical Manager) handles operations and resources.
When these overlap, impartiality gets blurred. Governance provides direction; management executes it.
Pro Tip: Hold separate meetings—one for governance reviews, one for operational discussions. Keep both recorded in minutes. Auditors appreciate seeing that independence in practice.
Example: One CB added a quarterly “Impartiality Review Meeting” led by its committee chair, separate from management reviews. It strengthened oversight and reduced findings related to impartiality.
Integrating Structural Requirements into Your Management System
Clause 6 isn’t an isolated box to tick—it connects directly with Clause 5 (Impartiality) and Clause 9 (Management System).
Here’s how to integrate it naturally:
Reference your org chart in your quality manual.
Audit structural elements as part of internal audits.
Discuss structure changes in management-review meetings.
Pro Tip: Keep your org chart version-controlled with revision dates. Auditors love seeing a current, controlled document—it’s a simple sign of a well-run system.
Pitfall: Updating procedures but forgetting to revise the org chart or job descriptions. That inconsistency is a red flag.
Q1:Can a CB operate under a parent organization? Yes, but you must document and prove impartiality through structural separation—especially between consulting and certification arms.
Q2:What evidence do auditors expect for Clause 6 compliance? Your org chart, governance charter, job descriptions, authority matrix, and impartiality-committee meeting records.
Q3:How often should the structure be reviewed? At least annually, or whenever you change reporting lines, key roles, or ownership.
Building a Structure That Withstands Accreditation Audits
Clause 6 gives structure to your integrity. It ensures decisions are made by the right people, in the right way, without outside influence.
From my years helping CBs prepare for accreditation, one thing’s clear—those with clear, transparent structures rarely get nonconformities in Clauses 5 and 6. They not only meet the standard—they operate smoother, faster, and more credibly.
If you’re unsure whether your current setup meets Clause 6, it might be time for a quick structural review.
[Book a consultation with QSE Academy’s ISO experts →] We’ll help you design a structure that’s compliant, efficient, and ready for your next accreditation audit.
Melissa Lavaro is a seasoned ISO consultant and an enthusiastic advocate for quality management standards. With a rich experience in conducting audits and providing consultancy services, Melissa specializes in helping organizations implement and adapt to ISO standards. Her passion for quality management is evident in her hands-on approach and deep understanding of the regulatory frameworks. Melissa’s expertise and energetic commitment make her a sought-after consultant, dedicated to elevating organizational compliance and performance through practical, insightful guidance.
