Why Structure Defines Credibility in Certification Bodies
When I help new personnel certification bodies prepare for ISO/IEC 17024 accreditation, one topic always sparks confusion—structure.
Everyone understands impartiality (Clause 4), but Clause 5 goes deeper. It’s about how your organization is built to protect that impartiality and ensure consistent, credible certification decisions.
In short, Clause 5 defines who holds authority, who’s accountable, and how independence is maintained.
If your structure isn’t clear—or if roles overlap in ways that could influence certification outcomes—assessors will notice immediately.
This guide will show you how to design a structure that not only meets ISO/IEC 17024 requirements but also works smoothly in day-to-day operations.
You’ll learn how to:
Set up a legally accountable certification body
Define clear roles and responsibilities
Maintain independence between certification and commercial activities
Demonstrate governance and management oversight effectively
What Clause 5 Really Means
Clause 5’s purpose is simple: make sure your certification body has a defined and documented structure that supports impartial operations.
It’s the “skeleton” of your management system. Without it, impartiality (Clause 4) and operational control (Clause 6–10) have nothing to stand on.
Think of Clause 5 as answering three key questions:
Who’s responsible for certification decisions?
Who oversees impartiality and governance?
Who ensures compliance and resources?
Here’s what I’ve noticed: Many bodies rely on their company’s existing org chart, thinking it’s enough. But ISO/IEC 17024 expects a structure built around certification, not sales or consulting.
Pro Tip: Start with your impartiality policy, then design your structure around protecting it.
Common mistake: Mixing certification and business development roles. When the same person sells services and approves certificates, impartiality is automatically at risk.
Clause 5.1 requires your certification body to be a legally identifiable entity. That means it must take full responsibility for its certification decisions and the certificates it issues.
This doesn’t always mean you need to create a brand-new company—but you must show legal accountability.
For example, one client ran certification as part of a larger training organization. To satisfy assessors, we registered the certification division as an independent subsidiary with its own contracts, liability insurance, and governance records.
It didn’t change how they operated daily, but it gave them the legal independence they needed to pass accreditation.
Pro Tip: If your certification body operates within a parent company, document exactly how it maintains independence—especially around finances and authority.
Pitfall: Shared ownership with a consultancy or training entity. Even if the intention is good, it creates a perceived conflict of interest.
Defining Roles, Responsibilities & Authorities
Every accredited certification body needs clarity in who does what. ISO/IEC 17024 Clause 5 expects roles and responsibilities to be defined, documented, and communicated.
At minimum, your structure should clearly identify:
Top management or governing body: oversees impartiality and resource allocation.
Certification decision-maker: final authority to grant, suspend, or withdraw certifications.
Scheme manager: manages day-to-day certification operations and scheme integrity.
Technical experts or examiners: evaluate candidates according to the scheme requirements.
Impartiality committee: monitors conflicts of interest and overall independence.
In one project, we built a Responsibility Matrix (RACI chart) that mapped every ISO/IEC 17024 clause to a specific role. Assessors praised it as “one of the clearest structures” they’d seen—it made responsibilities unambiguous.
Pro Tip: Assign certification decision-making authority to someone not involved in evaluation or training. That separation is key.
Common mistake: Allowing auditors, trainers, or assessors to also sign off on certification decisions. It’s efficient—but it violates independence.
Governance & Oversight Mechanisms
A solid governance system proves that your certification body operates under structured oversight—not personal discretion.
Governance typically includes your governing body (often top management or a board) and your impartiality committee.
Their job is to:
Approve policies that affect certification.
Monitor impartiality risks.
Review complaints, appeals, and conflicts.
Ensure independence from commercial pressure.
In one client case, we helped a certification body include external stakeholders—industry experts, clients, and regulators—on their impartiality committee. The result? Assessors commended their transparency and public accountability.
Pro Tip: External members bring fresh perspectives and reduce bias.
Pitfall: Concentrating too much power under one person—especially when that person owns the business and also signs certificates. It’s a red flag for assessors.
Ensuring Independence Within the Structure
Even the best-documented structure fails if independence isn’t visible. Clause 5 ties back to Clause 4 by requiring separation of functions within your organization.
If your body also runs training, consulting, or recruitment, you need clear operational barriers between those functions and certification.
Here’s an example: A small certification body I supported ran both training and certification under the same brand. To maintain independence, we created two distinct reporting lines:
The training manager reported to the commercial director.
The certification decision-maker reported directly to the governing body.
This simple adjustment satisfied assessors that certification decisions weren’t influenced by commercial goals.
Pro Tip: Create an org chart that visually separates your certification function from sales and training. Assessors love visual clarity.
Common mistake: “Dual-hatting” staff—letting someone work in both training and certification. It’s efficient but undermines independence.
Management Commitment and Oversight
Clause 5 doesn’t stop at defining structure—it demands active management oversight.
Top management must ensure the certification body:
Has adequate resources and competent personnel
Operates impartially
Continuously improves its management system
This isn’t a passive role. Assessors will ask to see how top management monitors impartiality, approves decisions, and reviews risks.
During one accreditation project, we included a recurring agenda item in management review meetings: “Review of structural and impartiality risks.” That single addition closed a nonconformity from the previous audit.
Pro Tip: Keep meeting minutes that show management discussing impartiality and structural changes—it’s easy evidence during audits.
Pitfall: Top management delegating responsibility without real involvement. If your CEO’s only signature appears on the policy, assessors will notice.
FAQs
Q1: Can a department within a larger organization become an ISO/IEC 17024 certification body? Yes—but you must show structural and financial independence. That means separate authority, clear reporting lines, and independent decision-making.
Q2: What’s the minimum structure for a small certification body? You’ll need at least: a top management representative, certification decision-maker, technical experts, and an impartiality mechanism (committee or external reviewer).
Q3: Do we need to register as a separate legal company? Not always. But you must demonstrate that your certification body has legal responsibility and authority for its certification decisions, distinct from other business functions.
Build Structure Around Trust, Not Titles
Clause 5 isn’t about creating layers of bureaucracy—it’s about building clarity, accountability, and confidence.
A strong structure ensures your certification body can resist influence, maintain impartiality, and deliver trustworthy results.
After working with dozens of ISO/IEC 17024-accredited bodies, I’ve seen one thing hold true: when your structure is clear, your credibility follows.
Your next step: Review your org chart, update your responsibility matrix, and verify that your decision-making process reflects independence. Your structure isn’t just paperwork—it’s the foundation of every certificate you issue.
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.
