Last Updated on December 19, 2025 by Melissa Lazaro

Why Structure Is One of the First Things Assessors Test

Here’s what I’ve noticed over the years:
Most PT providers don’t fail assessments because of technical competence. They stumble because their structure isn’t clear.

Clause 5 looks harmless.
Legal entity. Roles. Responsibilities.

But during assessments, this is where assessors start asking:

• “Who is ultimately responsible for PT activities?”
• “Who can override technical decisions?”
• “How are PT activities separated from commercial interests?”

If your answers aren’t consistent, Clause 5 quickly turns into findings.

This article breaks down what ISO/IEC 17043 really expects when it comes to structure—and how to explain it confidently during an assessment.

Legal Entity and Organizational Identity Requirements Under ISO/IEC 17043

Clause 5 requires the PT provider to be a legal entity, or a clearly defined part of one.

Sounds straightforward. In practice, this is where confusion starts.

I’ve worked with:

• Universities running PT schemes
• Government departments offering PT services
• Private companies combining PT, testing, and consulting

All of them can comply—but only if legal responsibility is crystal clear.

Assessors want to know:

• Who holds legal accountability for PT activities?
• Who signs contracts?
• Who answers when something goes wrong?

Pro tip:
Don’t overexplain your corporate structure. Just clearly show where PT sits and who is legally responsible.

Common mistake:
Using vague phrases like “part of the organization” without defining authority or accountability.

Organizational Structure and Authority for PT Providers

Now that we’ve covered legal identity, let’s talk about structure.

Assessors don’t care about fancy org charts.
They care about decision-making authority.

They want to see:

• Where PT activities sit within the organization
• Who has authority over scheme design and reporting
• How PT decisions are protected from commercial pressure

I’ve seen assessors ask simple questions that reveal everything:
“Who approves the final PT report?”
“Who can stop a scheme if something goes wrong?”

If the answers differ between staff, that’s a red flag.

Pro tip:
Your organizational chart should reflect how work actually happens, not how it looks in theory.

Common pitfall:
Copying a generic corporate org chart that doesn’t explain PT authority.

Responsibility, Accountability, and Independence in ISO/IEC 17043 Clause 5

Clause 5 makes one thing very clear:
Responsibility for PT activities cannot be vague or shared “in spirit.”

Someone must be accountable.

That includes responsibility for:

• Compliance with ISO/IEC 17043
• Technical validity of PT schemes
• Final decisions affecting participants

In small organizations, roles are often combined. That’s acceptable—but it must be justified.

I’ve seen assessors accept combined roles when:

• Responsibilities are clearly defined
• Independence is protected
• Risks are acknowledged and controlled

Pro tip:
If one person wears multiple hats, explain how risks are managed, not why it’s unavoidable.

Common mistake:
Assuming size excuses unclear accountability. It doesn’t.

Preventing Conflicts of Interest Through Structural Controls

Clause 5 connects directly to Clause 4 on impartiality.

Structure itself can create conflicts.

Examples I see often:

• PT managers reporting directly to sales managers
• Scheme designers influenced by commercial targets
• PT activities bundled with consulting services

None of these automatically mean nonconformity.
But they must be controlled.

Structural safeguards may include:

• Independent reporting lines
• Clear separation of roles
• Oversight mechanisms

Real-world insight:
Assessors often uncover structural risks during interviews—not document reviews.

Pro tip:
Be ready to explain why your structure doesn’t compromise impartiality, even if it looks risky at first glance.

Documentation and Evidence for Clause 5 Compliance

When it comes to evidence, less is usually more.

Assessors typically expect:

• Proof of legal status
• An organizational chart
• Role descriptions relevant to PT activities

That’s it.

I’ve seen providers overwhelm assessors with:

• Entire corporate manuals
• Irrelevant HR procedures
• Group-level policies that don’t apply to PT

That doesn’t help—and sometimes creates more questions.

Pro tip:
Only present documents that directly explain PT structure and responsibility.

Common mistake:
Assuming more documentation equals stronger compliance.

Demonstrating Structural Compliance During ISO/IEC 17043 Assessments

This is where everything comes together.

Assessors verify Clause 5 through:

• Document review
• Interviews with management and technical staff
• Cross-checking answers for consistency

I’ve seen solid systems fall apart because:

• The org chart said one thing
• Staff described another
• Reality was different again

Pro tip:
Before the assessment, walk your team through:

• Who is responsible
• Who has authority
• How PT decisions are protected

Common pitfall:
Treating Clause 5 as “management-only” and not briefing technical staff.

FAQs on ISO/IEC 17043 Clause 5: Structural Requirements

Does a PT provider need to be a separate legal entity?

Not necessarily. But legal responsibility for PT activities must be clearly defined and demonstrable.

Can small PT providers combine multiple roles?

Yes. As long as independence and accountability are maintained and risks are managed.

Do organizational charts need to be complex?

No. They need to be accurate, clear, and aligned with how decisions are actually made.

Conclusion: Clause 5 Is About Clarity, Not Complexity

Here’s the key takeaway.

ISO/IEC 17043 Clause 5 isn’t asking for a perfect corporate structure.
It’s asking for clarity.

Assessors want to see:

• Clear legal responsibility
• Clear authority
• Clear accountability

When structure supports impartial, independent PT activities, Clause 5 becomes straightforward.

Your next step:
Review your organizational structure and role definitions now—before the assessor starts asking questions.