Last Updated on November 12, 2025 by Melissa Lazaro

Why Structure Defines Credibility in Product Certification

When I review a certification body’s system, I always start with one question: “Who really makes the certification decisions?”
You’d be surprised how often that question causes silence.

Clause 5 of ISO/IEC 17065 is where structure meets accountability. It ensures your organization is clearly defined, legally recognized, and set up so no single person or interest can influence results.

If you’re building or refining your certification body, this article will help you:

• Understand what “structural requirements” truly mean
• Define clear authority and independence within your team
• Avoid the common conflicts that make assessors raise red flags

What Clause 5 Really Means – Structure with Accountability

Clause 5 isn’t just about drawing an org chart. It’s about demonstrating who’s responsible for what—and proving that your decision-makers act independently.

Think of it as your internal blueprint. It shows how leadership, auditors, committees, and support staff interact without stepping on each other’s impartiality.

Pro Tip: If you can’t explain your reporting lines in under a minute, your structure is probably too complicated.

Common Mistake: Letting one person wear too many hats—like managing audits, sales, and certification decisions. It’s efficient on paper but a nightmare for impartiality.

Legal Identity & Governance – Establishing Your CB’s Foundation

Clause 5.1 starts with the basics: your certification body must be a legally identifiable entity.
That means registration documents, ownership details, and governance structures must be up-to-date and transparent.

Accreditation bodies want to know exactly who holds the legal responsibility for certification decisions. If your parent company or holding group changes, update your documentation immediately.

Pro Tip: Keep a “legal dossier” with your registration, shareholder info, and organizational charter. When assessors ask for proof, you’ll have it ready in seconds.

I worked with one CB that nearly lost accreditation after a corporate merger blurred accountability. A simple governance update—clarifying who legally signed certificates—resolved it instantly.

Organizational Structure – Clarity in Roles and Authority

Clause 5.2 requires certification bodies to define responsibilities and authorities clearly.
Every key role—evaluation, review, decision-making, appeals—should be distinct and traceable.

Here’s the structure that consistently satisfies assessors:

• Certification decision team: independent from audit and sales functions.
• Impartiality committee: oversees conflicts and risk.
• Technical review staff: ensure audit evidence supports decisions.
• Complaints & appeals handler: separate from evaluation staff.

Pro Tip: Create a one-page org chart showing who reports to whom and where independence lines sit. It tells auditors everything at a glance.

Common Mistake: Combining certification and sales under one manager. Even if intentions are good, it immediately raises questions about impartiality.

Independence and Impartiality Interface – Preventing Conflicts of Interest

Clause 5 links directly to Clause 4. A sound structure is what keeps impartiality intact.

Your certification body must be free from undue influence—especially if you’re connected to other organizations that provide consulting, testing, or manufacturing.

Example: A CB shared facilities with a testing lab. To maintain independence, they created separate reporting lines, restricted data access, and added a cross-audit between departments. That small structural change turned a major non-conformity into a clean finding at reassessment.

Pro Tip: Document all shared resources and how conflicts are prevented. Transparency always earns trust with assessors.

Decision-Making and Operational Control – Who Approves What

Clause 5.3 is crystal clear: the people who audit or evaluate can’t be the ones deciding certification outcomes.
This separation prevents bias and ensures objectivity.

In practice, it means:

• Auditors gather evidence and submit reports.
• Reviewers check completeness and compliance.
• Independent decision-makers approve or reject certification.

Pro Tip: Use a documented “Decision Authority Matrix.” It lists who can approve what type of decision and under which conditions. It also serves as quick proof during audits.

Common Mistake: Small CBs often let auditors double as reviewers “to save time.” It’s efficient now—but non-compliant later.

Managing Subsidiaries, Branches, and Subcontractors

Many certification bodies operate through multiple sites or subcontract certain evaluations.
Clause 5 demands that, no matter how widespread your network is, you maintain central control and consistent practices.

Key expectations:

• Each branch follows the same procedures and policies.
• Headquarters retains oversight of all certification decisions.
• Subcontractors are formally approved, monitored, and reviewed.

Pro Tip: Conduct periodic internal audits across branches and subcontractors. Record how you verify consistency—it’s the easiest way to prove control.

Example: A CB with five regional offices unified its procedures under a single QMS manual. During the next surveillance visit, the assessor noted “excellent consistency across sites.”

Documentation and Evidence of Structure

Assessors love tangible proof. To demonstrate Clause 5 compliance, keep these ready:

• Updated organizational chart
• Job descriptions with assigned authorities
• Impartiality-committee charter and minutes
• Conflict-of-interest matrix
• Certification-decision procedure and records

Pro Tip: Reference each document in your Quality Manual so assessors don’t need to dig for evidence.

Common Mistake: Forgetting to update charts after promotions or resignations. Outdated roles instantly trigger minor non-conformities.

Continuous Oversight – Keeping Structure Effective

Even a solid structure weakens if it’s never reviewed. Schedule management reviews and internal audits that specifically evaluate whether your structure still supports impartiality and accountability.

Pro Tip: Treat structure as a living system—update it when ownership, scope, or staffing changes.

One client revised its org chart only after every third year. When new technical managers joined, roles blurred, and they received a non-conformity for unclear authority lines. Now, they update after every staff change—and haven’t had an issue since.

FAQs – Clause 5 Clarified

Q1: Can a certification body share ownership with a testing or inspection company?
Yes—but only if you maintain documented independence: separate management, financial control, and decision processes.

Q2: Is a documented org chart mandatory?
Absolutely. It’s the simplest way to demonstrate role clarity and independence.

Q3: Can auditors make certification decisions?
No. Certification decisions must be made by individuals not involved in the evaluation or audit of that client.

Conclusion – Build a Structure That Inspires Confidence

Your structure tells clients and accreditation bodies a lot about you—especially whether you can make impartial, consistent decisions.

A well-defined system with clear authority lines isn’t bureaucracy; it’s your credibility map.

At QSE Academy, we’ve helped hundreds of certification bodies design structures that pass accreditation without a single structural non-conformity.

If you’re reviewing your setup, start here:
→ Download the ISO/IEC 17065 Structural Compliance Checklist
or
→ Book a consultation to map your certification body’s structure with an expert.