Top ISO/IEC 17020 Audit Non‑Conformities
Last Updated on October 13, 2025 by Melissa Lazaro
Why ISO/IEC 17020 Audit Non-Conformities Matter
Let’s be real—no inspection body enjoys hearing the words “non-conformity.” They sound heavy, technical, and a little intimidating. But in truth, non-conformities are not failures; they’re feedback. They show you exactly where your management system needs to grow to meet ISO/IEC 17020’s requirements for impartiality, competence, and consistency.
In my experience working with inspection bodies preparing for accreditation, I’ve seen the same pattern again and again: the majority of audit findings come from just a few recurring areas—documentation control, competence evaluation, and impartiality management. Once those are under control, everything else falls into place.
This article breaks down the top ISO/IEC 17020 audit non-conformities—the ones assessors report most often—and explains:
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Why they happen.
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How to correct them effectively.
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And, most importantly, how to prevent them from reappearing in your next audit cycle.
Think of this as your insider’s map of common pitfalls. Whether you’re preparing for your first accreditation or your next surveillance visit, understanding these typical non-conformities will save you stress, time, and corrective-action headaches later.
Now that we’ve set the stage, let’s start by clarifying what exactly a “non-conformity” means under ISO/IEC 17020—and how assessors classify and record them during audits.
Understanding ISO/IEC 17020 Non-Conformities
Here’s something I’ve noticed after reviewing countless ISO/IEC 17020 audit reports: many inspection bodies don’t actually understand how non-conformities are classified. They see a finding, rush to “fix” it, and move on—without grasping its significance. But understanding why a non-conformity was raised, and how assessors define it, is what separates a reactive organization from a resilient one.
Under ISO/IEC 17020, a non-conformity simply means there’s a gap between what should happen according to the standard and what actually happens in your organization. It could be a missing record, an outdated procedure, or a control that’s applied inconsistently.
Non-conformities are usually grouped into three levels of importance:
| Type | Definition | Example | Impact on Accreditation |
|---|---|---|---|
| Major Non-Conformity | A serious failure to meet a requirement that affects impartiality, competence, or operational consistency. | Missing impartiality policy or failure to ensure inspection independence. | Accreditation cannot be granted or maintained until corrected. |
| Minor Non-Conformity | An isolated issue that doesn’t compromise overall compliance but still needs correction. | One outdated calibration certificate found during equipment review. | Must be corrected and verified before the next audit. |
| Observation / Opportunity for Improvement | A potential risk area or weak control that could become a non-conformity later. | Competence evaluation process not fully documented. | Not penalized but should be addressed proactively. |
Pro Tip:
Treat every observation as a gift. It’s an early warning from your assessor. Fixing it before your next audit shows maturity and commitment to continual improvement—two qualities accreditation bodies value highly.
Common Pitfall:
Some teams focus only on closing “major” findings, ignoring the minors and observations. Over time, those smaller issues compound and trigger new majors in the next cycle. The smartest inspection bodies treat every type of finding as an opportunity to tighten their system.
Now that we’ve defined how non-conformities are classified, let’s explore the most common management-system findings that appear in ISO/IEC 17020 audits—and how to prevent them from showing up in yours.
Top ISO/IEC 17020 Management-System Non-Conformities
Here’s what I’ve seen again and again: most inspection bodies struggle not with technical issues, but with management-system controls. The documentation looks fine on paper—policies, manuals, and forms are all there—but when assessors start asking questions, the inconsistencies surface. These “soft” gaps are what cause many ISO/IEC 17020 audit findings.
Let’s break down the most common management-system non-conformities and how to fix them before they reach your assessor’s report.
| Clause / Area | Typical Non-Conformity | Why It Happens | How to Prevent It |
|---|---|---|---|
| 4.1 Impartiality & Independence | No formal impartiality risk analysis, or outdated declarations. | Teams assume impartiality is “understood.” | Conduct an annual impartiality review and maintain a risk register with mitigation measures. |
| 4.2 Confidentiality | Missing confidentiality agreements with staff or subcontractors. | Assumed verbal confidentiality; not documented. | Have every employee and contractor sign confidentiality agreements annually. |
| 4.4 Management System Documentation | Quality manual not updated to reflect current structure or activities. | Manual created years ago and never revised. | Review and update the quality manual at least once a year or after any organizational change. |
| 4.5 Document & Record Control | Uncontrolled or duplicate versions of procedures in circulation. | Poor version control or lack of document master list. | Maintain a document control index with revision numbers, approval dates, and responsible owners. |
| 8.6 Internal Audit & Management Review | Missing audit plan or incomplete records of reviews. | Internal audits treated as a formality; no follow-up actions tracked. | Schedule audits annually, close all findings, and include audit results in management-review minutes. |
Pro Tip:
Before every accreditation audit, perform a quick management-system self-check. Ask yourself:
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Are all procedures aligned with current operations?
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Can we show evidence that impartiality and confidentiality are actively managed, not just written down?
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Have we closed every previous audit finding with documented proof?
Common Pitfall:
Some inspection bodies reuse ISO 9001 documentation, assuming it will satisfy ISO/IEC 17020. It won’t. ISO 17020 has unique technical and impartiality requirements that must be explicitly addressed in your management system.
With your management controls tightened, the next challenge is ensuring your technical operations meet the same level of rigor. Let’s look at the most frequent technical non-conformities assessors uncover—and how to eliminate them early.
Top ISO/IEC 17020 Technical Non-Conformities
If management-system findings are about structure, technical non-conformities are about substance. These are the gaps that directly question your inspection body’s competence—how you perform inspections, validate methods, control equipment, and prove technical credibility. And in ISO/IEC 17020 audits, this is where most organizations lose points.
Here’s a summary of the most common technical non-conformities and how to avoid them:
| Clause / Area | Typical Non-Conformity | Why It Happens | How to Prevent It |
|---|---|---|---|
| 5.1 Personnel Competence | No documented competence criteria or incomplete qualification matrix. | Inspectors trained informally without clear records or authorizations. | Maintain a live competence matrix linked to inspection scopes and individual training evidence. |
| 5.2 Inspection Methods & Procedures | Methods not validated or outdated; staff unaware of revisions. | Procedures copied from clients or standards without internal validation. | Validate every inspection method and maintain signed validation records; review methods annually. |
| 5.3 Equipment & Calibration | Calibration certificates missing, expired, or not traceable to national standards. | Weak calibration tracking system or overreliance on subcontractors. | Keep a calibration register with due dates, traceability data, and responsible staff. |
| 5.4 Inspection Records | Reports incomplete, missing signatures, or lacking traceability. | Templates not standardized; inconsistent documentation habits. | Standardize report templates and train staff on recordkeeping expectations. |
| 5.5 Subcontracting | No evaluation of subcontractor competence or unclear contractual terms. | Subcontracting handled informally without defined controls. | Approve subcontractors formally, record evaluations, and keep signed agreements. |
Pro Tip:
Think like an assessor: every technical claim must be supported by objective evidence. If you say an inspector is competent, show their training file and authorization record. If you claim a method is validated, show the report. ISO/IEC 17020 is all about traceability.
Common Pitfall:
Rushing through technical documentation updates just before the audit. Assessors can tell when evidence is “last-minute.” Maintain your technical records continuously—calibration logs, competence updates, and validation summaries should always be current, not refreshed the week before accreditation.
Now that we’ve covered the most common management and technical gaps, it’s time to dig deeper into why they keep recurring—and how to identify the root causes behind these non-conformities before they repeat.
Root Causes Behind Recurring ISO/IEC 17020 Non-Conformities
Here’s the uncomfortable truth: most ISO/IEC 17020 non-conformities don’t happen because teams lack knowledge—they happen because systems drift over time. Procedures are written once and forgotten. Internal audits become routine. Staff assume “everything’s fine.” Before you know it, small lapses accumulate into audit findings.
When you analyze dozens of accreditation reports side by side, the same root causes emerge. They usually fall into three main categories:
| Root Cause Category | Description | How It Creates Recurring Non-Conformities |
|---|---|---|
| Weak Internal Audits | Internal audits focus on checklists, not clause interpretation or evidence quality. | Gaps go unnoticed for years because auditors don’t challenge the system deeply enough. |
| Insufficient Training & Awareness | Staff don’t fully understand ISO/IEC 17020 requirements or their role in compliance. | Procedures exist on paper but aren’t consistently followed in practice. |
| Poor Corrective-Action Follow-Up | Findings are closed quickly but effectiveness isn’t verified. | The same issues reappear in the next surveillance audit. |
Other secondary factors often play a role too:
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Documentation fatigue – Teams delay updates because revisions feel tedious.
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Role overlap – Impartiality risks increase when responsibilities aren’t clearly defined.
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Reactive management – Actions happen only before audits, not continuously.
Pro Tip:
After each internal or external audit, take one extra step—trend your findings. Create a simple spreadsheet listing each clause with the number of findings over time. If you see the same clause popping up every cycle, you’ve found a systemic weakness, not a one-off error.
Common Pitfall:
Many organizations confuse symptom with cause. For instance, if calibration certificates keep expiring, the problem isn’t the technician—it’s the lack of a monitoring system. Fix the system, not just the event.
Understanding these root causes is what turns reactive corrections into proactive improvement.
Next, let’s walk through how to close these findings effectively—with a solid corrective-action process that satisfies any accreditation body.
Corrective and Preventive Actions for ISO/IEC 17020 Non-Conformities
Here’s what separates a mature inspection body from one that keeps chasing the same findings: how they handle corrective actions. Closing a non-conformity isn’t about replying to the assessor quickly—it’s about proving that the issue won’t happen again.
A strong corrective-action process under ISO/IEC 17020 should always follow a clear, evidence-driven sequence.
| Step | Action | Purpose / Output |
|---|---|---|
| 1. Identify the Non-Conformity | Restate the exact finding from the audit report, linked to the ISO/IEC 17020 clause. | Ensures clarity and alignment with the assessor’s observation. |
| 2. Analyze the Root Cause | Use the “5 Whys” or fishbone analysis to go beyond the surface. | Prevents superficial fixes and targets the system weakness. |
| 3. Define Corrective Actions | Decide what needs to change—document, process, training, or control mechanism. | Addresses the cause, not the symptom. |
| 4. Implement and Record Evidence | Update procedures, train staff, or revise templates; attach proof. | Demonstrates action and traceability. |
| 5. Verify Effectiveness | Review results after implementation (e.g., re-audit, spot check). | Confirms the issue is resolved and won’t recur. |
| 6. Record & Communicate Results | Update your corrective-action log and inform top management. | Closes the loop and supports continual improvement. |
Example:
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Finding: Missing impartiality risk assessment (Clause 4.1).
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Root Cause: Responsibility not assigned; no defined review frequency.
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Corrective Action: Assign impartiality committee leader, create annual review schedule, update management-review agenda.
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Verification: New impartiality report completed and reviewed during management meeting.
Pro Tip:
Never submit vague corrective actions like “staff were reminded” or “procedure updated.” Assessors want tangible evidence—revised documents, completed forms, signed training logs, or meeting minutes.
Common Pitfall:
Teams often stop after implementation and forget verification. But if you can’t show proof of effectiveness, assessors will mark the same clause again in the next cycle. Always confirm the change has worked—usually one to three months later.
By treating corrective and preventive actions as part of your continuous improvement loop—not just a compliance checkbox—you’ll turn every finding into an opportunity to strengthen your system.
Now, let’s explore how to reduce non-conformities before they even occur, using proactive measures that keep your inspection body audit-ready year-round.
How to Reduce ISO/IEC 17020 Non-Conformities Before the Next Audit
Here’s what I tell every client after an accreditation audit: the easiest way to pass the next one is to treat every day like audit day. Non-conformities don’t appear overnight—they build up slowly when procedures are ignored, records aren’t updated, or competence reviews are postponed. Prevention is always simpler than correction.
Here’s how high-performing inspection bodies keep non-conformities under control all year long:
| Preventive Measure | Why It Works | How to Apply It |
|---|---|---|
| Quarterly Internal “Mini-Audits” | Keeps the system alive between annual audits. | Audit one or two clauses each quarter instead of waiting a full year. Record findings briefly but consistently. |
| Live Competence & Calibration Records | Avoids last-minute document updates. | Use a shared log (spreadsheet or software) showing expiry dates and responsible persons. |
| Mock Assessments | Simulates real accreditation pressure. | Invite an external consultant or senior staff to perform a one-day mock audit. |
| Management Review Follow-Ups | Ensures improvement actions are tracked. | Include an “open actions” list in every management-review meeting and verify closure dates. |
| Document-Control Alerts | Prevents outdated procedures from circulating. | Set reminders for annual policy reviews and version renewals. |
Pro Tip:
Train your team to recognize “red flags” in daily work. If an inspector notices a missing calibration label or an unapproved report format, that’s the moment to act—not when the assessor is sitting across the table.
Common Pitfall:
Many organizations treat prevention as an extra task rather than part of daily operations. When compliance is built into routines—weekly checks, quick internal reviews, structured documentation updates—audits stop being stressful.
Quick Readiness Checklist:
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All procedures reviewed and approved within the past 12 months.
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Competence matrix and training records up to date.
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Calibration certificates current and traceable.
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Internal audit findings closed with verification evidence.
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Management review conducted and actions tracked.
The more consistently you apply these habits, the fewer findings you’ll face—and the more confident your team will be when assessors arrive.
Next, let’s address a few frequently asked questions about ISO/IEC 17020 non-conformities—what to expect, how to respond, and what really matters to accreditation bodies.
FAQs – ISO/IEC 17020 Non-Conformities
Q1: How many non-conformities are “acceptable” during an ISO/IEC 17020 audit?
There’s no fixed number—what matters is severity and response. A few minor findings are normal, even for well-managed inspection bodies. What assessors look for is your ability to respond promptly and effectively. A single major non-conformity, however—especially one involving impartiality, competence, or traceability—can delay or suspend accreditation until it’s corrected.
Q2: Can we challenge or appeal a non-conformity finding?
Yes, you can—but do it respectfully and with evidence. If you believe a finding is based on a misunderstanding or incomplete context, provide clear records, logs, or procedures that demonstrate compliance. Accreditation bodies usually allow written appeals or clarification requests within a specific timeframe (typically 15–30 days after the audit report).
Q3: How soon must corrective actions be submitted after the audit?
Most accreditation bodies require you to submit your corrective-action plan within 30 to 60 days of receiving the audit report. However, it’s best to act immediately. Start drafting your plan within the first week, even if you’re still finalizing evidence—this shows initiative and control.
Q4: What’s the difference between a correction and a corrective action?
A correction fixes the immediate issue (e.g., calibrating overdue equipment). A corrective action eliminates the root cause (e.g., implementing a calibration reminder system). Assessors value the latter—it proves your system prevents recurrence, not just patches problems.
Q5: Will non-conformities always affect our clients’ perception or operations?
Not necessarily. Accreditation bodies don’t publish your findings. What matters is how quickly you close them. In fact, clients often appreciate transparency when you can demonstrate a mature, traceable corrective-action system—it builds trust.
Conclusion & Next Steps
Here’s the bottom line: non-conformities aren’t the enemy—they’re the roadmap. Every finding, big or small, tells you exactly where your inspection body can strengthen its system. The difference between organizations that struggle and those that thrive is simple: the strong ones learn from every audit, adapt fast, and treat compliance as a living process, not a yearly chore.
By now, you’ve seen the full picture:
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What non-conformities mean under ISO/IEC 17020 and how assessors classify them.
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The most common management and technical findings that repeatedly appear in audit reports.
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The root causes behind them—and the structured way to perform root-cause analysis and corrective actions.
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The preventive systems that keep your inspection body audit-ready all year long.
If there’s one habit to build after reading this, it’s continuous verification. Don’t wait for the next audit cycle—review, update, and check effectiveness regularly. That rhythm turns compliance from a reaction into a culture.
When your records are current, your team understands their roles, and your procedures actually reflect what you do every day, assessors will notice. Accreditation becomes confirmation—not correction.
To take the next step:
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Download the ISO/IEC 17020 Non-Conformities Corrective-Action Tracker to start managing your findings systematically.
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Explore the ISO/IEC 17020 Documentation Toolkit for ready-to-use templates covering impartiality, competence, and inspection methods.
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Or, enroll in the ISO/IEC 17020 Audit Readiness & Non-Conformity Management Course to train your team on closing findings efficiently.
In the end, what matters most isn’t having a perfect audit—it’s having a system that continuously improves. That’s what real compliance looks like.
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.
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