Why ISO/IEC 17024 Non-Conformities Keep Reappearing (and How to Prevent Them)
After sitting through dozens of ISO/IEC 17024 accreditation audits, one thing’s clear: most certification bodies don’t fail because they lack documentation—they stumble because their systems aren’t consistently applied.
If you’ve ever wondered why these non-conformities keep recurring or how to finally break the cycle, this guide is for you. We’ll unpack the top issues, explain why they happen, and show exactly how to fix them—without unnecessary jargon or theory.
Understanding What ISO/IEC 17024 Non-Conformities Really Mean
Let’s start simple. A non-conformity (NC) isn’t an accusation—it’s a sign that something in your system doesn’t fully meet a clause in the standard.
There are three main types you’ll encounter:
Major NC: A systemic failure—like missing impartiality evidence or no documented competence criteria.
Minor NC: A smaller gap—perhaps one missing record or an isolated lapse.
Observation: A potential risk that could become a problem later.
Assessors don’t just count documents; they assess risk and consistency. So if a gap could affect impartiality, fairness, or reliability of certification, it’s going to be flagged.
Pro tip: Always ask your assessor to cite the exact clause for each finding. That small question makes your corrective action plan sharper and faster to close.
Top Non-Conformity #1: Weak Impartiality Management (Clause 4)
Impartiality is the heart of ISO/IEC 17024—and also the most common area where certification bodies slip.
Typical findings include:
The impartiality committee hasn’t met in months (or ever).
Conflict-of-interest forms aren’t updated.
No risk analysis showing how impartiality threats are managed.
These may sound minor, but they point to a deeper issue—your decision-making process might not be seen as fair or independent.
Pro tip: Review impartiality risks annually, even if nothing has changed. Assessors expect to see active risk management, not a file gathering dust.
A few years ago, a certification body I worked with had an assessor certify their former colleague. The risk was documented but never reviewed—resulting in a major NC. After revising their impartiality procedure and committee frequency, they passed their re-audit cleanly.
Avoid this pitfall: Treating impartiality as paperwork. It’s a live system that protects your credibility.
Top Non-Conformity #2: Inadequate Assessor Competence Records (Clause 6)
If impartiality is the heart, competence is the backbone of ISO/IEC 17024. Without it, the entire certification process loses value.
Common findings:
Missing or incomplete competence matrices.
No formal evaluation of assessor performance.
Outdated qualification or training records.
It’s not enough to hire experts—you need to prove their competence through documented evidence.
Pro tip: Create a simple “Assessor Competence File” for each person. Include their CV, qualifications, training certificates, observation results, and final approval notes.
Common mistake: Storing all records in generic HR folders. Assessors expect a role-specific structure showing how you validate competence for each scheme.
One of my clients had highly qualified assessors but no documentation of performance reviews. They received a major NC despite having top talent. Documentation matters as much as ability.
Top Non-Conformity #3: Poor Exam Design and Validation (Clause 7)
Exams are the proof of competence—so naturally, they attract heavy scrutiny.
Typical issues:
No documented exam validation or review process.
Outdated or untracked item banks.
No psychometric or statistical analysis of exam performance.
Pro tip: Keep a version-controlled Exam Validation Log. Include each update date, reviewer, reason for change, and approval signature. It shows control and consistency.
Pitfall: Treating exam design like an academic exercise instead of a controlled process. Under ISO/IEC 17024, every question and scoring method must be defensible and traceable.
I once saw a certification body reuse outdated questions for five years without analysis. Candidates complained about inconsistent difficulty—and the assessor agreed. They had to rebuild their entire exam validation process from scratch.
Top Non-Conformity #4: Uncontrolled Certification Decisions (Clause 9)
This one often surprises people. Many certification bodies handle exams well but fail at controlling the decision step.
Common problems include:
Assessors making certification decisions instead of an independent panel.
Missing approval signatures or rationale in decision records.
No documented separation between evaluation and decision.
Pro tip: Use a Certification Decision Log. Record assessor input, independent review, decision outcome, and justification. This one document solves half of all Clause 9 findings.
Pitfall: Automating approvals without human review. Some systems trigger certificates immediately after exams—completely bypassing independence. Assessors call that a “major.”
One client had to revoke multiple certificates because of this issue. They later introduced a two-step approval workflow and haven’t had a single NC since.
Top Non-Conformity #5: Weak Management System Implementation (Clauses 8 & 9)
Even strong certification bodies can fall short here. Management system gaps often emerge when leadership sees the ISO system as “administration” instead of “strategy.”
Frequent findings:
Internal audits not performed or too shallow.
Management reviews missing data analysis or improvement actions.
Complaints log incomplete or unverified.
Repeated findings with no root-cause analysis.
Pro tip: Integrate your management review with real operational data—complaints, candidate numbers, pass/fail ratios, and feedback trends. It turns the meeting into a decision-making tool, not a formality.
Pitfall: Doing internal audits only before accreditation. Assessors can tell when it’s a one-time show.
A body I assisted used to rush through annual reviews in two hours. Once they switched to quarterly data-driven reviews, their system matured fast—and their next audit had zero findings.
Preventing Repeat Non-Conformities: A Continuous-Improvement Approach
The most frustrating findings are the ones that repeat. When that happens, it’s rarely a documentation issue—it’s a weak root-cause process.
Here’s a better approach:
Identify the real cause. Go beyond “human error.” Look for systemic gaps.
Implement preventive actions. Fix the process, not just the symptom.
Track effectiveness. Verify that the same issue doesn’t reappear in future audits.
Pro tip: Keep a Corrective Action Register that links each NC to its root cause, assigned person, and closure evidence.
Avoid this trap: Closing findings just to meet deadlines. Accreditation bodies look for evidence that actions were effective, not rushed.
When you start viewing NCs as lessons, your system matures naturally—and audits become smoother every year.
FAQs – Quick Answers About ISO/IEC 17024 Non-Conformities
Q1: What’s the fastest way to close a major non-conformity? A solid corrective-action plan with clear root-cause analysis. Don’t rush—address the issue properly, and submit progress updates within the agreed timeframe.
Q2: How can we prevent repeat findings in future audits? Keep an internal NC tracker, assign accountability, and review closure effectiveness in your management meetings.
Q3: Are “observations” serious? Yes. They’re early warning signs. Treat them now, and you’ll prevent tomorrow’s non-conformities.
Turning Audit Findings Into Strengths
Every finding tells a story about where your system can grow. Instead of dreading them, use them.
I’ve seen certification bodies transform after one tough audit—because they treated every NC as a roadmap for improvement.
Start today: review your last audit report, build a live corrective-action tracker, and make follow-ups part of your monthly routine.
And if you want a head start, download QSE Academy’s ISO/IEC 17024 Non-Conformity & Corrective-Action Tracker Template—it’s designed to help you stay one step ahead before 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.
