Third-party certification must provide an independent assessment. If the same person designs a solution and then evaluates it, self-review creates a threat to impartiality. Auditors may explain requirements and the certification process, but should not take over the client's system design.
Why should an auditor not write a client's procedure and then assess it?
Third-party certification must provide an independent assessment. If the same person designs a solution, chooses how to meet a requirement and then evaluates that work, a threat to impartiality arises. An auditor may explain a requirement and the certification process, but the boundary is crossed when they take on the role of a consultant designing the client's system.
1. Auditors and consultants have different objectives
A consultant helps an organisation design or improve a solution. They may propose a specific procedure, recording system, calculation method or allocation of responsibilities.
An auditor assesses whether the organisation's solution meets the scheme requirements. This is a different role with different responsibilities.
2. Impartiality does not prevent communication
An auditor may explain a requirement, request evidence, describe a non-conformity, identify missing information or explain the certification process.
They should not move on to instructions such as: “Do exactly this, use this form and complete these fields, and I will close the non-conformity.”
3. A conflict of interest can arise before the audit
If an auditor previously provided paid services to design the client's traceability system, reconciliation, procedures or documentation, subsequently assessing that same system independently may be problematic.
The certification body should identify these relationships and apply measures to manage risks to impartiality.
4. Paying for an audit does not buy a positive outcome
The client pays for a professional assessment and certification process, not a guarantee of receiving a certificate.
The price, the client's size, the length of the relationship and commercial pressure should not influence the assessment of evidence or the decision.
5. Explaining a requirement differs from designing a solution
An explanation might be: “The requirement calls for batch traceability from input to output.” Consultancy might be: “Create field X in your ERP, add a label in this format and implement this procedure.”
The first describes the required outcome. The second selects a particular implementation method for the client.
6. General training differs from client-specific advice
General training on scheme requirements, common mistakes or audit structure may be possible, provided it does not become the design of a solution for a specific organisation.
The more closely the material addresses the client's actual documents and implementation decisions, the greater the risk of entering a consultancy role.
7. A non-conformity does not authorise the auditor to write the corrective action
An auditor may explain why a submitted response does not resolve the problem. They should not write the company's root cause analysis and corrective action.
The organisation must retain responsibility for its own system and the way it meets the requirement.
8. Technical review and certification decisions also require independence
Impartiality extends beyond the person conducting the audit. Reviewers and decision-makers must also act without conflicts of interest and in accordance with their assigned roles.
This is why certification is a system rather than the opinion of one specialist.
9. The practical benefit to the client is substantial
An independent audit can be more demanding, but its market credibility is stronger. Users of the certificate can have greater confidence that the outcome was not designed by the same person who approved it.
Impartiality therefore protects both the certification body and the credibility of the certified organisation.
10. How a company can prepare without consultancy from its auditor
It can use public RecyClass documentation, its own specialists, independent consultants who will not subsequently participate in the assessment, general training and internal reviews.
The essential point is to separate the person helping design the system from the person who will assess it independently.
11. How to ask questions without requesting consultancy
Instead of asking “How should we do this?”, ask “Which requirement applies?”, “What type of evidence does the scheme expect?” or “Does this document address the relevant clause?”
This provides clarification without transferring responsibility for designing the solution to the auditor.
12. Impartiality is part of ISO/IEC 17065 and RecyClass
RecyClass requires certification bodies to have mechanisms ensuring the impartiality of the organisation and its auditors. ISO/IEC 17065 also treats impartiality as a fundamental part of credible certification.
The boundary between auditing and consultancy is therefore part of the conformity assessment system, not simply a matter of working style.
FAQ
Can an auditor explain how to understand a requirement?
Yes. They may explain its wording and context. They should not design a specific solution for the client which they will later assess themselves.
Can a certification body provide training?
This may be possible while respecting impartiality requirements. Training should not become individual system design for a client subsequently certified by the same organisation without appropriate safeguards.
Can a consultant later audit the same company?
This requires an assessment of conflicts of interest and the certification body's rules. Separating consultancy from independent assessment is a sound approach.
Can an auditor give an example?
A general example illustrating a requirement can help. The problem arises when it becomes specific implementation instructions for the client being assessed.
Why should a client want this separation?
Because an independent certificate is more credible to customers, buyers and other interested parties.
Useful documents
Almaland's Quality and Impartiality Policy is available in the Documents section.