30

Nov

International Standards: Perception Of Impartiality

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Anil Jauhri

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New Delhi | Monday | 1 December 2025

“In God we trust; rest all have to show evidence”.

So goes a saying in the world of accreditations and certifications.

As professional auditors, we pride ourselves in saying that we go by what is called ‘objective evidence’.

And rightly so!

The best auditors are those who rely on hard evidence when they raise findings and not go by their opinions on what the best way of doing a thing is.

However, there is one requirement in international standards which does not only rely on evidence but also to perception – Impartiality.

One of the key pillars on which accreditation and certifications (and indeed regulations) are built is impartiality of the organizations who undertake these activities.

They not only have to be impartial but have to be perceived to be impartial.

I often quote an example in my trainings.

I go and audit my son’s company – it could be a certification body or a laboratory or a manufacturing company or a service company – as per an appropriate standard – let say ISO 9001.

I conduct an extremely professional audit, raise all the non-conformities observed and the report is reviewed by independent experts and found acceptable.

 

Article at a Glance
The article explores the importance of impartiality—both actual and perceived—in accreditation, certification, and conformity assessment. While auditors typically rely on objective evidence, impartiality is unique because it extends beyond evidence to public perception.
Using an example of auditing one’s own son’s company, the author shows how even a professional audit can appear biased due to conflict of interest. Although ISO standards such as 17021-1, 17065, 17024, and 17029 mention impartiality, many references appear in non-auditable sections, creating gaps in enforcement. Issues like related entities offering consulting, training, or validation create risks to credibility, especially in sensitive areas like carbon markets.
The UNFCCC’s Article 6.4 introduces stricter rules—explicit independence requirements and prohibitions on consulting, financing, or training—aimed at preventing conflicts of interest. The article argues that ISO should adopt similarly clear, enforceable standards to strengthen global trust in conformity assessment systems.

 

Is there a problem?

There is – I should not be auditing my son’s company due to inherent conflict of interest which may undermine impartiality of audit.

Was there any evidence that the audit was not impartial? None.

However, the perception would remain – how can one be impartial in evaluating his son? And in public perception this represents an unacceptable practice.

So we need to deal with this perception. Despite factual evidence being to the contrary.

The ISO 17000 series of standards which cover all aspects of conformity assessment, and prescribe requirements for conformity assessment – be it accreditation or certification or inspection or testing – do touch on this aspect of ‘actual or perceived’ impartiality but not always clearly.

ISO 17021-1 for management systems certification bodies states:

4.2.1 Being impartial, and being perceived to be impartial, is necessary for a certification body to deliver certification that provides confidence. It is important that all internal and external personnel are aware of the need for impartiality.

4.8 Risk-based approach

Certification bodies need to take into account the risks associated with providing competent, consistent

and impartial certification. Risks may include, but are not limited to, those associated with:

— the objectives of the audit;

— the sampling used in the audit process;

— real and perceived impartiality;

— legal, regulatory and liability issues…

It can be argued that this is stated among Principles and is not an auditable requirement.

ISO 17065 on product/process certification states:

A.2  Impartiality

A.2.1 It is necessary for certification bodies and their personnel to be to be impartial, and to be perceived as impartial, in order to give confidence in their activities and their outcomes.

Again, technically it can be argued that this is covered in an Informative Annex and hence not auditable.

ISO 17024 on certification bodies for persons states:

A.2.2 It is necessary for certification bodies and their personnel to be and to be perceived to be impartial in order to give confidence in their activities and their outcomes.

It is again in an informative Annex and hence not auditable.

ISO 17029 on Validation and Verification bodies states:

4.3.7 Risk-based approach

Validation/verification bodies need to take into account the risks associated with providing competent, consistent and impartial validation/verification. Risks can include, but are not limited to, those associated with:

a) the objectives of the validation/verification and the programme requirements;

b) competence, consistency and real as well as perceived impartiality;…

It can be argued again that this is stated among Principles and is not an auditable requirement.

However, the intent is clear – that these bodies are not only to be impartial but perceived to be impartial too.

This applies to any entity which is into evaluation – which includes regulators.

Typically, we consider impartiality at three levels:

•     Any related or linked entities and their activities which could affect impartiality

•     Any activities within the entity that might affect impartiality – most international standards do define some prohibitions e.g. management systems certification bodies are barred from engaging in management systems consulting among other prohibitions. Similarly product/process certification bodies are prohibited from being designer or manufacturer of the products they certify or designer or implementer of processes they certify.

•     Any issues arising from personal relationships – of the owners or employees within the entity

If the certification body is owned by a consulting organization – how would that look?

 Or has a subsidiary which is into consulting! How would that look?

Ugly, isn’t it?

Unfortunately, while ISO 17021-1 and ISO 17065 are reasonably explicit in prescribing prohibitions within the legal entity, ISO 17024 and ISO 17029 which is especially relevant today as India develops its carbon market allow conflicting activities – training in case of former and consulting or financing etc in case of latter.

ISO 17029 has a provision which is particularly problematic:

5.3.9 The validation/verification body shall not offer or provide both consultancy and validation/verification for the same claim from the same client.

 

This actually means that a validation and verification body can be a verifier and consultant to the same organization if its for different projects. This has significant bearing on the integrity of the carbon market.

 

In the crudest form, we have had examples of husbands operating a certification body and wives operating consulting organizations since there are no stipulations on related bodies!

 

UNFCCC, under Article 6.4 of the Paris Agreement, recently cracked the whip by imposing stringent requirements for the validation and verification bodies if they wish to operate in the Paris Agreement Crediting Mechanism (PACM).

 

It redefined impartiality itself as:

 

Impartiality – objectivity, both actual and perceived, with regard to the outcome of validation and verification/certification activities;

 

In addition, it added a clear requirement of Independence:

 

29. The DOE shall be an independent body neither owned by nor linked to any entity that is

engaged in prohibited activities as detailed in the paragraph 40 below.

 

And it stipulated explicit prohibitions:

 

40. The DOE and its related body and their personnel shall not engage in the activities below:

(a) Identification, development and/or financing of A6.4 project activities and PoAs and any GHG activities other than A6.4 project activities and PoAs;

(b) Consultancy related to A6.4 projects and PoAs and any GHG activities other than A6.4 project activities and PoAs;

(c) Providing training on A6.4 projects and PoAs and other related topics;

(d) Outsourcing, marketing and tie-up promotion with Article 6.4 consultancy/identification/ development/financing organizations and any consultancy/identification/development /financing organizations engaged in GHG activities other than A6.4 project activities and PoAs;

(e) Offering/payment of commissions or other inducements for promotion or new

business.

 

This means the VVBs can not engage in specific conflicting activities like consulting or financing for GHG projects nor can be linked to any entity which is into prohibited activities.

This goes far beyond any stipulation in ISO standards for conformity assessment and is poised to reshape the carbon market since many countries recognize accreditation of UNFCCC for their national programmes or follow the same standards.

It is hoped that stakeholders around the world and specifically ISO will take note and when they sit down to rewrite ISO standards on conformity assessment, would prescribe similar requirements for accreditation, certification or inspection bodies to enhance the credibility of conformity assessment.  (The Author is   ex-CEO,National Accreditation  Board for Certification Bodies and an international authority on standardisation)

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