Managing Certificate Transfers Between CABs in MSC Audits

What the transfer requirement is, and why it exists

Under Section 4.11 of MSC General Certification Requirements v2.7, certificate holders possess the explicit right to change their Conformity Assessment Body prior to or following certificate issuance. Clause 4.11.1 mandates that certification bodies must respect a client's request to transfer its certification. Clause 4.11.2 requires the succeeding body and preceding body to cooperate throughout the transfer process to ensure complete exchange of certification data.

This transfer framework exists to preserve commercial flexibility for fishery clients while safeguarding the scientific integrity of the MSC program. Changing an auditor must never serve as a mechanism to evade unfulfilled conditions, reset audit timelines, or bypass suspension decisions. Under clause 4.11.3.c and Guidance 4.11, the MSC recognizes only one valid certificate for a given fishery scope at any time, ensuring that the unique certificate code assigned under Section 7.5 remains continuous across certification bodies. Quality managers, compliance leads, and internal auditors must understand these transfer rules to maintain uninterrupted market access during auditor transitions.

Pre-transfer review and due diligence procedures

Executing a certificate transfer requires rigorous due diligence by the succeeding Conformity Assessment Body before accepting the client. Under clause 4.11.3, the succeeding body must record the transfer request, evaluate the client's underlying reasons for changing bodies, and establish whether the client or preceding body will supply required documentation. To comply with General Data Protection Regulation requirements, clause 4.11.3.b and Guidance 4.11.3.a mandate that the succeeding body must obtain a signed non-disclosure agreement waiver from the client before receiving historical certification files.

• Submit a formal transfer request to the succeeding Conformity Assessment Body and execute a written non-disclosure agreement waiver under clause 4.11.3.b.
• Provide the succeeding body with historical surveillance reports, open condition logs, and documentation of any Assurance Services International audit findings under clause 4.11.4.
• Authorize the succeeding body to contact the preceding Conformity Assessment Body to request supplementary certification records under clause 4.11.7.
• Review the pre-transfer findings and proposed audit pathway issued by the succeeding body, providing written acceptance under clause 4.11.10.
• Notify the preceding Conformity Assessment Body in writing of the final intent to transfer and establish the agreed transfer date under clause 4.11.12.

Under clause 4.11.4, the succeeding body must verify that the fishery falls within its accredited scope, confirm certificate authenticity, and evaluate outstanding non-conformities, open conditions, complaints, and Assurance Services International audit findings. Clause 4.11.8 imposes a strict obligation on the preceding certification body to supply all requested information within ten days of receiving the request. Following pre-transfer review, clause 4.11.9 allows the succeeding body to decline the transfer, require a full assessment as a new client, conduct a partial audit focusing on deficient areas, continue the existing surveillance program, or enforce outstanding suspension terms.

Executing the transfer and maintaining condition continuity

Once the pre-transfer review is complete and the client accepts the proposed audit pathway under clause 4.11.10, the parties must finalize the operational transfer. Clause 4.11.12 requires the succeeding body, preceding body, and client to agree upon a formal transfer date when all certification rights and obligations pass to the succeeding body. Under clause 4.11.13, the succeeding Conformity Assessment Body must notify the MSC of the agreed transfer date at least ten days in advance.

On the agreed transfer date, clause 4.11.14 requires the preceding body to cancel the certificate in the MSC scheme database and ensure all client records are fully updated. Simultaneously, clause 4.11.15 dictates that the succeeding body must issue the new certificate in the scheme database on or before the transfer date, guaranteeing no gap in certification validity occurs. Under clause 4.11.16.a, the expiry date of the new certificate must remain identical to the expiry date of the original certificate issued by the preceding body.

Furthermore, clause 4.11.16.b mandates that all conditions and non-conformities raised by the preceding body remain fully applicable unless formally closed or revised through an on-site audit by the succeeding body. Under clause 4.11.16.c, the succeeding body must follow the surveillance audit plan established by the preceding body. Any proposed amendments to the surveillance schedule must be justified, documented, and communicated to the MSC at least 30 days prior to the scheduled audit date.

Complex transfer scenarios and merged certificates

Section 4.11 governs certificate transfers across non-standard operational circumstances under clause 4.11.17. These include transfers requested during initial assessments, reassessments, or transfers originating from applicant bodies, suspended bodies, or certification bodies whose accreditation has been withdrawn or voluntarily cancelled. In all such cases, the succeeding Conformity Assessment Body must execute complete due diligence to verify that standard compliance and integrity are preserved.

When a client group seeks to merge multiple certified fisheries issued by different Conformity Assessment Bodies under Section 7.28 of MSC Fisheries Certification Process v2.3 and v3.0, transfer rules interact directly with merging procedures. Clause 7.28.1.a dictates that if certificates were issued by different bodies, the client must first transfer all certificates to a single Conformity Assessment Body under Section 4.11. Under clause 7.28.2.c.i, the merged certificate must adopt the expiry date of the certificate with the shortest remaining duration, ensuring that certificate cycles are not improperly extended.

Example

A commercial herring client group certified under MSC Fisheries Standard v2.01 decides to transfer its certification to a new Conformity Assessment Body at Year 3 of its five-year cycle. The fishery has two open conditions under Principle 2 regarding habitat impact data. The client group signs a non-disclosure agreement waiver authorizing the succeeding body to access historical records. The succeeding body reviews the file, confirms that no systemic integrity risks exist, and agrees to maintain the existing surveillance schedule.

The preceding body receives the formal transfer request and transmits all historical audit files within eight days, satisfying clause 4.11.8. Ten days prior to the agreed transfer date, the succeeding body submits formal notification to the MSC database under clause 4.11.13. On the agreed transfer date, the preceding body cancels the original certificate entry while the succeeding body simultaneously issues the new certificate under clause 4.11.15. The new certificate retains the original five-year expiry date and carries forward both open conditions with their original milestone deadlines under clause 4.11.16.

Before your audit

• Confirm that your current fishery certificate is valid and not subject to unaddressed withdrawal.
• Execute a written non-disclosure agreement waiver to permit data exchange between certification bodies.
• Collate all previous assessment reports, surveillance audit findings, and open condition logs.
• Verify that the succeeding Conformity Assessment Body holds accredited scope for your target fishery.
• Obtain confirmation that the succeeding body notified the MSC at least ten days before the transfer date.
• Confirm that your original certificate expiry date and surveillance schedule remain unchanged on the new certificate.
• Ensure that all open conditions and Client Action Plan milestones are fully incorporated into the new contract.

Questions people ask

Can a fishery certificate holder change its Conformity Assessment Body at any time?

Yes, under clause 4.11.1 of MSC General Certification Requirements v2.7, Conformity Assessment Bodies must respect a client's request to change its certification body at any point prior to or after certificate issuance.

How much notice must a succeeding Conformity Assessment Body give to the MSC before a transfer?

Under clause 4.11.13, the succeeding Conformity Assessment Body must inform the MSC of the agreed transfer date at least ten days in advance.

Do open conditions or non-conformities disappear when transferring to a new Conformity Assessment Body?

No, under clause 4.11.16.b, all conditions and non-conformities raised by the preceding body remain fully applicable unless formally closed or revised through an on-site assessment by the succeeding body.

What is the deadline for a preceding Conformity Assessment Body to supply requested transfer records?

Under clause 4.11.8, the preceding Conformity Assessment Body must provide all requested transfer information within ten days of receiving the request.

Can an uncertified applicant fishery transfer to a new Conformity Assessment Body during initial assessment?

Yes, under clause 4.11.17.a, transfers during an initial assessment process are permitted and must follow the standardized transfer procedures set out in Section 4.11.

Reference documents

• MSC General Certification Requirements v2.7
• MSC Fisheries Certification Process v2.3
• MSC Fisheries Certification Process v3.0