When organisations seek ISO 17100 certification, most of the attention falls on translators, revisers, and the four mandatory workflow stages. The project manager role, however, is where the entire operation holds together or falls apart. ISO 17100 does not treat the project manager as an administrative support function. The standard assigns this role specific competence requirements, defined responsibilities across pre production, production, and post production, and accountability for ensuring the workflow is followed on every single project. Understanding how the project manager role works in an ISO 17100 translation project is essential for translation companies pursuing certification, quality managers overseeing compliance, and auditors assessing conformity against the standard.
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This article walks through the project manager duties clause by clause, explains what conformity looks like in practice, and identifies the common gaps that certification auditors find when this role is not properly defined or resourced.
What ISO 17100 Says About the Project Manager
ISO 17100 defines the project manager as the person responsible for managing the translation project from initial enquiry through to delivery and post production follow up. This is not a generic title. The standard places the project manager at the centre of every interaction between the client, the translation service provider, and the production team.
The competence requirements for the project manager are set out in Clause 3.1.5 of the standard. Unlike translators, who must demonstrate linguistic and subject matter competence through formal qualifications or documented equivalent experience, the project manager is assessed against a different set of criteria. These include project management skills, knowledge of the translation process, familiarity with the tools and technologies used in production, and the ability to communicate effectively with both clients and production personnel.
If you want a detailed breakdown of how these competence requirements apply to the project manager alongside the reviser and reviewer roles, the article on reviser, reviewer and project manager competence requirements in ISO 17100 covers this in full. The short version is that competence must be documented. A job title alone does not satisfy the standard.
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Pre Production: Where the PM Role Begins
The project manager's responsibilities begin before a single word is translated. ISO 17100 Clause 4 covers pre production activities, and the PM is accountable for most of them.
Receiving and Reviewing the Enquiry
When a client submits a translation request, the project manager is responsible for reviewing it to determine whether the translation service provider can actually meet the requirements. This involves assessing the source language, the target language, the subject matter, the volume, the required delivery date, and any specific instructions from the client.
This is not a rubber stamp exercise. If the organisation does not have a qualified translator available for the language pair and subject matter, the project manager must either decline the project or make arrangements to bring in a qualified resource. Accepting a project and then assigning it to an unqualified translator is a nonconformity under ISO 17100, and it is one that auditors find regularly.
Preparing the Quotation and Agreement
The project manager is responsible for preparing the quotation and ensuring that the client agreement captures all the relevant project parameters. ISO 17100 Clause 4 requires that the agreement document specific items, including the language pair, the subject matter, the scope of services, the delivery format, any reference materials or glossaries to be used, and the confidentiality requirements.
In practice, this means the PM must have a template or process for capturing this information consistently. An agreement that simply states the price and delivery date does not satisfy the standard. Auditors will ask to see a sample of client agreements and will check whether the required elements are present. The article on ISO 17100 Clause 4 pre production provides a thorough explanation of what these agreements must contain.
Assigning Qualified Resources
One of the most critical pre production duties is resource assignment. The project manager must select a translator who meets the competence requirements set out in Clause 3.1.1 of the standard. This means checking that the assigned translator holds a recognised qualification or has documented equivalent experience for the specific language pair and subject matter.
The PM must also assign a reviser who is a different person from the translator. ISO 17100 makes revision by a second person a mandatory requirement, not an optional quality step. The project manager is accountable for ensuring this separation exists on every project. Assigning the same person to translate and revise their own work is a major nonconformity.
Beyond qualifications, the PM must also consider workload and availability. A qualified translator who is overloaded with concurrent projects is a risk to delivery quality and schedule. Managing this is a practical judgement call that sits squarely with the project manager.
Production: Keeping the Workflow on Track
During production, the project manager shifts into an oversight and coordination role. ISO 17100 Clause 5 defines the mandatory workflow stages, and the PM is responsible for ensuring they occur in the correct sequence with the correct personnel.
Monitoring Progress Against the Agreement
The PM must track whether the project is progressing according to the agreed schedule and scope. If the source material changes after the project has started, the PM is responsible for assessing the impact on cost, timeline, and resource requirements, and for communicating that impact to the client before proceeding.
This is a common failure point in smaller translation companies where the PM role is informal or combined with other functions. When scope changes are absorbed without formal acknowledgement, the organisation loses the documented trail that demonstrates the workflow was managed in accordance with the client agreement.
Ensuring the Four Mandatory Stages Are Completed
ISO 17100 requires four production stages: translation, checking by the translator, revision by a second qualified person, and any additional services agreed with the client such as review, proofreading, or desktop publishing. The project manager is responsible for ensuring each stage is completed and that documented evidence of completion exists.
In practice, this means the PM must have a system for recording when each stage was completed, by whom, and what was done. A translation file with no record of who revised it, or when, does not demonstrate conformity. Auditors will sample production records and ask the PM to show that the workflow was followed on specific projects. If the records are incomplete or inconsistent, this becomes a finding.
The article on translation, check, revision, verification: the four required stages of ISO 17100 explains each stage in detail and clarifies what the standard actually requires at each step.
Managing Tools and Technology
Where translation memory tools, terminology management systems, or machine translation post editing is involved, the project manager is responsible for ensuring these are used appropriately and that the agreed tools are applied consistently. If the client has specified that a particular translation memory or glossary must be used, the PM must ensure this instruction reaches the translator and that compliance is verified.
This also extends to file handling. The PM is accountable for ensuring source files are received in the correct format, that the correct target file is produced, and that version control is maintained throughout the project. Delivering the wrong version of a translation to a client is a quality failure that traces back to project management, not just production.
Post Production: Closing the Project Properly
ISO 17100 Clause 6 covers post production activities, and the project manager has a defined role here as well. Post production is not simply about sending the delivery email and moving on.
Delivery and Client Feedback
The PM is responsible for delivering the completed translation in the agreed format and within the agreed timeframe. After delivery, the organisation must have a process for capturing client feedback. ISO 17100 requires that feedback mechanisms exist and that feedback is used to drive improvement. The project manager is typically the person who receives and records this feedback.
Where a client raises a complaint or queries the quality of a delivered translation, the PM must manage the response. This includes investigating whether the complaint relates to a process failure, documenting the outcome, and ensuring corrective action is taken where warranted. A complaint that is resolved informally with no record does not satisfy the standard.
Archiving and Data Protection
The project manager is responsible for ensuring that project records are archived in accordance with the organisation's documented procedures and any specific requirements agreed with the client. This includes source files, target files, translation memories, glossaries, correspondence, and any quality records from the production stages.
Data protection is explicitly addressed in Clause 6. Where the client has specified confidentiality requirements, the PM must ensure these are communicated to all personnel involved in the project and that the organisation's data handling practices comply with those requirements. In an Australian context, this intersects with obligations under the Privacy Act 1988 and the Australian Privacy Principles, particularly where the translation involves personal information.
Common Nonconformities Related to the PM Role
Based on how ISO 17100 certification audits typically unfold, the project manager role generates a predictable set of findings when it is not properly implemented.
No Documented Competence for the PM
The most common gap is that the organisation has assigned someone to the project manager role without documenting their competence against the criteria in Clause 3.1.5. The person may be highly capable in practice, but if there is no record of how their competence was assessed, the organisation cannot demonstrate conformity. This is the same issue that arises with translators and revisers, but it is often overlooked for the PM because the focus tends to be on production roles.
PM Role Combined With Translation
In smaller organisations, the same person sometimes acts as project manager and translator on the same project. ISO 17100 does not explicitly prohibit this, but it creates a significant risk around the revision requirement. If the PM is also the translator, they cannot act as the reviser. The organisation must ensure a separate qualified reviser is assigned, and the PM must be careful not to let the dual role compromise the independence of the revision stage.
Incomplete Pre Production Records
Auditors regularly find that client agreements are missing required elements, or that the resource assignment process is not documented. The PM may have made good decisions verbally or via informal communication, but without records, the organisation cannot demonstrate that the pre production requirements were met.
No Feedback Loop From Post Production
Many organisations deliver translations and then move on with no structured mechanism for capturing and acting on client feedback. The PM is accountable for this process, and its absence is a gap against Clause 6. The fix is straightforward: a simple feedback register linked to the corrective action process satisfies the requirement without creating excessive administrative burden.
What Auditors Will Ask the Project Manager
When an ISO 17100 certification auditor interviews the project manager, the questions will follow the workflow from pre production through to post production. Expect questions such as:
- How do you assess whether you can accept a new project before committing to the client?
- How do you verify that the translator assigned to a project meets the competence requirements for that language pair and subject matter?
- How do you ensure that revision is always completed by a different person from the translator?
- What records do you keep to demonstrate that each production stage was completed?
- How do you handle a situation where the client changes the scope after the project has started?
- What happens when a client raises a complaint about a delivered translation?
- How do you manage archiving and data protection for completed projects?
These questions are not designed to catch anyone out. They follow the structure of the standard and test whether the PM role is genuinely operational rather than a title on an organisational chart. A project manager who can walk an auditor through a real project using actual records will satisfy these questions without difficulty. One who cannot point to records or who relies on informal processes will generate findings.
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If you are preparing an organisation for ISO 17100 certification, or if you have received findings related to the project manager role in a previous audit, the following steps will address the most common gaps.
- Document PM competence formally. Create a record that maps the project manager's qualifications, experience, and any training against the criteria in Clause 3.1.5. Review and update this record at least annually.
- Create a project initiation checklist. This should cover all the pre production requirements: confirming the language pair, subject matter, qualified resources, delivery format, reference materials, confidentiality requirements, and client agreement elements. The PM completes this for every project before work begins.
- Use a project tracking system. This does not need to be sophisticated. A spreadsheet or simple project management tool that records the translator assigned, the reviser assigned, the completion date for each production stage, and the delivery date is sufficient. The key is that the records exist and are consistent.
- Build a feedback process into project closure. After delivery, send a structured feedback request to the client. Record the response, or the absence of one, and link it to the improvement process. This closes the loop that Clause 6 requires.
- Conduct regular internal reviews of PM records. Sample a selection of completed projects each quarter and check that the pre production, production, and post production records are complete. This is the kind of internal monitoring that demonstrates a functioning quality management system rather than a certification exercise.
Why the PM Role Matters Beyond Certification
It is worth stepping back from the compliance framing for a moment. The project manager role in ISO 17100 is not just a box to tick for certification. It is the function that makes the difference between a translation service that consistently delivers quality and one that relies on the talent of individual translators to compensate for process failures.
A strong PM function means clients receive what they agreed to, qualified people are assigned to every project, the revision stage actually happens, problems are caught and corrected before delivery, and complaints are handled in a way that builds rather than damages the client relationship. These outcomes matter regardless of whether a certification body is watching.
For quality managers and ISO consultants working with translation companies, the project manager role is often the most productive place to focus improvement efforts. Getting this function right tends to lift performance across the entire workflow, because the PM touches every stage of every project.
If you are working toward ISO 17100 certification or want to deepen your understanding of how management system standards are audited in practice, Audit Workshop offers training in ISO auditing across multiple standards. The skills developed in lead auditor and internal auditor training translate directly to the kind of systematic, evidence based thinking that ISO 17100 project management requires.
