Why Competence Is the Foundation of ISO 17100
ISO 17100 is built on a straightforward idea: translation quality depends on the people doing the work. Unlike many management system standards that focus primarily on processes and documented information, ISO 17100 puts human competence at the centre of every requirement. If the people involved in a translation project do not meet the standard's competence criteria, the project cannot be considered conformant, regardless of how well the workflow is documented.
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Most discussions of ISO 17100 competence focus on the translator, and for good reason. The translator's qualifications attract the most scrutiny during a certification audit. But the standard sets equally specific requirements for three other roles: the reviser, the reviewer, and the project manager. Each role has its own competence profile, and each one will be examined by a certification auditor.
This article works through what ISO 17100 requires for each of these three roles, what records you need to demonstrate conformance, and where organisations most commonly fall short. If you are preparing for a certification audit, managing a translation business, or auditing a language service provider, this is the territory you need to understand clearly.
The Reviser: The Most Demanding Competence Profile After the Translator
Revision is the mandatory second-person check that sits at the heart of ISO 17100's production workflow. The standard requires that every translation be revised by a person other than the translator before delivery. This is not optional, and it is not satisfied by a quick read-through. Revision is a defined task with a specific scope: checking the target language text against the source, assessing translation choices, evaluating terminology, style, grammar, and fitness for purpose.
Because the reviser is performing a linguistic and technical assessment of the translation itself, ISO 17100 requires the reviser to hold competence that is largely equivalent to that of the translator.
Linguistic and Textual Competence
The reviser must have the same linguistic and textual competence required of a translator. That means native-level or near-native proficiency in the target language, strong reading comprehension in the source language, and the ability to produce and evaluate text that is accurate, fluent, and appropriate to the target audience. A reviser who lacks genuine bilingual competence cannot meaningfully assess whether the translation captures the source accurately or whether the target text reads naturally.
Subject Matter Competence
ISO 17100 requires the reviser to have subject matter competence relevant to the content being revised. This is where many smaller language service providers struggle. It is straightforward to assign revision to a senior translator, but if that person lacks domain knowledge in, say, pharmaceutical regulatory affairs or civil engineering, their revision of a specialist document may not satisfy the standard's intent.
Subject matter competence can be demonstrated through formal qualifications, work experience in the relevant field, or a combination of both. The key is that the organisation can produce documented evidence that the reviser actually knows the subject area, not just that they are a competent general translator.
Research and Information Processing Competence
The reviser needs the ability to research terminology, consult reference materials, and evaluate translation choices against authoritative sources. This is particularly relevant for technical or legal content where terminology must be precise and consistent with established usage in the target language jurisdiction.
Technological Competence
The reviser must be competent in using the tools required for the revision task. In practice this means proficiency with translation memory systems, terminology databases, and any quality assurance tools used in the workflow. A reviser who cannot use the same CAT tool environment as the translator may miss inconsistencies that are only visible when the translation memory is consulted alongside the target text.
Cultural Competence
Cultural competence for the reviser means the ability to assess whether the translation is appropriate for the target culture and audience. This goes beyond grammar and word choice. It includes sensitivity to register, tone, idiomatic usage, and any cultural references that may need to be adapted rather than translated literally.
What Records Demonstrate Reviser Competence?
During a certification audit, the auditor will look for documented evidence of reviser competence for each person assigned to that role. Acceptable evidence typically includes academic qualifications in translation or a relevant subject area, professional certifications, work history demonstrating subject matter expertise, performance evaluations, and records of any internal assessment the organisation has conducted. The key point is that competence must be documented before the person is assigned to revise a project, not assembled retrospectively when an auditor asks for it.
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The Reviewer: A Different Competence Profile Entirely
The reviewer role is often confused with the reviser role, but they serve entirely different purposes and require different competence. Where the reviser checks the translation against the source text, the reviewer assesses the target language text for its fitness for a specific purpose, domain, or target audience. The reviewer is typically a subject matter expert rather than a professional linguist.
ISO 17100 makes review an optional service rather than a mandatory step. It is performed at the client's request when specialist domain knowledge is needed to confirm that the translated content is accurate and appropriate for its intended use. A pharmaceutical company might request review by a regulatory affairs specialist. A legal firm might request review by a qualified lawyer in the target jurisdiction.
Domain Expertise as the Primary Requirement
Because the reviewer is evaluating content fitness rather than translation accuracy, the standard's primary competence requirement for this role is domain expertise. The reviewer must have recognised knowledge and experience in the relevant subject area. This might be demonstrated through professional qualifications, industry accreditation, or a verifiable work history in the field.
Linguistic competence in the target language is also required, because the reviewer must be able to read and evaluate the translated text. However, the reviewer is not expected to hold the same level of translation competence as the reviser. The reviewer is not comparing source and target texts word for word. They are reading the target text and assessing whether it is accurate, complete, and appropriate for its intended purpose from a domain perspective.
Terminology and Consistency
The reviewer is expected to identify terminology that is inconsistent with standard usage in their field, flag content that may be technically incorrect, and confirm that the document is fit for its intended use. This requires current knowledge of the domain, not just historical familiarity. A reviewer whose expertise is several years out of date in a fast-moving technical field may not satisfy the standard's intent.
Documenting Reviewer Competence
Because reviewers are often external subject matter experts rather than in-house staff, documenting their competence requires a slightly different approach. The organisation should maintain records that identify the reviewer, their qualifications and relevant experience, the domain they are competent to review, and the specific projects they have reviewed. Contracts or service agreements with external reviewers should include a competence declaration or reference to their professional credentials.
One common audit finding in this area is that the organisation has engaged a reviewer but has no documented basis for concluding that the person is competent in the relevant domain. The fact that a client nominated the reviewer does not remove the organisation's responsibility to verify and record that competence.
The Project Manager: Operational Competence Across the Whole Workflow
The project manager in an ISO 17100 context is the person responsible for managing a translation project from initial enquiry through to delivery and archiving. This is not a purely administrative role. ISO 17100 sets specific competence requirements for project managers because they make decisions that directly affect whether the production workflow is followed correctly and whether the right people are assigned to each task.
Project Management Competence
The project manager must be competent in planning and managing translation projects. This includes scoping projects accurately, preparing quotations, managing timelines, coordinating resources, and handling client communication. In practice it means understanding how translation workflows operate, how to allocate work across translators and revisers, and how to identify when a project requires specialist resources that are not available in-house.
Linguistic and Textual Competence
ISO 17100 requires the project manager to have linguistic and textual competence. This does not mean the project manager must be a professional translator, but they must have sufficient language competence to understand the nature of the work being managed. A project manager who has no working knowledge of either the source or target language is poorly placed to assess the scope of a project, identify potential complexity, or evaluate whether the right resources have been assigned.
In practice, most language service providers appoint project managers who are themselves qualified translators or who have a strong background in languages. The standard does not prescribe a specific qualification, but the organisation must be able to demonstrate that the project manager's linguistic competence is adequate for the projects they manage.
Technological Competence
The project manager must be competent in the technology used in the production workflow. This includes translation management systems, translation memory tools, file preparation and conversion processes, and any quality assurance software used in the workflow. The project manager needs to understand these tools well enough to set up projects correctly, brief translators and revisers on tool requirements, and identify when technical issues are affecting quality or workflow.
Domain Knowledge
While the project manager is not expected to have the same depth of domain expertise as a subject matter reviewer, ISO 17100 expects the project manager to have sufficient domain awareness to make sensible resourcing decisions. A project manager who cannot distinguish between a legal translation and a technical manual is unlikely to assign the right translator and reviser to each project type.
Research Competence
The project manager must be able to research terminology, style guides, client preferences, and domain conventions when preparing for a project. This is particularly relevant when onboarding new clients or managing projects in unfamiliar subject areas. The ability to identify and consult appropriate reference materials is part of the project manager's competence profile under the standard.
Records for Project Manager Competence
The same documentation principles that apply to translators and revisers apply to project managers. The organisation needs to maintain records that demonstrate each project manager's competence against the requirements of the role. This typically includes their educational background, language qualifications, relevant work experience, any training in project management or translation technology, and records of performance evaluation.
A common gap found during audits is that the organisation has robust competence records for translators but thin or absent records for project managers. The assumption that project management is a purely administrative function leads some organisations to treat it as outside the scope of ISO 17100's competence requirements. That assumption does not survive an audit.
How These Roles Interact in Practice
Understanding the competence requirements for each role in isolation is useful, but it is equally important to understand how these roles interact within a real project. The project manager selects the translator and reviser, confirms their competence for the specific project, and sets up the workflow. The translator produces the target text. The reviser checks it against the source. If review has been requested, the reviewer assesses the target text for domain accuracy and fitness for purpose.
Each handoff in this chain depends on competence being verified at the point of assignment, not assumed. The project manager needs to know enough about each person's competence profile to make appropriate assignments. The reviser needs to know enough about the subject area to evaluate the translator's choices. The reviewer needs to know enough about the domain to confirm that the content is fit for purpose.
When competence records are well maintained and up to date, this chain works smoothly and is easy to demonstrate to an auditor. When records are incomplete, the auditor must rely on the organisation's verbal assurances, which is not a satisfactory basis for certification.
Common Audit Findings Related to These Three Roles
Across certification audits of language service providers, a number of recurring nonconformities appear in relation to reviser, reviewer, and project manager competence.
- Reviser competence records are incomplete. The organisation can identify who revised a project but cannot produce documented evidence that the person had the required subject matter competence for that specific project type.
- The reviser and translator are the same person. ISO 17100 is explicit that revision must be performed by a person other than the translator. This is one of the most fundamental requirements of the standard, and it is still found as a nonconformity in audits.
- Reviewer competence is assumed rather than verified. The organisation has used an external subject matter expert as a reviewer but has no records confirming their domain qualifications or experience.
- Project manager competence records are absent. The organisation treats project management as an administrative function and has not documented competence evidence for people in that role.
- Competence records are outdated. The organisation has records from when a person was first engaged but has not updated them to reflect changes in their role, the subject areas they cover, or the tools they use.
Each of these findings can be raised as a nonconformity against Clause 3 of ISO 17100, which sets out the resource requirements including competence. If you are preparing for a certification audit, working through these common gaps against your own records is a productive starting point.
For a broader understanding of how the resource requirements in ISO 17100 connect to the rest of the standard, the article on ISO 17100 Clause 3 Resources: Competence Records and Infrastructure Requirements covers the full clause in detail. And if you want to understand how the mandatory production workflow ties these roles together in sequence, Translation, Check, Revision, Verification: The Four Required Stages of ISO 17100 explains how each step connects.
Exemplar Global Recognised Training ProviderRTP No. 310970Practical Steps for Maintaining Compliant Competence Records
Maintaining competence records that will satisfy an ISO 17100 auditor does not require a complex system. It requires consistency and discipline. The following practical steps will put most organisations in a strong position.
- Create a competence profile for each role. Document what competence is required for translators, revisers, reviewers, and project managers in your organisation. This does not need to be elaborate, but it needs to be specific enough to guide resourcing decisions.
- Collect and file evidence for each person. For every person assigned to a role covered by the standard, maintain a file that includes their qualifications, relevant experience, language combinations, subject matter areas, and any performance evaluation records.
- Link project records to competence records. When a project is completed, the record should show who performed each function and provide a reference to their competence evidence. This makes it straightforward for an auditor to follow the chain from project to person to competence.
- Review and update records regularly. Competence records should be reviewed at least annually and updated whenever a person's role, subject areas, or tool proficiencies change.
- Apply the same rigour to external resources. Freelance translators, revisers, and reviewers must have the same documented competence as in-house staff. Maintain a register of approved external resources with their competence evidence on file.
If you are also thinking about how competence requirements work across other ISO standards, the article on Internal Auditor Competence: What ISO Expects provides a useful comparison of how different standards approach this requirement.
Audit Workshop and ISO 17100 Awareness
Understanding the competence framework in ISO 17100 is valuable whether you are a language service provider preparing for certification, an internal auditor reviewing your own system, or a quality professional expanding your knowledge of sector-specific ISO standards. At Audit Workshop, our ISO auditor training courses build the practical skills needed to evaluate competence requirements across any ISO standard, including sector-specific ones like ISO 17100. If you are working toward your internal auditor or lead auditor credentials, the competence evaluation techniques you develop in training apply directly to this kind of detailed clause-level analysis.
