Extraordinary Revision of Registration


An extraordinary revision of an agency's registration is initiated by the Committee if there are substantiated concerns whether the agency is still eligible for registration and fulfils the criteria for inclusion, i.e. substantially complies with the ESG.

8.1 The Register Committee shall review its decision to admit a registered agency if substantial procedural errors were made in reaching the initial decision, if the initial decision was based on false information or evidence, or if there are major concerns that the registered agency no longer fulfils the criteria for inclusion.

The extraordinary revision may be based on (see §8.2 of the Procedures):

  • a Substantive Change Report by the agency (see section 5.12);
  • a third-party complaint (see section 5.14); or
  • publicly available information.

The agency concerned has to be notified of the extraordinary revision and needs to be given an opportunity to make representation before any decision is taken. This is similar to the representation made before a rejection decision on an application.

In practice, the Register Committee can notify the agency about an extraordinary revision and invite it to make representation on the planned action at the same time.

Possible Outcomes

The following are the possible actions the Committee can take:

  • Close the Extraordinary Revision without action

    If the representation by the agency resolves the concerns.

  • Reduce the remaining validity of registration

    If there are serious concerns about the applicant’s fulfilment of the criteria and the Register Committee considers it impossible to make a judgement without a new review” (§8.4 c), i.e. if the concerns about substantial compliance with the ESG are serious and a continued inclusion can only be justified on the basis of a new external review earlier than the regular 5-year period has passed. At the same time, upholding registration can be justified for a certain time, and there is no reason to exclude the agency from the Register immediately.

  • Exclude the agency with immediate effect

    If it evidently no longer fulfils the criteria for inclusion” (§8.4 b), i.e. if it obvious that in its structures or activities the agency no longer substantially complies with the ESG. Exclusion is “as from the date on which the agency ceased to fulfil the criteria” (idem).

  • Declare registration void ab initio

    (I.e. registration is terminated immediately and considered to never have existed, since the admission decision was flawed from the outset.)

    If the criteria for inclusion were evidently not fulfilled when the decision to include the agency was made” (§8.4 a), i.e. if it becomes known to the Committee that the external review process was seriously flawed, documents were not genuine, cases of fraud, etc.