1. The pre-assessment creates a direct influence on the decision

In self-managed systems, the sequence is often as follows:

1. a network stakeholder is supporting the project;
2. he participates in the production of evidence;
3. he prepares a preliminary file or a preliminary assessment;
4. he transmits his information to an evaluator;
5. The case is then processed using the same methodological approach.

This organization creates a structural influence:

• The project is guided by internal understanding.
• The file is optimized according to the network's doctrine.
• The evidence is prepared with the objective of a conformity known in advance.

Consequence:

The evaluation can no longer be independent.

2. Involving a subcontractor does not create an independent third party

Several private schemes involve external structures for “evaluation”. But these actors:

• apply the designer's method,
• follow his interpretations,
• do not control governance
• are not accredited to certify this method,
• are not independent of the system,
• do not have a mandate for impartial decision-making.

They act as:

• providers,
• operators,
• internal controllers, not as an independent third party.

The legal status is not that of an ISO accredited body.

It's subcontracting, not independence.

3. A Participatory Guarantee Scheme (PGS) is not a third-party assessment

A SGP is based on:

• peer review,
• community assessment,
• internal legitimation,
• the network consensus.

This model:

• is not independent,
• is not enforceable,
• is not accreditable,
• is not compatible with public policies,
• is not usable by institutional investors.

A SGP is a mechanism for internal cohesion, not an impartial evaluation.

4. Self-assessment + internal pre-evaluation = lack of impartiality

In these systems, the accompanying person:

• optimizes the project,
• design assistance,
• prepare the evidence.
• selects the items to be provided,
• influences how the criteria will be read.

Then an evaluator (external or not) receives a file already directed by the network.

Neutrality is lost:

• the evidence is not independent,
• The interpretation is predefined.
• Compliance is anticipated.
• Analysis is no longer free.

This is the exact opposite of what a third-party evaluation requires.

5. Why is this model incompatible with ISO 17065?

ISO 17065 requires:

• independence of the evaluation,
• impartiality of the process,
• absence of a dual role,
• Separate governance
• impartial decision
• control by a national accreditation body.

The diagram:

Support → Pre-assessment → Assessment → Decision in a closed system

rape:

• independence,
• impartiality,
• the traceability of evidence,
• the separation of roles,
• Decision-making neutrality.

Result :

Device not accreditable.

6. Without an independent third party, the evidence is not institutionally admissible.

European requirements (CSRD, Taxonomy, SFDR) require:

• an audited piece of evidence
• an independent third party,
• a governance free from influence,
• a methodology verifiable by a public authority.

An internal pre-assessment:

• directs the evidence,
• eliminates neutrality,
• prevents impartial verification
• makes the data unsuitable for integration into ESG financing.

Project owners, local authorities and investors cannot rely on it.

7. The independent model: separate production of evidence from the evaluation

The IRICE structure perfectly meets institutional expectations:

Biodiversity Partners

→ accompany → prepare the evidence → document → never evaluate.

IRICE Assessors

→ check → control → apply the ISO procedure → never accompany.

IRICE Decision

→ taken over by an independent entity.

Result :

Support ≠ Evaluation ≠ Decision → demonstrable impartiality.

Conclusion

Self-assessment and internal pre-evaluation do not replace an independent third party. Whether it is an assessor, an internal network, an external service provider, or a Participatory Guarantee System, the evidence remains produced and pre-validated within the system.

Only a strict separation between support, evaluation and decision-making, in accordance with ISO requirements, can guarantee an impartial, accreditable and institutionally acceptable evaluation.