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Audit extensions: what happens when they expire?

22 May 2025

Following on from our post earlier this year about audit extensions, this post explains what happens when they expire.

In February we shared a post about audit extensions as we transition to Release 5.1. In that post we explained the usual rules around extensions. Section 9 of the COUNTER Code of Practice outlines two types of audit extension:

  • Delayed seeding. ‘Seeding’ describes the actions auditors take on a publisher platform to create usage activity. This is then used to generate COUNTER reports for audit tests. If a report provider shares their Validation Tool results and explains what they are doing to fix the problems identified by the tool then seeding can be delayed. We can grant one extension of up to three months before seeding starts.
  • Extended fix. Auditors often find problems with the COUNTER reports that are generated after seeding. When that happens they issue an Interim Report. The provider then has three months to fix the problems before the auditors re-test. If an Interim Report has identified serious problems, we can grant one extension of the fix period of up to three months (i.e. six months total fix time).

You asked questions after the last post about what happens when audit extensions expire, which we’re going to answer here.

How can a report provider request an audit extension?

Whether it’s to delay seeding or extend a fix period, it is the report provider’s (publisher’s) responsibility to contact Tasha and request the extension. They should copy in the auditor so that everyone has the same information.

If the provider wants to delay seeding, they need to prove that they have run the Validation Tool and need time to fix structural problems with their reports. That means sharing the results and an explanation of what they are doing to fix the problems. They also need to share a timeline for the fix. We recommend running the Validation Tool at least two months in advance of seeding. This enables them to wrap up any fixes before the audit is due to start.

We will consider an extension to the fix period where the auditor’s interim report has identified significant problems. The auditor should be copying in Tasha on all interim reports so that she can anticipate likely extension requests. When requesting an extension, the report provider needs to explain what they are doing to fix the problems and how long they expect it to take.

What happens if the maximum three-month extension isn’t long enough?

In most cases where a report provider misses the extended deadline for either seeding or fixing, COUNTER will mark the audit as Failed. Per Section 9.2, providers who Fail an audit must start a new audit within three months.

We acknowledge in the Code that “there may be limited, unforeseen circumstances in which an additional extension may be granted”. This is the process for a report provider who thinks they fall under this clause:

  1. Share a detailed explanation with Tasha by email and schedule time to discuss it with her.
  2. If she agrees that the situation warrants an additional extension, Tasha will take a recommendation to the COUNTER Executive Committee.
  3. Where the EC agrees to the additional extension, the audit will stay as In Progress unless the report provider misses that extra-extended deadline.

Can a record disappear from the Registry?

Inclusion in the Registry signals two important things. It shows that a report provider is COUNTER-compliant or working towards compliance. It also shows that they support the organisation and the standard by being members of COUNTER. We wouldn’t usually remove records from the Registry, as it’s a valuable tool for librarians. However, there are two situations where we might delist:

  • If a report provider goes more than a year past their scheduled audit seeding date, and has not been in direct communication with Tasha to discuss the issue, we consider them to no longer be compliant or working towards compliance, and will hide their record from public view.
  • If a report provider allows their membership to lapse, we give them six months to resolve the situation before hiding their Registry record from public view.

Are you going to backdate this to R5 audits in the Registry?

No! These rules were clarified in R5.1 and we’ll only be enforcing them for audits under that version of the Code.

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