The Rule-Maker Must Be Governed Too

Standards often appear technical and neutral. They define what counts as safe, competent, sustainable, accredited, ethical, comparable or compliant. Once adopted by regulators, funders, purchasers, professional bodies and institutions, they can determine who enters a market, whose qualification is recognised, which claim is trusted and what conduct attracts sanction.

That is governing power even when the organisation exercising it is not a government. The rule-maker may be a professional association, accreditation council, certification scheme, donor consortium, examination body, private foundation, technical committee or international standard setter. Its decisions can travel through contracts and policies until people far from the original meeting must reorganise their work around them.

The rule-maker must therefore be governed too. Expertise does not remove the need for authority, independence, representation, conflict management, transparent reasoning, appeal and evidence of impact. A standard becomes credible when both the rule and the institution that produced it can survive disciplined scrutiny.

The newest dispute places the governance of standards in public view

On 25 October 2026, the Financial Times reported concerns from current and former staff about possible corporate influence over the Greenhouse Gas Protocol, whose accounting standards underpin much corporate emissions reporting. The report described disagreements about proposed changes to how companies account for electricity-related emissions and cited an external review that raised concerns about corporate representation in governance structures. Financial Times

These are reported allegations and governance concerns, not a completed finding that any company captured the standard or that a particular technical proposal is invalid. The Protocol told the Financial Times that scientific integrity, transparency, independence and inclusive decision-making are fundamental to its process; it said no stakeholder can unduly influence outcomes and that the chief executive does not vote on new standards.

The dispute is consequential because the Protocol describes itself as the world's most widely used greenhouse-gas accounting and reporting standard and the foundation for many other corporate decarbonisation initiatives. Its official governance page identifies a Steering Committee, an Independent Standards Board, technical working groups and a Donor Council. GHG Protocol governance

Responsible interpretation should therefore avoid both premature condemnation and complacent reassurance. The leadership task is to test whether the institution's formal safeguards govern real influence at the points where evidence becomes a rule.

A standard setter exercises delegated public consequence

A voluntary standard may acquire compulsory force without a legislature passing it. A regulator incorporates it, a donor makes it a condition, a procurement document requires certification, an insurer prices against it, a university adopts it or a dominant buyer insists upon compliance. The standard then operates as part of the institution's governing environment.

This power can create valuable coordination. Common definitions allow organisations to compare information, reduce duplication, protect safety and build trust across jurisdictions. But the same power can exclude smaller actors, import unsuitable assumptions, hide political choices inside technical language or grant private organisations practical authority without matching public accountability.

The first governance duty is to state the mandate honestly. Who authorised the body to write the rule? Is it advisory, contractual, professional, statutory or market-based? Which institutions may adopt it, and what remains within their independent judgement? A standard should not borrow the language of universal authority when its legitimacy depends upon voluntary adoption or a limited institutional mandate.

Independent review is a source of learning, not a verdict by association

An Oxford-led review published on 1 September examined governance across five influential climate and sustainability standard setters: the Greenhouse Gas Protocol, Global Reporting Initiative, International Organization for Standardization, International Sustainability Standards Board and Science Based Targets initiative. Oxford Net Zero

The public summary says all five demonstrate strong commitment to governance and public-interest objectives. It also identifies common challenges arising from the funding and capacity needed to sustain independence, transparency, due process and governance infrastructure. Those are sector-wide findings, not proof of the specific allegations reported on 25 October.

The distinction matters. Leaders should neither use a general review to convict an individual nor use the absence of a final misconduct finding to avoid examining structural risk. A governance review asks whether the system can identify, disclose, manage and correct improper influence before a disputed outcome becomes irreversible.

Participation must not become control

A credible standard needs knowledge from companies, workers, governments, scientists, communities, implementers and people expected to verify compliance. Excluding industry can produce rules detached from operational reality. Allowing regulated or commercially interested actors to dominate can turn consultation into control.

Map participation by function. Who supplies evidence? Who drafts? Who tests feasibility? Who resolves technical disagreement? Who approves the final requirement? Who may appeal? Who monitors outcomes? An interested stakeholder may make an essential contribution without acquiring the authority to determine how competing evidence is weighed.

Balance is not achieved by counting seats alone. Similar professional backgrounds, funding relationships, geographic concentration or repeated organisational affiliations can create common interests beneath apparently diverse names. Publish selection criteria, terms, affiliations, voting rules, recusals and the competence each appointment adds.

Funding should sustain the standard without purchasing influence

Standards development is expensive. It requires research, consultation, expert time, translation, administration, data, assurance and continuing revision. Long-term underfunding can weaken independence as surely as an openly conditional donation because the organisation becomes unable to operate without a narrow set of supporters.

Publish the funding model, material donors, grant conditions, restricted and unrestricted income, concentration risk, services supplied in kind, and safeguards separating money from technical decisions. A donor council may offer useful coordination, but its role should be distinct from the authority that approves normative requirements.

Independence does not require refusing every contribution from an interested party. It requires a structure in which no contributor can purchase privileged evidence, private access to decision makers, protection from an unfavourable standard or silence about an unresolved concern. The board should review both actual influence and the reasonable public perception of influence.

Conflict of interest begins before the vote

Conflict policies often focus on the final meeting: disclose an interest and abstain from voting. Influence begins much earlier. It can shape the mandate, leadership role, membership criteria, agenda, research question, consultant brief, evidence admitted, wording of options and timetable for consultation.

Require declarations when a person designs the system, seeks appointment, receives new interests and participates in a material decision. Record employment, clients, investments, funding, advisory roles, close institutional relationships and prior work that a reasonable observer would consider relevant. Then choose a proportionate response: disclosure, restricted access, independent review, recusal or non-appointment.

The OECD's conflict-of-interest guidance emphasises disclosure, openness, public scrutiny, individual responsibility and an organisational culture that can discuss and manage conflicts. The point is not to imply dishonesty whenever an interest exists. It is to prevent an unmanaged interest from compromising—or appearing to compromise—disinterested judgement. OECD

Technical independence needs enforceable boundaries

A board may govern finance, strategy and appointments while a technical body governs the content of the standard. This separation can protect expertise, but only if roles, escalation and removal powers are clear. Management should not be able to rewrite a technical conclusion through informal direction, and experts should not be able to ignore lawful resource, process or impact concerns.

The Greenhouse Gas Protocol says members of its Independent Standards Board serve in their individual capacity rather than as representatives of employers. Its October update states that technical proposals proceed through working-group discussion and Independent Standards Board approval before a consolidated public consultation planned for 2027. Scope 2 process update

These are formal safeguards. Their effectiveness depends upon whether the board receives complete evidence, controls its agenda, records material disagreement, resists private pressure and can require management to follow the approved procedure. Independence should be tested through decisions, not inferred from titles.

Transparency requires reasons, not only documents

Publishing membership lists, terms of reference and meeting papers is valuable. The Protocol's governance repository includes working-group, standards-board, steering and donor materials and says new items are added weekly. Governance repository

A document library does not by itself explain the decision. Readers need to know the question, evidence, alternatives, interests, decision criterion, objections, changes between drafts, authority and final reason. A large volume of files can technically disclose the process while leaving consequential influence difficult to reconstruct.

Create a decision trail. For every material requirement, connect the source evidence, consultation themes, technical analysis, alternatives considered, conflict declarations, governing discussion, resolution, dissent and review date. Transparency becomes useful when an informed outsider can understand why the rule took its present form.

Consultation is meaningful when influence can be traced

A public consultation can receive thousands of submissions yet remain unequal. Well-funded organisations can employ specialists, attend repeated meetings and submit model language. Smaller institutions, local communities and public-interest groups may lack time, technical vocabulary, translation or reliable access.

Publish whose participation was sought, who responded, which regions and affected groups were missing, and what assistance supported participation. Summarise arguments by substance rather than organisational prestige. Explain which evidence changed the draft and why other proposals were not adopted.

The ISEAL Code of Good Practice integrates scheme governance, stakeholder engagement, data, standards development, assurance, claims, due diligence and remediation. It treats credibility as a system rather than a consultation event. ISEAL

The Global South should co-author standards, not merely implement them

Global standards often reach African institutions through procurement, development finance, accreditation, reporting, supply chains and imported technology. Participation may be formally open while the real cost of contributing—research capacity, travel, expert time, language and sustained committee presence—remains unequal.

Africa is not a distant market whose context can be added after the rule is complete. It contains standard setters, regulators, universities, laboratories, businesses, professional bodies, workers and communities whose knowledge should shape the definition of quality itself. The African Organisation for Standardisation's strategy for the Fourth Industrial Revolution was developed with standards bodies, regulators, researchers and other contributors to align standardisation with continental priorities. ARSO

Active inclusion may require funded participation, regional evidence, translation, local testing, longer response periods and representation in drafting and approval—not only an invitation to comment. Global comparability and contextual validity should be designed together rather than traded against each other after adoption.

Market acceptance is relevant but cannot govern truth

A rule that no institution can implement will not deliver its purpose. Standard setters should examine cost, capability, data availability, transition time, unintended effects and whether smaller actors can comply. Feasibility is a legitimate decision criterion.

Market acceptance becomes dangerous when it means that powerful users can veto requirements that would make their claims less favourable. The governing question is not whether every stakeholder welcomes the standard, but whether the rule is sufficiently accurate, fair, proportionate and implementable to serve its declared purpose.

Record trade-offs explicitly. If a requirement is phased, simplified or adapted, show the evidence and affected groups. If integrity requires a difficult change, state what capability and transition support will make compliance possible. Do not preserve an attractive claim by weakening the measurement intended to test it.

Evidence should remain distinguishable from advocacy

Scientists, companies, civil society, regulators and affected communities bring different knowledge. Technical models may estimate physical relationships; industry data may reveal operational constraints; worker and community evidence may expose consequences invisible to a spreadsheet. None should be dismissed merely because its source has an interest.

Classify the contribution. Is it independently replicated evidence, internal company data, expert interpretation, scenario modelling, legal analysis, implementation experience, affected-person testimony or preferred policy? Record limitations, confidentiality and whether the evidence can be tested by others.

Advocacy is legitimate when named. The problem occurs when a preferred outcome is presented as if technical evidence compelled it, or when an inconvenient technical conclusion is dismissed because the expert also holds a public-interest conviction. The decision record should show how evidence and values were integrated.

Dissent can strengthen the standard

Consensus is valuable when it reflects reasoned accommodation. It becomes misleading when disagreement is compressed into vague minutes, dissenters leave the process or the final report implies unanimity that never existed.

Create protected routes for members and staff to raise procedural, scientific and ethical concerns. Record minority reasoning when the issue is material. A governing body may still make the final decision, but it should know which assumption or value produced the disagreement and what future evidence would justify review.

Whistleblowing is not a substitute for ordinary challenge. If people must leak documents before a concern can reach independent authority, the internal governance system has already become fragile. Leaders should make principled disagreement safer than silence and more useful than reputational warfare.

Complaints and appeals complete the authority chain

A standards body needs a route for challenging process, conflicts, technical application, certification decisions and misuse of claims. These are different complaints and may require different competent decision makers.

Publish admissibility, evidence requirements, confidentiality, independence, timetable, interim protection, decision authority and review. A complaint against management should not be controlled by the same management; an appeal should not simply ask the original decision maker to confirm itself.

Track themes and corrective action. A complaint system is not successful because cases are closed. It is useful when recurring problems change guidance, training, composition, assurance or the standard itself, while individual parties receive a reasoned outcome and protection from retaliation.

Boards should govern the rule-making institution

The governing board should protect mission, independence, resources and due process without substituting its preferences for competent technical judgement. It should approve the mandate, committee architecture, appointment criteria, conflict system, funding safeguards, risk appetite, complaints route and review cycle.

Board assurance should examine whether technical bodies operated within their authority, received balanced evidence, disclosed interests, documented decisions and considered affected people. It should also test whether management provided complete information and whether donors, members or partners obtained access outside the approved process.

When the organisation's own governance is questioned, commission a review whose scope, independence, evidence access, reporting destination and publication approach are visible. A review designed to reassure rather than discover will deepen the credibility problem it was meant to solve.

Higher education should examine who writes the academic rule

Universities and colleges operate through qualification frameworks, accreditation standards, examination rules, professional requirements and internal academic policies. These protect quality when their authority and evidence are clear. They can also produce compliance rituals detached from learner competence and institutional purpose.

An academic body should distinguish regulatory minimum, professional expectation, institutional choice and recommended practice. Faculty, assessors, learners, employers and communities should have appropriate participation, while authorised academic authorities retain responsibility for curriculum and assessment decisions.

When a regulator, donor or technology supplier proposes a standard, ask who helped write it, which evidence supports it, what local capacity it assumes, how exceptions and appeals work, and who bears the cost. Adoption should be an authorised educational judgement—not a reflex response to technical prestige.

Faith institutions should govern doctrinal and safeguarding standards

Churches and ministry networks need shared standards for doctrine, formation, ordination, finance, safeguarding and pastoral conduct. Spiritual conviction gives these standards seriousness; it does not exempt their human administration from accountability.

State the scriptural and theological basis, competent ecclesial authority, consultation, evidence, procedure, conflict safeguards and route for review. Those who teach the rule, investigate conduct and decide appeal should not be collapsed into one unchallengeable office where the consequence is material.

A standard intended to protect truth or vulnerable people loses credibility when influential leaders receive informal exceptions. Grace and restoration may shape the response, but they should operate through an accountable process that protects people, records authority and does not rename favouritism as pastoral discretion.

Public service should not outsource policy without oversight

Governments regularly rely on professional standards, technical codes, consultant methodologies, ratings and certification schemes. This can bring expertise and consistency. It can also allow private criteria to shape public services, procurement or eligibility without public officials examining how the rule was produced.

Before incorporating an external standard, identify its legal status, owner, revision process, funding, conflicts, accessibility, local participation, cost, auditability and appeal. Public authority remains responsible for rights, proportionality, procurement integrity and remedy even when the technical requirement comes from elsewhere.

A citizen should be able to discover which rule affected the decision and how it may be challenged. Proprietary language or consultant confidentiality should not make public power unreviewable.

Enterprises should distinguish compliance from influence

Companies should contribute operational evidence to standards that govern their industries. They should also disclose participation, funding, lobbying positions and conflicts where the public may reasonably question influence. Membership of a working group should not be marketed as endorsement of the company's claims.

Boards should ask whether the organisation applies the same standard it seeks to shape, whether its public position matches private advocacy and whether smaller suppliers can meet the proposed requirement. A technically compliant claim may still mislead if the company helped weaken the measure without transparent reasons.

Responsible influence is possible: publish evidence, accept competing scrutiny, avoid privileged channels, support representation beyond the firm and remain willing to comply with an outcome the company did not prefer.

Digital and AI standards need visible human governance

AI standards are increasingly written by coalitions of technology companies, governments, researchers and civil-society organisations. The technical complexity can make vendor participation indispensable and simultaneously increase the risk that commercial assumptions become the default definition of safety, performance or responsible use.

Disclose model-provider roles, benchmark ownership, data access, intellectual-property constraints, funding, incidents considered, affected-language coverage and who may change the requirement. Test standards in African languages, institutions and infrastructure before claiming global validity.

AI may help compare consultation responses, detect conflicts and maintain a decision trail. It should not rank stakeholder legitimacy, manufacture consensus or replace the accountable body that must explain the final rule. The governance record should preserve what the system summarised, omitted and could not evaluate.

Consultants should not design authority for themselves

Consultants may help a standards body redesign governance, recruit leaders, draft procedures, model technical options or assess implementation. The assignment creates a conflict risk when the adviser can shape a role, selection process or continuing service from which it may later benefit.

Terms of engagement should disclose interests, define decision boundaries, preserve client ownership of evidence, include independent challenge and prevent the adviser from certifying its own design without proportionate review. Working papers should distinguish stakeholder evidence from consultant interpretation.

Capability transfer matters. The client should be able to operate, question and revise the governance system after the adviser leaves rather than depend upon the same firm to explain every rule it helped create.

Leadership thinkers become useful when influence is made answerable

Maxwell Leadership's newest verified podcast, published on 23 October, presents coaching as the work of recognising potential, preparing people and entrusting responsibility. It is practitioner guidance rather than independent outcome evidence. Its standards-setting test is whether participation develops contributors with real influence or merely recruits them to validate a process already controlled elsewhere. Maxwell Leadership

Patrick Lencioni asks whether teams can speak uncomfortable truth before conflict becomes crisis. Jim Collins asks whether disciplined leaders confront brutal facts. Myles Munroe and Stephen Covey connect authority with purpose and principle, while Ken Blanchard asks whether responsibility is matched by clarity and support. Simon Sinek keeps the standard connected to an intelligible public purpose.

Brené Brown and Amy Edmondson help institutions protect candour. Marshall Goldsmith and Adam Grant ask whether credible challenge changes senior judgement. Ram Charan and Liz Wiseman bring board discipline and distributed intelligence into view. John Kotter asks whether a standard becomes operating practice; Robin Sharma keeps integrity visible in daily conduct; Craig Groeschel asks whether the system enables capable people to act without hidden permission from the top.

Fred Swaniker and Sam Adeyemi reinforce Africa's responsibility to form leaders and institutions that shape the rules of an interdependent world. The Global South should not seek exemption from credible standards. It should insist upon co-authorship, contextual evidence and governance strong enough to make global rules worthy of global trust.

Use a rule-maker integrity record

Purpose identifies the public or institutional outcome. Authority states who may propose, draft, advise, approve, interpret, assure and hear appeal. Composition records competence, geography, affected interests, appointment route, term and removal. Funding identifies donors, conditions, concentration and safeguards.

Interests record affiliations and management decisions. Evidence distinguishes research, operational data, testimony, modelling and advocacy. Participation shows who was invited, supported, heard and absent. Options record competing approaches, costs, rights, feasibility and consequences.

Decision criteria explain how integrity, impact, feasibility and equity were weighed. Reasons connect evidence with the approved text. Dissent preserves material contrary reasoning. Implementation tests usability and unintended harm. Complaints and appeals provide remedy. Review determines whether the rule still serves its purpose and whether its maker remains worthy of the authority others have placed in it.

Govern one rule before enforcing it today

Select one standard, policy, rubric, qualification rule or professional requirement that your institution applies. Identify who wrote it, under what authority, with whose money, using which evidence and with what participation. List the people who benefit, bear cost or may be excluded.

Ask whether a material interest was disclosed, whether technical judgement is protected, whether Global South and affected-person knowledge shaped the rule, whether reasons are traceable and whether a person can challenge its application. Decide what must be disclosed, corrected, locally adapted, independently reviewed or referred to the competent authority.

Do not abandon standards because rule-making can be influenced. Govern the influence. Institutions need shared measures, but legitimacy cannot be borrowed from technical vocabulary. The strongest standard is produced by a process able to name its power, expose its interests, hear those who carry the consequence and correct itself when evidence shows that the rule no longer deserves trust.