Twelve criteria, one standard

The label rests on twelve criteria, grouped in four families: governance, diligence, traceability and ethics. Each is assessed on a four-level scale, with precise evidence requested from the applicant.
To obtain the label, an applicant must reach the “compliant” level on each of the twelve criteria, and the “exemplary” level on at least three of them. A single criterion at the “insufficient” level leads to refusal.
This page presents each criterion, the evidence expected and how it is assessed by the auditor.
The criteria in figures
The twelve criteria
1GovernanceCompliance officer appointed, organisation chart and written procedures.
2Due diligenceVerification of sellers' identity and the source of funds.
3BIOP searchSystematic consultation before any acquisition or sale.
4ProvenanceRequirement of provenance documents according to the age and nature of works.
5AuthenticityUse of accredited experts for sensitive works.
6Retention of filesArchiving of documents for at least ten years.
7ReportingInternal procedure for reporting suspect works to OIMAP.
8Financial transparencyTraceability of payments and refusal of cash above a threshold.
Annual training in diligence and ethics.
OIMAP mention and clear information for buyers.
Vigilance system and reporting of suspicions.
Response to requests from the authorities and from OIMAP.
The four assessment levels
| Level | Meaning | Consequence |
|---|---|---|
| Exemplary | Practice beyond the requirements | Counts towards the three exemplary criteria |
| Compliant | Requirement met | Validates the criterion |
| To be improved | Minor gaps, action plan | Label possible with reservation |
| Insufficient | Requirement not met | Label refused |



How a criterion is assessed
- Reading the procedures
The auditor reads the written documents.
- Sample of files
Twenty files are examined.
- Interviews
Meeting with managers and staff.
- Rating
Each criterion receives a reasoned level.
- Report
The applicant receives the report and may reply.
Evidence counts more than promises
Procedural criterion or practice criterion

Procedural
Existence of a written rule- Documented procedure
- Designated officer
- Easy to prove
Necessary condition.

Of practice
Application observed- Files checked
- Staff interviewed
- Harder to prove
Sufficient condition.
Case study: a criterion to be improved
Files kept for too short a time
An auction house keeps its files for five years, instead of ten.
- The auditor notes this during the sample.
- The criterion is rated “to be improved”.
- An action plan is agreed.
The label is awarded with reservation; a new check takes place after six months.
Development of the framework
- Ten criteria
First version.
- Eleven criteria
Addition of cooperation.
- Twelve criteria
Addition of anti-money-laundering.
- Assessment levels
Introduction of the four-level scale.



Development and revision
The framework is revised every three years by the label committee, after consulting holders, auction houses and Member States. Changes are published six months before they enter into force.
Holders have a one-year adaptation period to comply with new or strengthened criteria.
A principle of proportion

« The label does not demand perfection. It demands that everyone knows what they are doing, and proves it. »
Vocabulary of the criteria
- Due diligence
- Checks expected of a prudent professional.
- Action plan
- Corrective commitments agreed after an audit.
- Sample
- Set of files examined by the auditor.
- Exemplary
- Higher level of assessment.
Frequently asked questions
Do the criteria apply to collectors?
Yes, with adaptations; the framework specifies what is required according to profile.
Can a rating be challenged?
Yes, by a written reply to the report, examined by the committee.
How many files are examined?
Twenty in general, more for large houses.
Where can I read the full framework?
In the downloadable document, published on this page.
Useful documents
Contacts

Submit an application
Image credits (24)
- Coin of Eukratides I (170–145 BCE) — Cleveland Museum of Art, CC0 1.0
- Seal Color Box (1662–1722) — Cleveland Museum of Art, CC0 1.0
- Leopard d'Or of Edward III of England (1327–1377) — Cleveland Museum of Art, CC0 1.0
- Necklace Bead and Pair of Pendants in the Shape of an Auspicious Symbol (c. 150 BCE) — Cleveland Museum of Art, CC0 1.0
- Tetradrachm: Owl, Crescent Moon, Olive Branch (reverse) (480–449 BCE) — Cleveland Museum of Art, CC0 1.0
- Carnet (1863–1865) — Cleveland Museum of Art, CC0 1.0
- Coin of Demetrios, I (reverse) (200–190 BCE) — Cleveland Museum of Art, CC0 1.0
- Dragon Fly Brooch, René Lalique (c. 1900–1910) — Cleveland Museum of Art, CC0 1.0
- American Red Cross War Council Medal (obverse), Daniel Chester French (1920) — Cleveland Museum of Art, CC0 1.0
- Plaque (1500s–1600s) — Cleveland Museum of Art, CC0 1.0
- Solidus of Justinian I (obverse) (c. 545–565) — Cleveland Museum of Art, CC0 1.0
- Pendant (1900s) — Cleveland Museum of Art, CC0 1.0
- Portrait of Pope Paul II Barbo (obverse) and (reverse), Cristoforo di Geremia (c. 1468) — Cleveland Museum of Art, CC0 1.0
- Mercury (Budha), from a Mandi Astrology Series, Sanju (c. 1810) — Cleveland Museum of Art, CC0 1.0
- Medal Commemorating Commodore Oliver Hazard Perry (1785-1819) and the Battle of Lake Erie, Moritz Fürst (1813) — Cleveland Museum of Art, CC0 1.0
- Necklace of Brilliants (1700s) — Cleveland Museum of Art, CC0 1.0
- Solidus of Justinian I (reverse) (545–565) — Cleveland Museum of Art, CC0 1.0
- Chemin de fer de Toulouse à Bayonne. Pont de l'Aran (en trois arches de 17m d'ouverture chacune). Situation des travaux au 21 juillet 1861, Édouard Baldus (1861) — Cleveland Museum of Art, CC0 1.0
- American Red Cross War Council Medal (reverse), Daniel Chester French (1920) — Cleveland Museum of Art, CC0 1.0
- The Old Market, Cleveland, Frank Wilcox (1920) — Cleveland Museum of Art, CC0 1.0
- Seal of Doge Michele Steno (reverse) (1400–1409) — Cleveland Museum of Art, CC0 1.0
- Medal Depicting Gian Lorenzo Bernini (1598-1680) from the Illustrious Men of the Kingdom of the Two Sicilies (obverse), V. Catenacci (1830–34) — Cleveland Museum of Art, CC0 1.0
- Leaf from a Lectionary with St. Luke (1057–1063) — Cleveland Museum of Art, CC0 1.0
- Clasp Set with Semiprecious Stones (324–26 CE) — Cleveland Museum of Art, CC0 1.0
Cleveland Museum of Art · CC0 1.0
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