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Preparing for COUNTER Release 5 Compliance

This document page is especially aimed at Content Providers (publishers and vendors) preparing to comply with the COUNTER Code of Practice. You can also download the PDF.

The COUNTER Code of Practice is the technical specification for counting and reporting the usage of electronic resources. Compliance with the Code of Practice ensures that your customers receive credible, consistent and comparable usage statistics. It also means that library electronic resource management services and library consortia can easily harvest your usage reports on behalf of their customers or members.

Compliance with the COUNTER Code of Practice requires all Content Providers to undergo an annual independent audit of their COUNTER usage reports.

In this document, we explain what an audit looks like and what the process is for completing an audit for Release 5 of the Counter Code of Practice.

So, what is a COUNTER Audit?

An approved independent auditor completes a COUNTER audit. The role of the auditor is to verify that your usage reports are being generated in compliance with the COUNTER Code of Practice.

Auditing involves the auditor using your service to review and check your usage reporting, looking for any inaccuracies and suggesting improvements if they’re required. There are four steps to follow when preparing for compliance and a COUNTER audit:

  1. Understand and implement the Code of Practice
  2. Review and test your own usage reports in both Tabular and JSON format
  3. Become a member of COUNTER
  4. Choose an auditor.

Let’s go into these steps in a bit more detail…


Step 1

Familiarize yourself with the Code of Practice. Remember, the Code of Practice enables providers to produce consistent, comparable and credible usage data for their online content.

The Code of Practice is a technical document, so we recommend you check out the ‘Friendly Guide’ first.

Contact the COUNTER Project Director to agree which COUNTER usage reports are relevant to the type of content you publish, and therefore which usage reports you’ll be required to audit.

Table 3.b in section 3 of the Code of Practice is a key resource when deciding on your ‘Host_Type’ and therefore which COUNTER reports are suitable for your type of content.

Note all Content Providers must provide the Platform Master Report (PR) and its Standard View (PR1). Whatever reports are suitable for your type of content, you must provide the Master Report in order to be compliant. The Standard Views are derived from the Master Report.

When reading the Code, it’s important to review Section 3.0 – the Technical Specifications for COUNTER Reports, and Appendix E – the Audit Requirements and Tests. These can all be found on the COUNTER website.


Step 2

Use our Validation Tool to check the format of your Tabular and SUSHI reports. This will allow you to correct any errors.


Step 3

Become a member of COUNTER and sign our Declaration of Compliance


Step 4

Once you have ensured your reports follow the Code of Practice, you are ready to choose your auditor. Contact details for all the approved auditors are available on the COUNTER website.

COUNTER will also accept an audit by any Chartered Accountant in the UK, CPA in the US or their equivalent elsewhere.

The auditor does not review every report you have produced over the last 12 months; instead, they take a “snapshot” of your activity, assuring that it is compliant (or that it remains compliant, even if you passed last time). You should, therefore, discuss with your auditor when you would like the audit to take place. Choose a time when you will be able to provide them with the support they need in order to carry out the audit. If you are planning any upgrades to your platform, schedule the audit for after these have taken place.



So, now you know how to prepare for an audit, let’s take a look at what a typical COUNTER audit looks like.

A COUNTER audit follows a three-stage process. Here’s what you can expect in each…

You will need to help the auditor by providing log-in details and appropriate access rights, and they may have some compliance suggestions for you at this stage.




The time involved in completing your COUNTER audit is partly dependent on the number of usage reports to be checked. But it will typically require around three months to complete the three stages, assuming everything runs smoothly. (Remember this when you come to schedule next year’s audit, so that you don’t run the risk of falling out of compliance if there is any delay.)

If all has gone well and no issues arise, you’ll receive a report from your auditor confirming successful completion. This report is shared with COUNTER, so that your entry in the COUNTER Registry of compliant publishers can be updated.

Your entry in the Registry shows the date of your COUNTER audit, the date you passed the audit and when the next audit is due. It also lists the compliant reports available from your organization.

You will need also to share with COUNTER your SUSHI details, so these can be added to your entry in the COUNTER Registry.


If any issues of non-compliance are found, your auditor will advise you and COUNTER of these in an Interim Report and work with you to correct them. The Code of Practice allows up to three months from the date of the Interim Report for corrections to be made.

Once you believe all the issues are resolved, your auditor will re-run the usage reports. They will check them against the original activity in order to confirm their compliance.

Once you’ve received the good news and you’re COUNTER compliant, we’re sure you’ll want to promote this achievement!

The easiest way to do this is to use the COUNTER date-stamped logo which COUNTER will send to you. You can use this in your promotional material, on your website and in your email signatures. The date-stamped logo must link back to your entry on the COUNTER Registry of compliance.


The word “audit” might sound a bit frightening, but these steps, coupled with the information provided in the ‘Friendly Guides’ and FOUNDATION Classes, should help ensure it’s easy to do.


Between audits

Because platform technologies and systems are updated, a COUNTER audit is an annual requirement. Between audits, small changes to your platform may impact your COUNTER reports. We recommend that you use the Validation Tool to test them on a monthly basis.



Some smaller publishers prefer to contract an expert third party to provide COUNTER data processing and reporting processes on their behalf. In these cases, the third party, rather than the Content Provider, is audited for COUNTER compliance. The COUNTER Project Director can provide a list of companies that offer these services.

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