Chapter 03. Vendor Registration and Management
Table of Contents
The UN Secretariat maintains two vendor databases: The UNGM (www.ungm.org), which includes vendors that are interested in doing business with the UN, and the UMOJA database, which includes vendors that have been registered as Business Partners.
In order to maximize economy and efficiency, Procurement Officials and staff in EOS OSCM should continually strive to identify new technically and financially sound vendors. In particular, the UN shall actively work to increase its sources of supply from developing countries and countries with economies in transition.
UNGM acts as a single-window through which potential vendors may register with the entities of the United Nations system, including the UN Secretariat. The vendor registration function in EOS is responsible for any aspects related to vendor registration, establishment and maintenance of vendor files, and assistance to vendors and Procurement Officials in related matters. The Master Data Management Team in UNGSC is responsible for synchronizing the UNGM vendor registration data into UMOJA as Business Partners. VRO/EOS may also synchronize UNGM vendor registration data into UMOJA as Business Partners.
Vendors wishing to participate in solicitation exercises conducted by the UN Secretariat must have completed the process of self-registration at the Basic Level in the UNGM portal, including confirmation of the acknowledgment of the United Nations Supplier Code of Conduct. Unless otherwise indicated in the Request for Expression of Interest (REOI) or solicitation instructions, a completed registration at the Basic Level suffices to participate in UN Secretariat solicitation exercises.
Vendors that are not registered at the Basic Level in UNGM or have been suspended (even if they are in the process of being reinstated) shall not be invited to participate in solicitation exercises and shall not be eligible to submit a bid or even receive the solicitation materials.
Furthermore, vendors are required to be registered at the appropriate level prior to contract award. Contracts shall only be awarded to eligible vendors that are registered with the United Nations Global Marketplace, unless specific exceptions apply (please see Chapter 3.1.4).
The UN evaluates vendor applications to determine whether the application complies with established UN requirements as set forth below and whether vendors are thus eligible for registration. Successful and eligible applicants are duly registered as UN Secretariat vendors.
Under exceptional circumstances (e.g. the vendor cannot access UNGM or has insufficient knowledge of any of the languages supported by UNGM) or as requested by the Director, PD or Chief, Enabling and Outreach Service, the UN may assist a vendor in completing the registration process in UNGM. In such instances, a signed vendor registration form shall be obtained from the vendor, including an Eligibility Form and statement that the vendor accepts the Supplier Code of Conduct and the UN payment terms.
Information about a vendor in UNGM, as maintained by the vendor, is replicated in UMOJA when required. Authorized staff members initiate the replication manually, and the information is thereafter replicated automatically from UNGM to UMOJA. This action is typically taken when Procurement Officials have determined that vendors not yet replicated in UMOJA need to be added to the List of Invitees.
The UN’s vendor registry consists of three (3) levels, each with distinct risk profiles and registration requirements: Basic Level, Level 1 and Level 2.
Vendor Registration Level
< US$ 150,000
≥ US$ 150,000 and ≤ US$ 500,000
> US$ 500,000
TABLE 2. UN VENDOR REGISTRATION LEVELS
Registration at the Basic Level is a fully automated process in UNGM and can be completed online by the vendor. This allows the vendor to be invited to participate in solicitations. To be synchronized in UMOJA, at the Basic Level, the UN reviews compliance of the vendor with the Pre-requisites for Eligibility.
It is only at the time of contract award that the vendor under consideration needs to be registered at registration Level 1 or 2 for awards above US$ 150,000. However, no vendor may participate in any solicitation exercise unless it is fully registered, at a minimum, at the Basic Level, at the time of the issuance of the solicitation. If within a period of time following the issuance of the solicitation, a vendor registers at Basic Level, the Procurement Official may, at his/her sole discretion, include the vendor in the List of Invitees. With regards to joint ventures, please refer to Chapter 188.8.131.52.
Registrations at Levels 1 and 2 shall be initiated by the vendor but require evaluation by the UN before they come into effect.
Registration as a vendor is subject to the following:
- a. All information provided to the UN must be certified as true and correct. The UN may unilaterally seek at any time to clarify and/or conduct further research on any concern it may have regarding the eligibility of a vendor and to take such action that it may deem appropriate under the circumstances.
- b. Registration of a vendor in UNGM indicates that the vendor is eligible to participate in UN Secretariat tender activities (subject to evaluation of eligibility criteria). Registration does not guarantee an invitation to a solicitation exercise or contract award.
184.108.40.206 Pre-Requisites for Eligibility
To become registered vendors to be able to participate in UN solicitation exercises and receive solicitation materials, applicants are required to declare that:
- They are not a company, or associated with a company or individual, under procurement prohibition by the United Nations, including but not limited to prohibitions derived from the Compendium of United Nations Security Council Sanctions Lists;
- They are not currently removed from the registered vendor list or suspended as registered vendors by the United Nations or any other entity of the UN system including the World Bank;
- They are not under formal investigation, nor have been sanctioned within the preceding three (3) years, by any national authority of a United Nations Member State for engaging or having engaged in proscribed practices, including but not limited to: corruption, fraud, coercion, collusion, obstruction, or any other unethical practice;
- They have not declared bankruptcy, are not involved in bankruptcy or receivership proceedings, and there is no judgment or pending legal action against them that could impair their operations in the foreseeable future;
- They do not employ, or anticipate employing, any person(s) who is or has been a UN staff member within the last one year (12 months), if said UN staff member has or had prior professional dealings with the vendor in his/her capacity as UN staff member within the last three years (36 months) of service with the UN (in accordance with UN post-employment restrictions contained in ST/SGB/2006/15; and
- They undertake not to engage in proscribed practices (including but not limited to: corruption, fraud, coercion, collusion, obstruction, or any other unethical practice) with respect to the UN or any other party, and to conduct business in a manner that averts any financial, operational, reputational or other undue risk to the UN.
When a consortium or joint venture submit a joint proposal as a single bidder on behalf of all of its members, all of the members of the consortium/joint venture must meet the criteria requirements described in this chapter. If in the judgment of the Procurement Official an award is considered, the Procurement Official shall submit a request for special approval of the joint venture to the e-SAC. In addition, should the contract be awarded to the consortium/joint venture, risk mitigation measures in the form of liability provisions, warranties, and/or other assurances are to be included into the contract as appropriate, in consultation with OLA. It preferred and strongly recommended that contracts be signed with a prime vendor. Any partners acting as subcontractors in joint ventures can give rise to legal risk. If a joint venture is considered for an award, it is necessary for the Director PD or CPO - who may consult the Office of Legal Affairs (OLA) - to provide advice before a decision is taken.
In the case that a vendor’s situation changes with regard to any of the statements listed under paragraphs 220.127.116.11 a-f, the vendor shall immediately inform the UN Secretariat (e-mail to firstname.lastname@example.org).
18.104.22.168 Registration Levels
To be registered at a certain level, vendors must provide the following information and documents:
Basic Level registration:
- Vendor information such as officially registered company name, owners, address, contact information, telephone, e-mail, etc.;
- Declaration of meeting the Pre-requisites for Eligibility;
- Acceptance of UN Supplier Code of Conduct;
- Selection of United Nations Standard Products and Services Code (UNSPSC) Commodity Codes of goods/services offered.
Level 1 registration
- Basic registration criteria;
- Proof that the vendor has been in business for a minimum of 3 years2;
- Current certificate of incorporation or equivalent document verifying legal status;
- Identification of at least three (3) independent, non-affiliated clients/companies with whom the vendor has conducted business over the previous 12 months, including details of the projects (client name and contact details, description of the project/work undertaken, start and completion date, and if feasible, the contract value of the project);
- Name of owner(s) and principals (including the parent company, subsidiaries/affiliates, CEO/Managing Director, and those with controlling interest, if applicable, including under any former corporate incarnation; and
- The names of intermediaries, agents and/or consultants (if any) employed in relation to United Nations contracts or bids/proposals.
Level 2 registration
- Basic and Level 1 registration criteria;
- Audited / Certified financial statements for the previous three financial cycles, consisting of Audit Report / Review Report (Statement of Opinion) by independent and accredited Audit / Accounting firm, Income Statement, and Balance Sheet. For privately held companies who do not have audited financial statements, the VRO will request certified financial statements (consisting of Income Statement and Balance Sheet accompanied by Review Report by independent / accredited Accounting firm) with a statement of opinion or a compilation report which will be considered in exceptional circumstances for review by the e-SAC; and
- Three reference letters from non-affiliated clients/companies with whom the vendor has conducted business with over the past year (12 months). The letters must be on the Reference company’s letterhead and signed by an authorized official of the Reference company.
22.214.171.124 Special Considerations and Requirements for Specific Vendor Types
126.96.36.199.1 Air Operators
The United Nations only awards contracts for long-term air charter requirements and short-term passenger movements to air operators in a possession of an Air Operator Certificate (AOC) authorizing them to operate in the area of interest to the UN, with all types of aircraft required by the UN. Prospective contractors for such aircraft charter services are required to demonstrate their ability to comply with the requirements of the United Nations and have sufficient technical and financial resources to conduct safe operations.
The process to become a registered Air Operator of the UN Secretariat for the services described above consists of two-steps: a technical application and an administrative/commercial application. A technical evaluation of each vendor to determine the potential contractor’s capabilities to perform the services is required and is typically conducted by OSCM. As is the case for all vendors, the administrative/commercial application is submitted and conducted online through the UNGM platform where Air Operators must register at Level 2. The review of administrative/commercial applications will be conducted for those vendors whose technical application is considered to be compliant.
Air transportation companies interested in participating in solicitations and being considered for UN contracts must comply with relevant air operator registration requirements. (https://www.un.org/Depts/ptd/aviation).
The technical aviation vendor registration team reserves the right to impose additional aviation safety risk-mitigating measures on air operators applying for UN flight service vendor registration, and technically cleared flight service vendors. This is to benefit aviation safety in UN air transport services and to limit the Organization’s exposure to potential legal, financial, reputational and other liabilities.
Registered Air Operator vendors must maintain full compliance with the technical and administrative/commercial requirements for registration as Air Operators with the United Nations Secretariat. EOS/VRO, upon determination that a vendor has failed to remain in full compliance with the technical and/or administrative/commercial criteria may approve and carry out the removal from the list of registered United Nations Air Operators prequalified to participate in UN solicitations, and such status will be reflected in the corresponding Umoja and UNGM records; EOS/VRO shall notify the vendor accordingly. This shall render the Air Operator ineligible to participate in or be invited to future solicitations and awards until such time that full reinstatement efforts in line with relevant compliance requirements have been made by the vendor and the respective UN offices endorses the reinstatement.
188.8.131.52.2 Sole Proprietorships
Due to exposure of sole proprietors to personal liability, the United Nations typically does not enter into a contractual relationship with this type of legal entity.
In cases where local business practices and/or the nature of relevant requirements demands, sole proprietorships applying for registration at the Basic Level shall be approved by the Chief, VRO based on a written justification from the Procurement Official, in view of local business practices and the nature of goods and/or services solicited.
In cases where local business practices and/or the nature of requirements demands, sole proprietorships applying for registration above the Basic Level shall be referred to the e-SAC for special consideration of approval. Sole Proprietors require a BP in Umoja.
Sole proprietorships cannot be contracted to provide consulting services.
184.108.40.206.3 Low Value Acquisition Vendors
Low value acquisition vendors for requirements of up to US $10,000 are not required to be registered in UNGM, however they are checked against the list of UN sanctioned vendors and require a commercial BP in Umoja.
220.127.116.11.4 Special Commercial Categories
When not feasible, Hotels/conference centers and utility companies are not required to be registered in UNGM, however other appropriate commercially prudent verification
s are to be conducted and they are also to be checked against the list of UN sanctioned vendors prior to establishing a commercial BP in Umoja.
Individual landlords are not required to be registered in UNGM, however other appropriate commercially prudent verification
s are to be conducted and they are also to be checked against the list of UN sanctioned vendors prior to establishing a commercial BP in Umoja.
The Chief, EOS shall designate Vendor Registration Officers (VRO/VROs) who are responsible to evaluate vendor registration applications, create and maintain vendor records, and provide support service to the UN Secretariat for matters involving vendor registration.
The evaluation of vendor registration applications is conducted by the VRO based on the criteria stated in this chapter. The VRO either approves the registration application, requests additional information/documentation as deemed necessary to complete the review process or denies the application.
Registrations at Level 2 require a thorough review of the applicant’s financial status (i.e., revenue, profitability and liquidity). During the review, the VRO analyses information from documents submitted by the vendor (i.e., financial statements), information obtained through business information services and other sources as appropriate. The VRO shall use the standard financial review methodology as established by the Chief, EOS.
The VRO, using established financial assessment criteria, shall evaluate whether a vendor registering at Level 2 is in sound financial condition. Failure to submit the required financial data shall disqualify the vendor for registration at Level 2.
Annex 4— Special Approval Request Form for Registration
Following the evaluation and uploading of vendor documentation into UNGM, the VRO shall maintain documentation in an electronic platform, which shall be available upon request for review by Procurement Officials. Performance Evaluation Reports received from the Requisitioner should be submitted/forwarded by Procurement Officials to the VROs to be maintained in their respective vendor files.
All registered vendors are required to update UNGM and inform the UN immediately - in writing - of any material change in the information or documentation provided to the UN, setting out all relevant details. All vendors must immediately update their online application in UNGM, uploading additional documentation. A follow-up communication or alert may be in the form of an online application update, letter, fax or email, and shall include all relevant documentation.
Upon the UN’s request, which may occur as part of a pre-qualification or solicitation exercise or through UNGM automated periodical notifications, registered vendors are required to submit their updated financial statements and other relevant documentation.
If a vendor undergoes a legal name change, the vendor is required to upload to the UNGM certified true copies of all legal documents relevant to the transactions that led to the name change, including new certificate of incorporation, or documents relevant to a merger, takeover, etc.
All exchange of information and documentation in support of the vendor registration should be conducted online through UNGM. The vendor is likewise informed of the status of their application through the UNGM e-mail notification system.
The VRO, shall review compliance with the Pre-requisites for Eligibility and related documentation, to assess the continued eligibility of vendors both at the time of registration and after they have been registered with the UN Secretariat.
The Vendor Review Committee (VRC) is an internal administrative body tasked with making recommendations to the Under-Secretary-General for the DMSPC regarding possible sanctions against, and possible reinstatement of, vendors following the review of cases related to:
- Vendors who may have engaged or attempted to engage in proscribed practices (including but not limited to corruption, fraud, coercion, collusion, obstruction, sexual exploitation or any other unethical or anti-competitive practice);
- Vendors who have failed to perform in accordance with the terms and conditions of their contract(s) with the UN to the extent that it would warrant suspension;
- Prior to registration, a failure to (a) meet any of the applicable “Pre-Requisites for Eligibility” set forth in Chapter 3.1.4 above, (b) submit a Declaration of Eligibility, or (c) accept the UN Supplier Code of Conduct;
- Following registration, non-compliance with (a) any of the applicable “Pre-Requisites for Eligibility” set forth in Chapter 3.1.4 above, (b) statements made in the Declaration of Eligibility, or (c) the undertakings contained in the UN Supplier Code of Conduct;
- Vendors who requested reinstatement and have satisfactorily completed the reinstatement process.
The VRC will recommend to the USG, DMSPC whether to censure, suspend, remove, accept or reject registration or reinstate a previously suspended or removed vendor.
The VRC has a quorum when three members, including the Chairperson, are present. The membership of the VRC is comprised as follows:
- Director, BTA, DMSPC, or her/his officer-in-charge, who serves as Chairperson;
- A representative from the Office of Programme Planning, Finance and Budget, who will also act as alternate chair in the absence of the Chairperson;
- A representative from DOS;
- A representative from the Department of Economic and Social Affairs.
Representatives of the procurement office responsible for the administration of the associated contract(s), the requisitioning office responsible for the management of the associated contract, or a representative of Office of Internal Oversight Services (OIOS), OLA or the Ethics Office may be invited to attend meetings of the VRC in an ex officio capacity.
The VRC will be supported by a secretariat responsible for preparing and presenting the case to the VRC members, taking minutes of meetings, circulating minutes and related documents for clearance of the members and signature by USG, DMSPC. The secretariat is a supportive function of the VRC and does not participate in the substantive discussions of the VRC.
The VRC does not communicate or meet directly with vendors. The decision of the USG, DMSPC is communicated to the vendor once taken, by Chief, EOS.
Where the UN has received evidence that one of the instances described in Chapter 3.3 a (i)-(v) has occurred, the secretariat of the VRC will be requested to submit the case for review by the VRC. Upon receipt of a case presentation from the secretariat, the VRC reviews the information and documentation and may seek additional expert advice from relevant, substantive UN offices, such as OLA or the Ethics Office. The deliberations of the VRC and the decision of the USG, DMSPC are recorded in writing and kept in the vendor file in the form of approved minutes.
Evidence of a vendor’s failure to perform under a contract with the UN should not automatically result in a submission to the VRC with a recommendation to sanction such vendor. Instances of performance issues that do not, in the UN’s view, materially affect the vendor’s compliance with the contract or otherwise warrant suspension should be handled in accordance with Chapter 13.
Upon examination, the VRC makes a recommendation to the USG, DMSPC on whether to sanction or reinstate a vendor in UNGM, seek clarifications and consultation, accept or reject a vendor’s registration or take no action. The VRC may also determine specific conditions under which a suspension can be lifted.
If the VRC recommends that the vendor be sanctioned, the period of time and any associated conditions recommended for such sanction should be clearly defined.
The VRC meets in person (which includes video links) to deliberate on the case presented.
All VRC recommendations to the USG, DMSPC are made in writing. The VRC secretariat maintains a repository of the minutes of the VRC and written decisions of the USG, DMSPC in the applicable vendor file. A copy of such decisions and minutes will be communicated by the VRC secretariat to the Chief, Enabling and Outreach Service, the Director, Procurement Division, the relevant requisitioner, and the procurement office responsible for the administration of the associated contract(s), immediately upon signature.
The Model Policy Framework (MPF) on Vendor Sanctions is the set of policies and guidelines that UN organizations follow in order to sanction vendors in the UNGM that have been involved in proscribed practices such as fraud, corruption, collusion, coercion, unethical practices, and obstruction. The MPF allows UN agencies and entities to establish sanction procedures that meet their specific requirements while at the same time allowing for the harmonization of efforts throughout the UN system.
Each UN organization nominates an officer to the role of Ineligibility List Administrator (ILA) to administer, maintain and update the list of ineligible vendors. For the UN Secretariat, this role will be performed by the Secretary of the VRC.
Upon receipt of the recommendation of the VRC, the USG, DMSPC decides whether to sanction a vendor. The vendor shall be notified in writing as appropriate by Chief, EOS.
The USG, DMSPC, upon recommendation by the Vendor Review Committee, may impose any of the following sanctions or a combination of them:
- Censure: A reprimand in relation to a vendor’s conduct. Censure does not affect the vendor’s eligibility, but its existence will be an aggravating factor for imposing sanctions in future proceedings.
- Suspension: A decision that, for a period of time determined by the UN, a vendor has become ineligible to: be awarded UN contracts; partake in UN procurement solicitations; conduct new business with the UN as agent, representative or subcontractor of other vendors; partake in entering into direct negotiations with the UN regarding new contracts. At the conclusion of the set time period, the vendor’s status will be reviewed by the VRC, and a recommendation made to the USG, DMSPC that the vendor either be reinstated (with or without conditions), the suspension period be extended, or the vendor removed from the UN vendor register.
- Removal: A decision that a vendor shall be removed from the register and rendered ineligible to participate in any aspect of UN procurement including to: be awarded UN contracts; partake in UN procurement solicitations; conduct new business with the UN as an agent, representative or subcontractor of other vendors; partake in entering into direct negotiations with the UN regarding new contracts. A vendor that has been removed from the register may apply for reinstatement if the conditions giving rise to the removal have materially changed. It is within the UN’s sole purview to determine the veracity of such a claim and determine the action to be taken.
- Other Sanctions: Any other sanctions that the VRC finds appropriate under the circumstances of a case, including but not limited to, a recommendation that would subject existing or future contracts to special conditions, etc. These other sanctions may be imposed in addition to or in place of censure or suspension or removal.
The notice of sanction advises the vendor of the UN’s decision to sanction them, either for a specific period of time or by its removal from the UN vendor register and specifies the reasons for the decision. In addition, the notice informs the vendor that it may request a review of the decision. If applicable, the notice also should list any relevant corrective action that the vendor must take in order to be considered for reinstatement.
Notices are sent by mail, with return receipt requested, or by email with a confirmation of transmission requested. A copy of the return receipt or confirmation of transmission is kept in the vendor’s file. The vendor is entitled to a maximum period of 30 days following the UN’s receipt thereof to request a review of a UN decision imposing a sanction. Upon receipt of the vendor’s request for review, the VRC makes a recommendation to the USG, DMSPC, who determines whether to maintain, reverse, or amend the decision.
In cases where the VRC recommends suspension of a vendor that has an ongoing contractual relationship with the UN, the recommendation will specify whether to terminate or allow continuation of an existing contract(s), to ensure that the best interests of the UN, including but not limited to operational needs and the security of UN personnel and property, are duly protected. In such cases, the USG, DMSPC, shall take note of the VRC recommendation in relation to the existing contract(s), and may decide to refer the recommendation on such contracts to the relevant Authorized Official for decision.
The Requisitioner is notified of such cases and shall consult with PD on action to be taken, such as termination of the contract. PD or the CPO, as appropriate, and in consultation with OLA, ensures that the interests of the UN are duly protected in connection with any termination of a contract, taking into account considerations including but not limited to operational needs and the security of UN personnel and property.
If a vendor requests reinstatement, whether following a finite period of suspension or in other instances, the VRC shall review the request. This review includes but is not limited to evaluating whether any special conditions, if applicable, have been met and if sufficient evidence is presented to support the vendor’s request. In addition, the VRC may recommend additional conditions in order for the vendor to be considered for reinstatement.
SOP on Vendor Review Committee Review Process
The e-SAC reviews cases related to vendors that do not meet the registration criteria required for the respective level of registration. This Committee is an internal body within OSCM tasked to evaluate and determine the eligibility of a vendor to be registered as or remain registered at the desired qualification level.
The review of the e-SAC is directed towards an exceptional special approval of a vendor at the desired qualification level when the vendor does not meet all necessary criteria for the appropriate registration level. The reasons for such special approval will subsequently be documented in the vendor registration file maintained by EOS.
E-SAC Review Process. As soon as a recommendation of award is evident, in case the vendor is not registered at the appropriate level the Procurement Official, as needed, will draft and submit to the VRO a request for special approval based on the template attached in Chapter 3.2.1. The VRO will review the request and seek clarification, if any, with the Procurement Official. The case for consideration of the e- SAC for special approval will be submitted by the VRO to all members of the e-SAC via email, with a recommendation pertaining to the registration level of a vendor. The e-SAC is an internal review body and does not communicate or meet directly with vendors. The e-SAC’s deliberations are conducted electronically, and the e-SAC’s recommendation(s) take full effect only upon approval from the Chief, EOS.
The e-SAC has a quorum with three voting members present, including the Chairperson. The membership of the e-SAC is comprised as follows:
- Chairperson of e-SAC (Chief of Service, PD);
- a representative from the PD;
- a representative from a requisitioning office.
Representatives from PD and the requisitioning office will serve on a rotating basis and will not be invited to the e-SAC for those cases where they or their section are involved.
A vendor’s failure to meet or continue to meet the criteria for the respective level of registration, as based on substantial and documented evidence, will give cause for consideration whether to grant special approval for a level of registration and adjust the respective level of the vendor’s registration in UNGM.
The e-SAC reviews the case and recommends whether to either accept or reject the vendor’s registration level or accept the vendor’s registration level for a specific contract(s) only, taking into consideration the published criteria for registration and other factors including the potential financial risk to the Organization. The e-SAC makes certain that the standards are set at reasonable levels to ensure that small and medium-sized applicants from developing countries and countries with economies in transition are not unduly rejected, while all measures must be taken to mitigate risk for the Organization. Any special approvals of registration for a specific contract shall detail if it includes all optional extensions. Any subsequent extensions beyond those originally submitted to the e-SAC shall be submitted for its review.
Upon receipt of a case presentation from the VRO for the review of a vendor’s registration status, the e- SAC reviews all relevant evidence, taking the factors above into consideration. The e-SAC may recommend granting special approval for a vendor for multiple or single solicitations and/or award(s). Once a determination is made by Chief, EOS for special approval of a vendor, the vendor relevant data in UMOJA will be enriched to reflect the approved level. The vendor’s registration level in UNGM will remain unchanged.
SOP on Special Approval of Vendor Registration Level
2 Vendors that have not been in incorporated for a minimum of three years but were incorporated as a different entity (e.g. under a different name) prior to the date of incorporation of the current company, shall provide sufficient proof thereof. The Vendor Review Officer (VRO) may accept such application, provided that both the current and the prior company meet the pre-requisites for eligibility and other requirements for registration at a specific level.