While we prepare for the release of ISO 14001:2026 next January, businesses can still implement and be certified to ISO 14001:2015 until at least June 2027. After the final version is released in Q1 2026, during the early-phase transition period; we will update our customers with the documentation they need to revise their environmental management system.
ISO 14001:2026 change and action summary
Start your ISO 14001:2026 transition planning early by reviewing our change and action summary to help you avoid disruption and maintain certification. The ISO 14001:2026 update will focus on clarifications and alignment rather than sweeping new requirements.
Clause 4 Context of the Organization
Change summary: The revision places a greater focus on how external environmental factors, such as climate change, biodiversity, and resource availability, both affect the organization and are affected by its operations.
This includes considering aspects like greenhouse gas emissions and climate action more explicitly within the EMS. This reflects the growing global imperative to address critical ecological issues.
- Clause 4.1 Environmental conditions (e.g., climate change, pollution, biodiversity) must now be explicitly considered. Environmental conditions such as pollution levels, climate change, biodiversity, and ecosystem health must now be considered as external issues.
- Clause 4.2 Stakeholder needs and expectations may now include expectations related to
- environmental conditions (e.g., climate change, pollution, biodiversity). Relevant interested parties can have requirements related to climate change.
- Clause 4.3 EMS scope must reflect a life cycle approach. The standard will shift from ‘considering’ to actively applying lifecycle perspectives in environmental planning.
- Key documents must be available as documented information.
Your action: Update context analysis, stakeholder maps, and scope definition. Update your context analysis to include specific environmental conditions. Revisit your stakeholder analysis and evaluate new environmental expectations. Ensure your EMS scope takes a lifecycle perspective into account. Review how you make key EMS documents available to interested parties.
Clause 5 Leadership
Change summary: The revision places greater emphasis on top management's personal involvement and accountability in driving environmental performance. While tasks can be delegated, ultimate responsibility remains with leadership, designed to foster a stronger culture of environmental responsibility throughout all areas of the business.
- Clause 5.1 Top management must support all relevant roles, not just management roles.
- Updated terminology: The term ‘meet compliance obligations’ replaces ‘fulfil’.
- Greater emphasis on conserving natural resources and ecosystem protection.
Your action: Revise your environmental policy to reflect revised terminology and broader commitments and ensure executive engagement. Ensure top management understands the broader scope of leadership in the EMS. Ensure that the environmental policy is accessible to all stakeholders both internally and externally.
Clause 6 Planning
Change summary: The approach to identifying and addressing environmental risks and opportunities has been further improved, with clearer links between environmental aspects, compliance obligations, and planned actions.
This aims to promote a more proactive and strategic approach to managing environmental performance.
Change management has been done to ensure that positive environmental outcomes remain consistent and no unintended environmental impacts slip through the cracks.
- Clause 6.1.1 Planning to address risk and opportunities will be split into:
- 1.4: identify risks and opportunities.
- 1.5: plan actions accordingly.
- Clause 6.1.2 When evaluating environmental aspects and impacts, emergency situations must be separate from ‘abnormal’ operations, e.g., normal, abnormal, and emergency.
- Clause 6.3 This new clause requires a structured approach to EMS change management.
Your action: Review your planning documentation to reflect new clause references. Separate your planning processes into identification (6.1.4) and action (6.1.5), and refresh your risk register, aspect and impact register, and other planning documentation as needed.
Introduce a structured change management approach as required by Clause 6.3. Update your aspect and impact analysis to include potential emergencies. Reassess the effectiveness of your objectives and KPIs in Clause 6.2.
Clause 7 Support
Change summary: The new version recognizes the growing role of digital solutions, such as AI and data analytics, in driving environmental performance. Organizations will be encouraged to use technology to monitor, manage, and report in real time, increasing efficiency and accountability.
- Terminology now standardized: all EMS records must be ‘available’, instead of ‘maintained’ as documented information.
- Clause 7.4 Communication must empower employees to contribute to continual improvement.
Your action: Review communication and training processes, ensuring evidence is documented and accessible. Ensure that top management and all relevant personnel involved in the EMS are aware of the upcoming changes and their potential impact on their roles and responsibilities. EMS communications, both internal and external, are traceable and transparent. Adjust process descriptions to align with revised terminology.
Clause 8 Operation
Change summary: The revision now states that organizations must control or influence externally provided processes, products, or services that are relevant to their EMS, including those from suppliers. Evaluate upstream and downstream impacts and encourage suppliers to adopt sustainable practices. The level of control must be clearly defined and documented. This encourages a fully-rounded approach to sustainability within your supply chain.
- Clause 8.1 Outsourced processes are referred to as ‘externally provided processes, products or services’.
- Operational control must extend to suppliers and partners.
- Clause 8.2 Emergency preparedness must align with risk planning (Clause 6.1.2).
Your action: Strengthen supplier management by identifying all externally provided processes and assessing existing control mechanisms. Review your supplier evaluation and environmental performance checks. Review your existing emergency response plans to ensure they reflect updated planning clauses. Ensure operational documentation is accessible and consistently maintained.
Clause 9 Performance evaluation
Change summary: The management review process has been reorganized into sub-clauses for '9.3.1 General', '9.3.2 Inputs', and '9.3.3 Results' to provide clearer audit trails and help you demonstrate that you are driving real improvements.
- Clause 9.1.1. Explicit requirement to evaluate environmental performance and EMS effectiveness.
- Clause 9.2.2 Internal audits must define objectives, in addition to the scope and criteria.
- Clause 9.3 Management reviews are restructured into three sub-clauses: inputs, process, and results.
Your action: Update internal audit and management review processes. Update your internal audit protocols to include defined objectives. Ensure performance evaluation includes EMS effectiveness, not just data points. Revise your management review process to follow the new substructure of Clause 9.3.
Clause 10 Improvement
Change Summary: The ongoing commitment to continual improvement and the obligation to improve the EMS remains a core principle of the environmental standard.
- Clause 10.3 was removed, and its content is now integrated into Clauses 10.1 and 10.2.
- More structured approach to nonconformity and corrective action.
- Clear linkage between Clause 9 findings and continual improvement.
Your action: Strengthen root-cause analysis and improvement tracking. Update your internal audit protocols to include defined objectives. Ensure performance evaluation includes EMS effectiveness, not just data points.
What is the proposed transition timeline?
Below is a realistic timeline with a phase-based approach; however, the timeline is not yet definitive until the new version is officially released. It is likely that by:
- October 2025: Draft International Standard (DIS) released, allowing businesses and certification bodies to provide feedback.
- January 2026: Final publication of ISO 14001:2026 expected. The standard three-year transition period is expected, during which certified organizations must update their management systems to the new standard.
- January 2026 to 2027: Early-phase in which companies should start analyzing gaps and aligning their EMS with the new requirements. During this early-phase transition period, we will update our customers with the documentation they need to revise their environmental management system.
- January 2027 to 2028: Mid-phase in which Certification bodies will update their auditing protocols to assess compliance with the revised standard. This will allow businesses plenty of time to upgrade their environmental management systems to incorporate the additional requirements.
- January 2028 to 2029: Final-phase in which all businesses must get their systems audit-ready before the transition period ends and complete the formal transition audit before ISO 14001:2015 certifications become invalid.
During the transition period, organizations can still get certified to the 2015 version, but they will need to transition to the 2026 version by the end of the transition period, which is expected in January 2029, to maintain their certification.
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