Climate Change in ISO 9001:2026: What Clause 4.1 Asks You to Decide

Climate change is now in the main text of ISO 9001:2026. ANSI's release on publication lists "climate change carried into the main text, folding in the 2024 amendment to the 2015 edition" among the updates (ANSI, September 16, 2026). This article explains what it is, in plain words.

A note on sources. This is our own summary, not ISO text. We have not checked the 2026 clause wording against the standard itself, so check your own licensed copy.

What the 2024 amendment says

The ISO 9001 Auditing Practices Group's guidance on auditing climate change issues sets out the two changes made by the 2024 amendment to ISO 9001:2015:

• Clause 4.1 (context of the organization): a sentence was added saying the organization must determine whether climate change is a relevant issue.

• Clause 4.2 (interested parties): a note was added saying relevant interested parties can have requirements related to climate change.

(ISO 9001 Auditing Practices Group, Auditing Climate Change issues in ISO 9001, Edition 1, March 19, 2024). That paper says it has not been through ISO's, ISO/TC 176's or IAF's endorsement process, and is for educational and communication purposes. We have not seen the 2026 text of these clauses, so we cannot say whether the wording is the same.

What it does not require

The same guidance paper says the amendment "does not require an organization to have climate change initiatives unless it has been identified as a relevant issue to achieve the intended results of the QMS". It also says relevance varies with factors such as the size and sector of the organization, its products and services, its place in the supply chain, its geography and the scope of its system, and may "span the spectrum from no relevance to extremely relevant".

Our reading: decide, and keep a note of how you decided

Our reading of the amendment: work out whether climate change matters to your organization, and keep a note of how you decided. "Not relevant" can be a valid answer if you can show you considered it. The APG paper says auditors are to evaluate how the organization demonstrates it has determined whether climate change is a relevant issue, in the context of the quality management system and its intended results.

A note of how you decided does not need to be long. A few lines in your context analysis are one way to do it:

• What you considered (for example, regulation, customer expectations, supply chain, your premises)

• What you concluded: relevant, or not relevant

• Why

• When you will look again

Two checks

1. Does your context analysis (clause 4.1) have a line on climate change, with the reasoning?

2. Do customers or regulators expect anything climate-related from you? If so, does your interested parties register (clause 4.2) say so?

These are two of the questions in our free Gap Analysis Checklist for ISO 9001:2026 (questions 2 and 5). They are our own suggestions for turning the reported text into something you can check.

What might be relevant

The APG paper lists examples that auditors may consider. In our own words, they include changes in regulation, the vulnerability of delivery to storms, floods, fires or drought, supply chain concerns, and customer requirements or parent company policies on climate change. These are examples from a guidance paper, not a checklist, and your own situation may look quite different.

The paper also says that if an organization makes climate-related claims about its products or services, it must be able to show it can meet them. If you make any, check your evidence.

If it is relevant

If you decide climate change is relevant, the APG paper says it is addressed in the QMS in the same way as any other issue. It says this may involve determining risks and opportunities, planning changes to the system, changes in scope, or addressing the related requirements in other parts of the system. In 2026 that connects to two clauses that have also been reported as changed:

• Risks and opportunities are now handled separately. See risks and opportunities in ISO 9001:2026.

• Planning of changes (clause 6.3) has been strengthened. See planning of changes in ISO 9001:2026.

If you also run an environmental system

The APG paper notes that a climate issue can be relevant to different management system disciplines, such as environmental, health and safety or energy, and that if an organization has an integrated system, the same issue may be analyzed from different perspectives. If you work to ISO 14001, note that Global ACI says ISO 14001:2026 has "stronger alignment with key environmental priorities, including climate change, biodiversity and resource efficiency" (Global ACI). The two standards ask different questions, so check each one separately.

Check where you stand

Our free Gap Analysis Checklist for ISO 9001:2026 has 111 plain-English questions covering clauses 4 to 10, with 25 new or changed 2026 requirements flagged, in Excel and Word. The download page has a short sign-up form; occasional emails about Clearline Systems kits are a separate, optional tick box.

The checklist paraphrases requirements in our own words. It is not ISO text, you will still need your own copy of the standard, and using it does not promise a pass or certification. Only a certification body can certify your organization.

For the full list of reported changes, see ISO 9001:2026: what changed and what to update.

Clearline Systems is an independent publisher of documentation templates. Clearline Systems is not affiliated with or endorsed by ISO (the International Organization for Standardization), IAF, ANSI, Global ACI, any national standards body, accreditation body or certification body. We don't reproduce ISO text; you'll need your own copy of the standard.

Sources

1. ANSI, "First Full Revision of ISO 9001 in a Decade Now Available from ANSI," September 16, 2026: https://www.prnewswire.com/news-releases/first-full-revision-of-iso-9001-in-a-decade-now-available-from-ansi-302880800.html

2. ISO 9001 Auditing Practices Group, Guidance on Auditing Climate Change issues in ISO 9001, Edition 1, March 19, 2024 (the paper says it is not endorsed by ISO, ISO/TC 176 or IAF): https://committee.iso.org/files/live/sites/tc176/files/PDF%20APG%20New%20Disclaimer%2012-2023/APG%20Auditing%20Climate%20Change%20issues%20FINAL%203-19-2024%20Rev%201.pdf

3. Global ACI, news page on ISO 14001:2026 transition requirements, September 14, 2026: https://global-aci.org/en/news/global-aci-publishes-transition-requirements-for-iso-140012026/

All sources checked October 1, 2026.