Climate Change Considerations in ISO Management Systems
Climate Change in Brief
- ISO Amendment 1:2024 added climate change to context for all ISO standards
- Both physical risks and transition risks for the organisation
- Interested party expectations on climate change
Climate Change in ISO Management Systems
In February 2024, ISO issued a set of amendments (Amendment 1 to the Harmonised Structure) that added explicit climate change wording to Clauses 4.1 and 4.2 of more than thirty management system standards at once. The affected standards include ISO 9001, ISO 14001, ISO 45001, ISO 27001, ISO 22301 and others. The change took effect immediately for the standards involved, which means organisations holding any of these certifications need to show they have considered climate change as part of their context and interested parties analysis.
The amendment is not a new substantive requirement in the sense of introducing fresh controls. It is a clarification. Climate change was already implicitly within scope of any context analysis that was honest about the strategic environment the organisation operates in. What the amendment does is close off the argument that climate change is someone else's problem - it must be considered, even if the conclusion is that it is not material to the specific management system being certified.
What the Amendment Says
Two specific clauses have been updated. Clause 4.1 - Understanding the organisation and its context - now adds that the organisation shall determine whether climate change is a relevant issue. Clause 4.2 - Understanding the needs and expectations of interested parties - adds a note that relevant interested parties can have requirements related to climate change.
The wording is deliberately brief. It does not prescribe how the organisation should analyse climate change, what it should do in response, or what evidence to present. The intent is that the issue is raised to the table during context and interested party analysis, and the management system reflects the conclusions.
How the Amendment Applies in Practice
For most organisations, applying the amendment comes down to a short documented review that answers three questions:
Is climate change a relevant issue for our context? For a construction firm, climate change affects project planning (heat stress, extreme weather disruption), material choices (low-carbon concrete, embodied carbon reporting), and client expectations (carbon reduction plans in tenders). For a software business, it affects energy use of data centres, travel footprint, and increasingly procurement expectations. The answer is almost always yes in some form.
Do any interested parties have climate-related requirements of us? Customers increasingly ask for carbon data, sustainability commitments, or evidence of emissions reduction. UK public procurement above £5 million requires a Carbon Reduction Plan under PPN 06/21. Investors, insurers and supply chain partners increasingly ask similar questions. If so, those requirements are compliance obligations or interested party needs that the management system should reflect.
Does this change anything in how we run the management system? Usually in modest, targeted ways: an aspect added to the register, an objective reflecting a carbon target, a compliance obligation on SECR or PPN 06/21 for those caught by them, an item on management review inputs. Rarely does it rewrite the system.
F-IMS38 (or an equivalent climate change review record) is usually the right place to document the analysis. A single page can cover what climate change means for this organisation, what the interested parties expect, and any changes the management system needs to reflect.
Certification Audit Expectations
Certification bodies have been asking about the amendment since early 2024. Auditors are generally looking for:
Evidence that the organisation has considered climate change, not just mentioned it in passing.
Linkage from the consideration into the management system - an aspect, an objective, a risk, a compliance obligation, something tangible that shows the thinking has landed.
Evidence that interested party analysis has picked up climate-related requirements if any apply.
Management review minutes or inputs that show climate has been a topic.
Most organisations that already had a coherent context analysis have been able to add the climate-change review with modest effort. Those that had treated Clauses 4.1 and 4.2 as a box-ticking exercise have had more to do.
The climate change amendment is widely misunderstood. It is not a requirement to set net zero targets, produce a detailed carbon inventory, or rewrite the EMS around climate risk. It is a requirement to think about whether climate change is a relevant issue for your organisation and to document the conclusion. For most businesses, that is a one-page review and a couple of entries added to existing registers, not a major project.
Where organisations do have genuine climate exposure - carbon reduction obligations, supply chain demands, weather-related operational risk - the management system is the natural place to coordinate the response. The amendment essentially makes that coordination official.
When I audit against the 2024 amendment I look for two things. First, a short documented review showing climate change has been considered in the organisation's context, with a reasoned conclusion. Second, evidence that anything identified as relevant has fed into the wider management system - aspects, objectives, risks, compliance obligations, management review inputs.
A one-line entry dismissing climate change as not relevant is unlikely to stand up unless the rationale is obvious and recorded. A brief but honest analysis is what an auditor is looking for.
Practical Compliance Guidance
IMS1 Section 4 covers the organisation's context and interested parties, including the consideration of climate change as required by the 2024 ISO amendment.
The following alphaZ documents support addressing the climate change amendment across the management system.
| alphaZ document | How to use it |
|---|---|
| ISO 9001/14001/45001 IMS Toolkit | The integrated toolkit covering the three most commonly held standards, updated for the 2024 climate change amendment. |
| F-IMS38 Climate Change Review | The template for recording the organisation's consideration of climate change under Clauses 4.1 and 4.2. A short documented review meeting the amendment requirement. |
| ISO 14001 Toolkit | The full environmental toolkit. Climate change commonly surfaces as an aspect and a compliance obligation within the EMS. |
| P-2 Environmental Policy | The environmental policy - often updated to reflect climate change commitments alongside the standing pollution prevention and compliance commitments. |
| P-110 Net Zero Policy | Where the organisation has adopted a net zero target, this policy sets out the framework. Sits alongside P-2 rather than replacing it. |
| F-ENV4 Environmental Aspects Register | Carbon emissions and climate-related aspects belong on the register where they are material to the organisation. |
| ER9 Legal Register | Links climate-related legislation - the Climate Change Act, SECR, PPN 06/21 for public procurement - to the management system. |
Note - all the above files can be downloaded with an alphaZ subscription.
Frequently Asked Questions
UK Legislation
The following UK legislation interacts with climate-related considerations under ISO management systems. Organisations outside the UK should identify the equivalent legislation applicable in their jurisdiction.
- Climate Change Act 2008
- Environment Act 2021
- Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018
