ISO 9001 Clause 4.1 and Climate Change

ISO passed a resolution adding two short statements about climate change to the harmonised structure that ISO management system standards share — one in Clause 4.1, one in Clause 4.2. The IAF/ISO joint communiqué of 22 February 2024 announced them and said they would be published the following day. You are not required to have a climate policy, a carbon footprint, or a net-zero target. You are required to have determined whether climate change is a relevant issue for your management system, and to be able to show an auditor that you did. For most UK small businesses that is a documented decision, not a project. This guide sets out the exact wording, what a UK auditor is looking for, and what counts as enough.

The exact wording that was added

The IAF/ISO joint communiqué of 22 February 2024 is the primary source, and it quotes both additions in full.

To Clause 4.1 (Understanding the organization and its context), after the existing requirement to determine external and internal issues:

"Added: The organization shall determine whether climate change is a relevant issue."

To Clause 4.2 (Understanding the needs and expectations of interested parties):

"Added: NOTE: Relevant interested parties can have requirements related to climate change."

Two sentences. That is the entire change. The communiqué explains that the additions "will be incorporated into the new text of the Harmonized Structure (Appendix 2 of the Annex SL in the ISO/IEC Directives Part 1 Consolidated ISO Supplement)" — the common clause framework that ISO management system standards are built on, which is why the same two statements appear across a range of standards rather than in one of them.

Note the difference in force between the two. Clause 4.1's addition is a shall — a requirement. Clause 4.2's addition is a NOTE — guidance, which in ISO drafting convention is not auditable as a requirement in its own right. That distinction is worth holding on to when someone tells you that you need to survey your customers about climate change.

What the change does not do

The communiqué is unusually direct on this point:

"The overall intent of the requirements for clauses 4.1 and 4.2 remain unchanged; these clauses already include the need for the organization to consider all internal and external issues that can impact the effectiveness of their management system; these new inclusions are assuring that Climate Change is considered within the management system and that it is an external factor that is important enough for our community to require organizations to consider it now."

And on proportionality:

"It is not the intention of the changes to (for example) turn a health and safety management system audit or a road traffic safety management system audit into one that disproportionality considers Climate Change, though this does not of course understate the importance of Climate Change."

It also notes that "the effect on a Quality Management System could be very different to that on a Health and Safety Management System" — which matters for ISO 9001 specifically. The question a quality management system has to answer is not "what is our environmental impact". It is "can climate change affect our ability to consistently deliver conforming product or service".

There was no transition period and no re-certification. UKAS's technical bulletin on the amendment states that "certification bodies need to include the new text in their auditing of the organisation and its context" and that "CBs will need to continue to audit these clauses to ensure that all internal and external issues, which includes Climate, Change [sic] have been determined by their clients as relevant or not and if so, considered in the development and effectiveness of the management system(s)." In other words: it folded into normal auditing of Clause 4, immediately.

What an auditor actually looks for

UKAS is specific about the failure case. If an organisation cannot demonstrate that it has considered whether climate change is relevant, "a suitable finding should be raised."

Read the requirement carefully and you will see that "not relevant" is a valid answer — as long as it is a determined answer rather than an absent one. What the auditor wants to see is that the question was asked, by someone who understood the business, and that the conclusion was recorded.

The practical test is whether your Clause 4.1 record — your context analysis, issues register, SWOT, or whatever you call it — has climate change in it with a conclusion attached.

What a proportionate ISO 9001 answer looks like

For a quality management system, climate change is a business-continuity and supply-chain question. Here is the shape of a determination that satisfies Clause 4.1 for a typical UK SMB, with the reasoning visible.

Route by which climate change could affect the QMS	Relevant?	Basis
Physical disruption to our site (flooding, heat, storm damage)	Assess against your actual location	Site flood risk, business continuity plan
Disruption to key suppliers or transport	Usually yes for physical goods	Supplier locations, single-source dependencies
Customer requirements — tenders asking about carbon or climate resilience	Increasingly yes in public sector and large-corporate supply chains	Recent tender questionnaires
Regulatory change affecting our product or process	Sector-dependent	Applicable UK regulations
Availability of materials or energy price volatility affecting conformity	Often yes for manufacturers	Purchasing records

Working through five rows like that, recording the conclusion for each, and dating it is a complete Clause 4.1 climate determination for most small businesses. It takes an hour. Two of those rows connect directly to risks you have almost certainly already identified — see the ISO 9001 risk assessment template for how they feed the risk register under Clause 6.1.

Three common mistakes

Treating it as an environmental requirement. ISO 9001 is a quality management standard. A carbon footprint calculation is not evidence of a Clause 4.1 determination, and a Clause 4.1 determination is not a substitute for ISO 14001 if you actually need environmental certification.

Writing "climate change is not relevant to our business" with no reasoning. This is the version that attracts a finding — not because the conclusion is wrong, but because there is nothing behind it. A software business genuinely may conclude that physical climate risk is low; it should still note that customer tender requirements are the route by which it becomes relevant.

Doing it once and never revisiting it. Clause 4.1 requires the issues to be monitored and reviewed. Climate relevance is a standing item, and management review is where it belongs — see the ISO 9001 management review guide for where it fits in the agenda.

Where this sits in the 2026 edition

The climate additions predate the ISO 9001:2026 revision — they were amendments to the 2015 edition, applied from February 2024. The revision is a separate piece of work. If you are planning for the new edition, see the ISO 9001:2026 vs 2015 clause-by-clause comparison and the what changed guide for how the clause structure moves.

The practical implication is that a climate determination you make now carries forward. It is not work you will repeat at transition.

Practical takeaway checklist

1. Find your Clause 4.1 record — context analysis, issues register, or equivalent
2. Add climate change as an explicit row, not a mention
3. Work through the routes: site, suppliers, customers, regulation, materials
4. Record a conclusion per route, with a one-line basis
5. Date it and name who made the determination
6. Note in Clause 4.2 whether any interested party has raised a climate requirement — a tender question counts
7. Feed any "relevant" conclusion into the risk register under Clause 6.1
8. Put climate relevance on the management review agenda as a standing item
9. Do not build a carbon footprint unless a customer or regulation actually requires one

If you are documenting context for the first time, the ISO 9001 gap analysis checklist covers what Clause 4 needs alongside the rest of the standard.

This article is for general informational purposes only and does not constitute legal, regulatory, or professional compliance advice. The quoted wording is taken verbatim from the IAF/ISO joint communiqué of 22 February 2024 and the UKAS technical bulletin linked above; the full text of ISO 9001 itself is a purchased standard and is not reproduced here. ISO 9001 is a voluntary standard, not a legal requirement. Verify how the amendment applies to your scope with your UKAS-accredited certification body.