ISO 9001:2026 Climate Change Amendment Explained: Clause 4.1, Risks, and Practical QMS Actions
Are you prepared for the biggest shift in quality management in a decade?
If you work in Quality Assurance or Quality Management, you already know that ISO standards are not static documents. They evolve to reflect the realities of business, risk, and society. However, few changes have generated as much discussion, uncertainty, and debate as the recent climate change amendment to ISO 9001.
While much of the industry is focused on the upcoming ISO 9001:2026 revision—currently at the Draft International Standard (DIS) stage—a critical change has already taken effect. In February 2024, ISO published Amendment 1: Climate Action Changes, immediately embedding climate considerations into the existing ISO 9001 framework.
This amendment acts as a formal bridge to ISO 9001:2026 and makes one thing unmistakably clear: climate change is now a mandatory consideration for every certified Quality Management System (QMS).
For many Quality Managers, this raises an immediate and uncomfortable question:
“We are not an environmental organization, so does this really apply to us?”
The answer is a clear and unambiguous yes. But there is no need to panic.
This change is not about forcing every organization to install solar panels, publish carbon reports, or become carbon neutral. Instead, it is about risk awareness, operational resilience, and business continuity—core principles that have always been at the heart of ISO 9001.
In this comprehensive guide, we will explain exactly what has changed, how ISO 9001:2026 formalizes these requirements, and how organizations can address Clause 4.1 in a practical, audit-ready way—without rebuilding their entire management system.
Understanding Clause 4.1 in ISO 9001:2026
To understand where ISO 9001 is heading, we first need to understand where it started.
Clause 4.1 – “Understanding the organization and its context” has long been the foundation of a modern QMS. It requires organizations to determine the internal and external issues that are relevant to their purpose, strategic direction, and ability to achieve intended results.
Under ISO 9001:2015, organizations had significant discretion in deciding what those issues were. Many progressive organizations already considered environmental or climate-related factors, but it was not explicitly required.
The New Climate Change Requirement
With the 2024 amendment—now fully integrated into the draft text of ISO 9001:2026—a specific requirement has been added to Clause 4.1:
“The organization shall determine whether climate change is a relevant issue.”
At first glance, this may appear to be a minor addition. In reality, it fundamentally changes the compliance landscape.
This single sentence removes ambiguity. Organizations can no longer silently ignore climate change. They must actively evaluate it, document the determination, and be prepared to explain their reasoning during audits.
What “Climate Change” Means in a Quality Context
One of the most common misunderstandings is assuming that ISO 9001 is turning into an environmental standard. It is not.
ISO 9001 remains a Quality Management System standard, not an environmental management standard like ISO 14001.
When assessing climate change under Clause 4.1, you are not measuring carbon footprints unless required by customers. Instead, you are evaluating climate change through the lens of:
- Product and service conformity
- Customer satisfaction
- Process stability
- Supply chain reliability
- Business continuity
In simple terms, the key question becomes:
“Does climate change affect our ability to consistently meet customer and regulatory requirements?”
How the ISO 9001 Climate Amendment Impacts Your QMS
The transition toward ISO 9001:2026 is not just a documentation exercise. It represents a broader shift in how organizations are expected to think about risk.
1. Context of the Organization (Clause 4.1)
This is the primary impact point. Your existing PESTLE (Political, Economic, Social, Technological, Legal, Environmental) or SWOT analysis must now explicitly show that climate change has been considered.
Even if climate change is assessed as “not relevant,” auditors will expect to see evidence of the evaluation and the rationale behind the conclusion.
2. Interested Parties (Clause 4.2)
The amendment also adds a note to Clause 4.2 acknowledging that interested parties—such as customers, regulators, investors, and insurers—may have climate-related requirements.
For example, if a key customer commits to Net Zero by 2030, they may require suppliers to provide climate or emissions data. Once that requirement exists, it becomes a QMS issue, even if your organization is not environmentally focused.
3. Risks and Opportunities (Clause 6.1)
Any climate-related issue identified in Clause 4.1 must flow into Clause 6.1 – Actions to address risks and opportunities.
This includes assessing:
- Supply chain disruptions due to extreme weather
- Infrastructure vulnerability (floods, heat, power outages)
- Operational variability affecting product quality
Practical Examples: Clause 4.1 Climate Change in Action
Below are detailed, audit-relevant examples showing how different industries can assess climate change relevance under ISO 9001:2026.
Example 1: Global Manufacturing Organization
Context: A manufacturer of precision automotive components sources specialized raw materials from a coastal region experiencing increasing hurricane activity.
Climate Change Relevance: Yes
Quality Impact: Supply chain continuity. Supplier shutdowns lead to missed delivery dates and customer dissatisfaction.
QMS Actions:
- Clause 4.1: Document “supply chain disruption due to extreme weather”
- Clause 6.1: Add risk to the risk register
- Mitigation: Qualify alternate suppliers in different regions
Example 2: Construction Company
Context: Residential construction in regions facing extreme summer heat.
Climate Change Relevance: Yes
Quality Impact: Concrete curing defects and worker safety risks.
QMS Actions:
- Clause 4.1: Identify rising temperatures as a relevant issue
- Clause 8: Implement hot-weather concreting procedures
- Project Planning: Adjust timelines for heat-related no-work days
Example 3: SaaS / IT Service Provider
Context: Cloud-hosted infrastructure relying on third-party data centers.
Climate Change Relevance: Potentially Yes
Quality Impact: Service availability due to energy or water shortages.
QMS Actions:
- Assess data center resilience
- Implement multi-region redundancy
- Document downtime risks under Clause 6.1
Example 4: Local Consulting Firm
Context: Office-based or remote consulting services.
Climate Change Relevance: Low or Not Relevant
QMS Actions:
Clause 4.1 documentation states that climate change does not currently affect service delivery. The key is that the assessment is documented.
Implementation Roadmap for ISO 9001:2026 Compliance
Step 1: Management Review
Engage top management to evaluate climate-related strategic risks.
Step 2: Update Context Analysis
Add explicit climate change evaluation to SWOT or PESTLE.
Step 3: Engage Interested Parties
Identify customer and regulatory climate expectations early.
Step 4: Update Risk Register
Ensure alignment between Clause 4.1 and Clause 6.1.
Step 5: Update Operational Controls
Modify procedures where climate risks directly impact quality.
Business Benefits Beyond Certification
It is easy to view this amendment as just “another hoop to jump through.” However, aligning your QMS with the ISO 9001:2026 climate focus offers tangible business benefits.
- Enhanced Resilience
By identifying climate risks early—such as raw material shortages or logistics disruptions—you can build contingency plans. When the disruption hits, your competitors will be scrambling while you continue to ship product. - Competitive Advantage
Large enterprise buyers are aggressively decarbonizing their supply chains. If your QMS is already set up to monitor and manage climate data, you become a “low-friction” vendor. You are easier to do business with than a supplier who creates a compliance headache. - Future-Proofing
Regulations regarding climate disclosure (like the CSRD in Europe or SEC rules in the US) are tightening. Integrating this into your QMS now prepares you for the inevitable regulatory landscape of the late 2020s. - Talent Attraction
The modern workforce values sustainability. Demonstrating that your organization takes climate change seriously—embedding it into the very DNA of your management system—can help attract and retain top talent.
Conclusion: Act Now, Not in 2026
The ISO 9001:2026 climate change focus is not optional, theoretical, or future-facing. The 2024 amendment is already effective, and auditors are already asking questions.
Organizations that act now will find compliance straightforward. Those that delay may face rushed updates, audit findings, and operational surprises.
Review your Clause 4.1 determination this week. Document your reasoning. Strengthen your QMS.
Climate change is now a quality issue—and ISO 9001 has made that unmistakably clear.
FAQ
ISO 9001:2026 requires organizations to determine whether climate change is a relevant issue under Clause 4.1 (Context of the Organization). This requirement was first introduced through Amendment 1: Climate Action (2024) and is already effective for certified organizations.
Yes. Organizations must now evaluate and document whether climate change is relevant to their Quality Management System. While actions depend on relevance, the assessment itself is mandatory.
No. ISO 9001 is a quality standard, not an environmental standard. Organizations are not required to calculate emissions unless customers or regulators demand it. The focus is on quality, continuity, and customer satisfaction.
Climate change is addressed primarily under:
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Clause 4.1 – Context of the Organization
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Clause 4.2 – Interested Parties (customer and regulatory expectations)
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Clause 6.1 – Risks and Opportunities
That is acceptable. However, the organization must document the evaluation and justification. Auditors will verify that the decision was made deliberately and not ignored.
Auditors will look for:
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Documented Clause 4.1 assessment
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Evidence in SWOT or PESTLE analysis
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Alignment with the risk register (Clause 6.1)
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Consideration of customer or regulatory climate requirements
ISO 9001:2026 is expected to be published in 2026, but the climate change requirement is already in force through the 2024 amendment.
No. ISO 14001 focuses on environmental performance. ISO 9001 focuses on how climate-related risks affect quality outcomes.