As organizations prepare for ISO 9001:2026, climate change is sometimes presented as though it were an entirely new subject being introduced by the revised standard. That is not the case. Climate-related considerations were already added to ISO 9001 in 2024, when ISO published ISO 9001:2015/Amd 1:2024 — Climate action changes on 23 February 2024.
The amendment added explicit climate-related considerations to two familiar parts of the standard: the context of the organization and the needs and expectations of interested parties. The right way to understand ISO 9001:2026 is therefore not that ISO is suddenly “adding climate change”, but that the 2026 edition is carrying forward an approach that has already been part of ISO 9001 since 2024.
This distinction matters because it helps organizations avoid overreacting. The amendment does not automatically require a new environmental management programme, a climate procedure or a carbon accounting system. Its purpose is to ensure that organizations do not dismiss climate change without first considering whether it is relevant to the performance of their QMS.
What happened in 2024?
The 2024 amendment made two important points explicit. First, when reviewing the context of the organization, the organization needs to determine whether climate change is a relevant issue. Second, relevant interested parties may have requirements related to climate change.
The wording is brief, but the practical implication is significant. Organizations should no longer assume that climate change is outside the scope of ISO 9001 simply because they are not environmental companies.
The starting question is:
Could climate change, or requirements connected with it, affect our ability to achieve the intended results of the QMS?
That is very different from assuming in advance that climate change must be treated as a major business risk. ISO and IAF made clear in their 2024 joint communication that the underlying intent of the clauses on organizational context and interested parties had not changed. Organizations were already expected to understand external issues that could affect their management systems; the amendment made climate change an explicit consideration within that existing logic.
What changes with ISO 9001:2026?
At the time of writing, the final ISO 9001:2026 standard has not yet been published, so FDIS wording should not be presented as a requirement already in force. However, the overall direction is clear: climate-related considerations are being incorporated into the revised edition rather than disappearing when ISO 9001:2015 is replaced.
For certified organizations, this means the climate topic should not be treated as something that begins only with the 2026 transition. The sequence is more accurately understood as follows:
climate-related considerations were formally added to ISO 9001:2015 in 2024;
organizations have already been expected to consider whether climate change is relevant to their QMS;
the new edition carries that principle into the next version of ISO 9001.
There is therefore no reason for an ISO 9001:2015-certified organization to wait for the 2026 transition before reviewing the issue.
What does “consider climate change” actually mean?
The wrong starting point is to ask, “What climate programme do we need to create?” A much better question is: Could climate change affect our ability to provide conforming products and services or achieve the intended results of our QMS?
For some organizations, the answer may clearly be yes. For others, the effect may be limited. In some cases, a reasonable analysis may conclude that climate change is not currently a significant issue for the QMS.
All of these outcomes are possible. What matters is that the organization has actually considered the subject and reached a conclusion that makes sense in the context of its activities.
ISO 9001 Auditing Practices Group guidance makes clear that the relevance of climate change can vary substantially depending on factors such as:
industry and business model;
products and services;
geographic location;
supply-chain structure;
infrastructure dependencies;
customer requirements;
statutory and regulatory obligations.
This is therefore not a one-size-fits-all requirement.
When climate change can be relevant to a QMS
The easiest way to understand the issue is to look at how climate-related conditions can affect ordinary quality management.
Raw materials and availability
A manufacturer may depend on agricultural, chemical or natural raw materials whose availability or characteristics are affected by weather patterns, water availability or extreme temperatures. Potential consequences could include reduced availability, greater price volatility, changes in material characteristics or increased variation between suppliers.
For ISO 9001, the relevant question is not whether the organization should adopt a position on climate policy. It is whether changes in the availability or characteristics of raw materials could affect product conformity or the organization’s ability to meet customer requirements.
If the answer is yes, the issue is relevant to the QMS.
Logistics and distribution
Extreme weather can disrupt roads, ports, rail networks, air freight and local distribution. An organization that relies on a single transport route or logistics provider may therefore face increased risk of late delivery or interrupted supply.
If delivery performance is part of customer requirements or process objectives, this becomes a quality-management issue. Appropriate responses might include:
alternative transport routes;
secondary logistics providers;
adjusted inventory levels;
alternative sourcing arrangements.
These are ordinary business continuity and QMS decisions. They are not environmental programmes.
Temperature-sensitive products
Some products depend on controlled temperature conditions throughout production, storage or transport. Examples may include pharmaceuticals, food products, chemicals, laboratory materials and certain types of electronics.
If periods of extreme heat become more frequent or severe, the organization may need to consider questions such as:
Is existing refrigeration or cooling capacity sufficient?
Can logistics providers maintain the required temperature range?
Are monitoring arrangements adequate?
Could product stability, shelf life or performance be affected?
This is clearly a quality issue because it concerns the ability to maintain specified product characteristics.
Energy supply and infrastructure
Manufacturing sites, laboratories, data centres and cold-storage facilities can depend heavily on reliable electricity. If weather-related conditions increase the likelihood of outages or create additional cooling demands, the organization may need to review backup power, infrastructure resilience or contingency arrangements.
The reason for doing so is not that ISO 9001 has become an environmental standard. The reason is that infrastructure failure could affect the intended results of the QMS.
Water availability
Water can be critical to food production, pharmaceutical manufacturing, chemical processing, sanitation and many industrial processes. Changes in water availability or quality may affect capacity, process stability or final product characteristics.
Where this can influence product conformity or the organization’s ability to operate consistently, climate-related context becomes relevant to the QMS.
Supplier stability
An organization does not need to experience climate-related disruption directly for the issue to matter. Important suppliers may face water shortages, transport disruption, raw material scarcity, energy limitations or production interruptions.
This means the organization may need to consider the resilience of its supply chain, not only the conditions at its own sites. The QMS question is whether suppliers can continue to support the organization’s quality, delivery and customer requirements.
Customer requirements
Climate-related issues can also enter the QMS through customers rather than through physical events. A customer may require specific packaging characteristics, recycled or lower-impact materials, evidence supporting environmental claims, particular sourcing conditions or information about product-related carbon characteristics.
From an ISO 9001 perspective, the question is straightforward: if such a requirement is relevant and accepted, can the organization identify it, control it and fulfil it?
That is normal requirements management.
Statutory and regulatory requirements
Legislation may affect product materials, packaging, labelling, energy-related characteristics, reporting obligations or claims made about products and services.
ISO 9001 does not create these laws. However, where statutory or regulatory requirements are applicable to an organization’s products or services, the QMS needs to address them through the normal mechanisms for identifying and meeting applicable requirements.
Changes to product characteristics
Organizations may also redesign products in response to market or customer expectations, for example by changing materials, reducing energy consumption, altering packaging or extending product life.
Such changes may affect testing, validation, acceptance criteria, design controls and supplier requirements. In that situation, climate-related considerations become part of ordinary product and quality management rather than a separate environmental activity.
Data centres and IT infrastructure
The connection may appear less obvious for software and service organizations, but IT services still depend on physical infrastructure. Data centres rely on electricity, cooling, telecommunications, physical access and backup systems.
Periods of extreme heat or instability in energy supply can affect service availability. If uptime, continuity or availability is part of customer requirements, the issue can therefore be relevant to the QMS.
Climate relevance should not be dismissed automatically simply because the organization provides digital rather than physical products.
When the impact may be limited
Not every organization needs an extensive climate-related analysis.
Consider a small consulting business where services are delivered primarily online, operations are geographically distributed, there are no climate-sensitive products, customers do not impose climate-related requirements and the business has limited dependence on critical physical infrastructure.
After reviewing its context and relevant interested parties, the organization may reasonably conclude that climate change does not currently have a significant effect on the intended results of its QMS.
That can be a valid conclusion. The important distinction is between:
“We considered the issue and concluded that its current relevance to our QMS is low.”
and:
“Climate change does not apply to us because we are not an environmental company.”
The first statement reflects analysis. The second may simply reflect an assumption.
What ISO 9001 does not automatically require companies to do
One of the biggest risks around the 2024 amendment is unnecessary bureaucracy. Several requirements are frequently assumed even though ISO 9001 does not automatically impose them.
Calculate a carbon footprint
ISO 9001:2015/Amd 1:2024 does not create a universal requirement for every ISO 9001-certified organization to calculate greenhouse gas emissions or a carbon footprint.
A carbon calculation may be required because of legislation, customer contracts, corporate policy, sector-specific requirements or voluntary commitments. But it is not automatically required simply because an organization operates an ISO 9001 QMS.
Set environmental or carbon-reduction objectives
The climate amendment does not require every organization to establish emissions-reduction targets or environmental objectives.
If a climate-related issue is relevant to the QMS, the organization should determine appropriate actions. Depending on the issue, those actions might concern supply-chain resilience, temperature control, infrastructure, logistics or supplier capability rather than emissions reduction.
Become certified to ISO 14001
ISO 9001 and ISO 14001 serve different purposes. ISO 9001 focuses on quality management and the consistent provision of conforming products and services. ISO 14001 focuses on environmental management, environmental aspects, compliance obligations and environmental performance.
Organizations may integrate both systems, but ISO 9001 does not automatically require ISO 14001 certification.
Create a separate Climate Change Procedure
There is no general requirement to create a dedicated climate procedure. Where climate-related issues are relevant, they can often be managed through existing QMS processes such as:
context review;
risk and opportunity management;
supplier management;
infrastructure planning;
design and development;
operational planning;
management review.
A new document should be created only if it genuinely helps the organization manage the issue.
Add a mandatory “climate risk” to the risk register
The first step is to determine relevance. If climate change creates a meaningful risk to a process or to the intended results of the QMS, it can then be addressed through the organization’s normal risk-based approach.
Adding a generic line called “climate change risk” solely because an auditor might expect to see the words adds little value.
The more useful logic is:
Relevance first → action second
rather than:
Document first → justification later
ISO 9001 and ISO 14001: the difference in perspective
The same underlying issue can appear in both standards for different reasons.
Take water scarcity. Under ISO 9001, the organization might ask whether reduced water availability could affect production capacity, process stability or product conformity. Under ISO 14001, the question is more likely to concern how the organization’s water use affects the environment and how related environmental aspects and obligations are managed.
The physical issue is the same, but the management-system perspective is different.
This is why climate-related considerations in ISO 9001 should not be interpreted as converting a QMS into an environmental management system. For organizations with an integrated management system, the same underlying issue may often be managed once while satisfying the relevant purposes of both standards.
Do you need new documents?
Usually, the best starting point is not to create more documentation.
Many organizations can address the climate amendment by reviewing and, where necessary, updating existing activities such as:
context analysis;
interested-party review;
supplier assessment;
risk and opportunity review;
infrastructure planning;
management review.
If climate change is relevant, the consequences can then flow naturally into the parts of the QMS where they actually matter.
For example, the context review may identify increasing extreme heat as a possible logistics issue. Operational controls may then be reviewed for temperature-sensitive products, logistics providers may be reassessed, and temperature excursions may be monitored as part of normal performance data.
That is far more useful than creating a stand-alone “Climate File” that has little connection with day-to-day operations.
What might an auditor ask?
An auditor is likely to focus first on whether the organization has genuinely considered climate change as part of its context and whether its conclusion is reasonable.
Relevant questions may include:
How did you determine whether climate change is relevant to your QMS?
Could climate-related disruption affect suppliers or logistics?
Are any products or processes sensitive to temperature, water or energy availability?
Do customers impose climate-related product or sourcing requirements?
Are there applicable statutory or regulatory requirements affecting products or services?
Does the organization make environmental or climate-related product claims?
If a climate-related issue was found to be significant, what action was taken?
How is the effectiveness of that action reviewed?
If the organization concludes that climate change is not currently significant, the auditor may reasonably explore how that conclusion was reached.
The purpose is not to assess the organization’s environmental philosophy or political position. The purpose is to determine whether the organization understands its context and can continue to achieve the intended results of its QMS.
Climate change checklist for ISO 9001:2026 preparation
Use the following questions as a practical review:
Has the organization explicitly considered climate change as part of its QMS context?
Is there a reasonable conclusion on whether the issue is relevant?
Could climate-related conditions affect raw materials, suppliers or logistics?
Are any processes dependent on temperature, water, electricity or other infrastructure that could be disrupted?
Do customers or other relevant interested parties have climate-related requirements?
Are there applicable statutory or regulatory requirements affecting products or services?
Does the organization make environmental or climate-related claims that need to be supported by evidence?
If climate change is relevant, has the issue been integrated into the appropriate existing QMS processes?
Are actions reviewed to determine whether they are effective?
Key takeaway
Climate change is not a subject that first appears in ISO 9001 with the 2026 edition. It formally entered the current edition through ISO 9001:2015/Amd 1:2024, published on 23 February 2024.
The practical requirement is also narrower than many organizations assume. The organization needs to determine whether climate change is a relevant issue for its QMS and whether relevant interested parties have climate-related requirements that need to be addressed.
If the answer is yes, the issue should be integrated into the parts of the QMS where it affects products, services, processes, suppliers, infrastructure or customer requirements. If the answer is no, and that conclusion is based on a reasonable analysis, ISO 9001 does not automatically require carbon-footprint calculations, environmental targets, ISO 14001 certification or a dedicated climate procedure.
The purpose is not to turn every QMS into an environmental management system. It is to make sure that a potentially significant external issue is not ignored simply because it sits outside traditional quality terminology.
This article is part of Audit Advisor’s dedicated resource covering the revised standard and the transition to ISO 9001:2026.