Has Your ISO Standard been amended? How To Implement the Climate Change Amendment in AS9100, ISO 9001, ISO 14001 & ISO 45001. | Jay Wiessner
Updated: Sep 18
Climate change considerations are now part of the management-system requirements that certified organizations need to address. The 2024 climate action amendments added climate-related language to Clauses 4.1 and 4.2 of many ISO management system standards, including ISO 9001 and ISO 45001. IAQG also formally recognized the ISO 9001 climate amendment for the 9100-series certification scheme. ISO 14001 has since moved to ISO 14001:2026, which incorporates climate change more directly into the current environmental management framework.
The key point is straightforward: organizations must determine whether climate change is relevant to the intended results of their management system, and they must consider whether relevant interested parties have climate-related requirements. If climate change is relevant, the organization should address it through the parts of the management system that are affected.
What Is the Current Status in 2026?
The original 2024 amendments are still important, but the status now differs by standard:
ISO 9001: ISO 9001:2015/Amd 1:2024 remains the published climate amendment while ISO 9001:2026 is under publication and scheduled for release in September 2026. ISO 9001 consulting services can help organizations evaluate how the current requirement is addressed and prepare for the upcoming edition.
AS9100 / 9100:2016: The 9100-series remains based on ISO 9001 requirements. IAQG Resolution 170 formally recognized the ISO/IAF climate amendment and confirmed that certified aerospace organizations must acknowledge the requirement and address it in their QMS. AS9100 consulting services can help aerospace organizations review how the requirement fits their existing system.
ISO 14001: ISO 14001:2026 was published in April 2026 and replaced ISO 14001:2015 and its 2024 amendment. The current edition gives stronger attention to environmental context, including climate change, biodiversity, pollution, and resource availability. ISO 14001 consulting services can support organizations transitioning to the current edition.
ISO 45001: ISO 45001:2018/Amd 1:2024 remains the published climate amendment while the next edition of ISO 45001 is still under development. ISO 45001 consulting services can help organizations evaluate the requirement within an occupational health and safety management system.
What Did the Climate Change Amendment Actually Change?
The 2024 amendments did not create an entirely new management-system program. ISO and the accreditation community described the change as a clarification of the existing requirement to understand internal and external issues and interested-party requirements.
The amendments added two important expectations:
Under Clause 4.1, the organization must determine whether climate change is a relevant issue for the management system.
Under Clause 4.2, organizations are reminded that relevant interested parties can have requirements related to climate change.
This does not mean every organization must create a climate program, carbon-reduction target, or separate climate procedure. It means the organization needs a reasonable method for considering climate change and determining whether it can affect the management system's intended results.
How to Implement the Climate Change Requirement
The simplest approach is to integrate the requirement into the management-system processes you already use instead of creating unnecessary standalone paperwork.
1. Determine Whether Climate Change Is Relevant
Consider whether climate change could affect the organization's ability to achieve the intended results of the management system. The answer may be different for a quality, environmental, aerospace, or occupational health and safety system.
Supply-chain disruption or material availability.
Extreme weather, heat, flooding, fire, storms, or other conditions that could affect operations.
Customer or contractual climate-related requirements.
New or changing statutory and regulatory requirements.
Facility, infrastructure, workforce, or business-continuity risks.
Environmental conditions and resource availability where relevant to ISO 14001.
If climate change is not relevant, the organization should still be able to explain how that determination was made.
2. Review Interested-Party Requirements
Review relevant customers, regulators, owners, employees, suppliers, certification requirements, and other interested parties to determine whether any climate-related expectations or obligations apply to the management system.
For example, a customer may introduce supplier climate requirements, a regulator may impose new environmental or worker-safety obligations, or changing weather conditions may create operational risks that need to be considered.
3. Record the Determination in a Practical Way
The standards do not require one universal climate-change form or a specific risk register. Organizations can document the determination using the existing tools that make sense for their system.
Context-of-the-organization analysis.
Interested-parties matrix.
Risk and opportunity review.
Management review records.
Business continuity or operational risk assessment.
Environmental aspects or compliance-obligation processes, where applicable.
The objective is to create enough evidence to show that climate change was actually considered, not to create paperwork solely for the auditor.
4. If Climate Change Is Relevant, Address the Impact
When climate change is determined to be relevant, the organization should connect that issue to the parts of the management system that need action. Depending on the standard and the organization, this could affect risks and opportunities, objectives, operational controls, emergency planning, suppliers, training, resources, or monitoring.
The response should be proportionate to the real issue. A company facing significant wildfire, heat, flooding, regulatory, supply-chain, or customer-related climate risk may need more action than an organization with limited exposure.
5. Revisit the Determination When Conditions Change
Climate relevance is not necessarily a one-time decision. Customer requirements, regulations, facilities, supply chains, weather exposure, and business operations can change. Review the determination when relevant changes occur and as part of the organization's normal management-system review processes.
What Will Auditors Expect to See?
Certification bodies are expected to confirm that organizations have considered climate change as part of Clauses 4.1 and 4.2. If an organization determines that climate change is relevant, the auditor may look for evidence that the issue has been addressed through the appropriate management-system processes.
There is no requirement for a special climate-change audit or a separate certification audit solely because of the 2024 amendment. For aerospace organizations, IAQG has also stated that the climate-amendment activity should not increase audit duration or require a special audit.
Evidence that climate change was considered.
A reasonable explanation of why it was determined relevant or not relevant.
Evidence that applicable customer, statutory, regulatory, or other interested-party requirements were considered.
Actions within the management system when a relevant climate-related issue was identified.
Ongoing review when circumstances or requirements change.
How the Requirement Can Differ by Standard
ISO 9001 and AS9100
For quality and aerospace quality management systems, the question is not whether an organization has an environmental program. The question is whether climate change can affect the organization's ability to consistently meet customer, product, service, statutory, regulatory, or management-system requirements.
ISO 14001:2026
Climate change is especially relevant within an environmental management system. ISO 14001:2026 now places climate change within a broader environmental context that also includes issues such as biodiversity, pollution, ecosystems, and resource availability. Organizations transitioning from ISO 14001:2015 should evaluate the complete 2026 revision rather than treating the 2024 amendment as a standalone change.
ISO 45001
For occupational health and safety, climate-related issues may be relevant when they affect worker health, workplace conditions, emergency preparedness, operational risks, or legal obligations. Examples could include extreme heat, severe weather, wildfire smoke, flooding, or other changing conditions where they create meaningful OH&S risks.
Frequently Asked Questions
Do we need to update our ISO 9001 or AS9100 system for the climate change requirement?
You need to make sure your management system shows that climate change has been considered under organizational context and relevant interested-party requirements. If climate change is relevant, the issue should be addressed through the appropriate QMS processes. If it is not relevant, the organization should still be able to explain how that conclusion was reached. A separate climate-change procedure is not automatically required.
What will an ISO or AS9100 auditor expect us to show about climate change?
An auditor will generally expect evidence that the organization considered climate change, determined whether it is relevant to the management system, considered applicable interested-party requirements, and addressed relevant issues through the appropriate management-system processes. The evidence can be integrated into existing context, risk, management review, environmental, safety, or other system records.
What if climate change is not relevant to our organization?
The requirement does not say that climate change must be relevant to every organization. The organization should make a reasonable determination based on its operations, location, customers, regulations, supply chain, and management-system objectives. If the conclusion is that climate change is not relevant, the organization should be able to explain the basis for that conclusion.
Do we need a new ISO or AS9100 certificate because of the climate change amendment?
The 2024 climate amendments did not require a special recertification program or a new certificate solely because of the amendment. Organizations should continue to follow their normal certification cycle and any transition requirements that apply when a full new edition of their standard is published.
Conclusion
The climate change requirement is still relevant, but organizations do not need to overcomplicate it. The practical goal is to determine whether climate change matters to the management system, consider relevant interested-party requirements, document the determination in a sensible way, and take appropriate action when a real issue exists.
If your organization needs help evaluating how climate change requirements fit into an existing quality management system, My ISO Consultants provides ISO 9001 consulting services to help organizations review current requirements, identify gaps, and make practical updates without adding unnecessary complexity.
Author: Jay Wiessner
