Insights · 4 min read
The climate change amendments: what was actually added
In February 2024 ISO published amendments to a large number of management system standards, including all six within our accredited scope. The change…
Published by CAS — Conformity Assessment Services · 4 September 2026
In February 2024 ISO published amendments to a large number of management system standards, including all six within our accredited scope. The change was small enough to read in under a minute and has produced more confusion than almost anything else in the last two years.
Here is what was added, what it requires, and — the part that matters most — what it does not.
The text
Two changes, in two clauses.
Clause 4.1 gained one sentence: the organization shall determine whether climate change is a relevant issue.
Clause 4.2 gained a note: relevant interested parties can have requirements related to climate change.
That is the whole amendment. One requirement and one note, in the context clauses.
Both landed in ISO 9001, ISO 14001, ISO 45001, ISO 22000, ISO 50001 and ISO 22301 — and in many other standards built on the same harmonized structure.
What "determine whether" means
The verb is the requirement, and it is worth reading slowly.
The clause does not say climate change is a relevant issue. It says the organization shall determine whether it is. That is a question the organization must answer, and both answers are available.
A determination of "no, and here is our reasoning" conforms. A determination of "yes, for these reasons, and here is what follows" conforms. What does not conform is never having asked.
This is the single most common misreading in both directions. Organizations either assume the amendment obliges them to build a climate programme, or assume it obliges them to write "not applicable" and move on. Neither is what the sentence says.
What it does not require
A carbon footprint or greenhouse gas inventory. Nothing in the amendment asks for measurement. That is a different standard entirely.
A climate policy. Not mentioned.
A separate procedure or a documented output. Clause 4.1 required no documented information before the amendment and requires none after it. The determination has to have happened and be evidenceable — which is not the same as being written in a document called "climate change determination".
A new management system. The amendment sits inside the existing context clause. It is a question added to a question you were already required to answer.
Action. If the determination is that climate change is not relevant to your purpose, strategic direction, and ability to achieve intended results, nothing follows from it. The clause asks for the determination, not for a particular outcome.
What it does require
That the question was asked, by people in a position to answer it, and that the answer has reasoning behind it.
That interested-party requirements were considered in the same light. A customer with climate-related purchasing criteria, a regulator with reporting obligations, a lender with disclosure conditions — clause 4.2 asks which of your relevant interested parties have requirements, and the note now names this as a category that can appear there.
That it feeds forward if it is relevant. If climate change is determined to be a relevant issue, clause 6.1 determines risks and opportunities considering the issues in 4.1. A determination that stops at itself has not done the work the structure expects.
Why an amendment and not a transition
This is where the confusion has real consequences.
An amendment modifies the text of a standard and takes effect on publication. There is no transition period, no grace window, and no separate certificate. Certificates already issued remain valid; the amended requirement simply applies from the moment it exists.
A revision replaces the standard with a new edition, and revisions come with transition arrangements — a defined period, a date after which certificates to the old edition cease to be valid, and a route for certified organizations to move.
The 2024 climate change change was an amendment. Many organizations treated it as a revision, waited for a transition deadline that was never coming, and are now addressing it later than they needed to.
What this means in an audit
Audit teams have been examining this since the amendment took effect. The question is straightforward and the evidence is usually already somewhere in the organization.
An auditor is looking for whether the determination happened, whether the reasoning is plausible for this organization in its situation, and whether — if the answer was yes — anything downstream reflects it.
A one-line "not applicable" appended to a context register with no reasoning is the finding that keeps appearing. Not because the answer is wrong, but because a determination without reasoning is an assertion, and the clause asked for a determination.
If your last management review predates the amendment
That is the practical starting point. Clause 9.3 lists changes in external and internal issues among the required inputs to management review, and this is a change in what the clause requires you to consider.
The question is not what your climate position is. It is whether anybody has been asked to form one.