ISO 9001:2026 contains exactly two sentences about climate change, and both came from Amendment 1:2024 to the 2015 edition. In 4.1 the organisation shall determine whether climate change is a relevant issue. In 4.2 a NOTE says that relevant interested parties can have requirements related to climate change. That is the whole requirement. It does not ask for emissions data, a carbon footprint, a net-zero target or an environmental management system; those belong to ISO 14001, ISO 14064 and the organisation’s own commitments. It asks for a decision, made deliberately, and revisited when circumstances change. What is new in 2026 is only that the sentences are now part of the base text, so an organisation that was certified before 2024 and never applied the amendment now meets the requirement for the first time.
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What the requirement is
Clause 4.1 requires the organisation to determine the external and internal issues relevant to its purpose and strategic direction that affect its ability to achieve the intended results of its QMS, and, as one specific instance, to determine whether climate change is such an issue. The NOTEs to 4.1 already listed environmental conditions among the external issues; the amendment made climate change a named question that cannot be skipped. Clause 4.2’s NOTE points at the other route by which climate reaches the QMS: customers, investors, lenders, regulators and supply-chain partners may expect something from you on climate, and if they do, that expectation is an interested-party requirement to be considered under 4.2 b) and, under the new 4.2 c), a requirement you decide whether to address through the QMS.
Annex A.4.2 explains the intent in a sentence: expectations relating to climate change can influence interested-party requirements in areas such as regulatory compliance, customer requirements and organisational commitments, and where those expectations are relevant they form part of the context for planning and operating the QMS.
What it is not
The requirement does not oblige you to conclude that climate change is relevant. “Not relevant, and here is why” is an acceptable determination for many organisations, provided it was actually considered. It does not require carbon accounting, a sustainability report, an ESG rating or a climate policy. It does not require documented information: 4.1 asks you to determine and to monitor and review, not to record. And it does not turn the QMS into an environmental management system; the standard’s introduction says explicitly that it does not include requirements specific to environmental management.
How a Philippine organisation decides
The honest way to answer the question is to ask what climate-related conditions could stop the QMS delivering conforming products and services and satisfied customers. For most Philippine organisations, four questions settle it.
Physical exposure: are your sites, your suppliers’ sites or your delivery routes exposed to typhoons, flooding, storm surge, extreme heat or drought in a way that interrupts production, damages stock, cuts power or blocks logistics? A Cebu food manufacturer whose cold chain depends on grid power during typhoon season has a QMS-relevant climate issue; a two-person consultancy working remotely may not.
Working conditions: does heat affect the environment for the operation of processes (7.1.4) or the people who run them, on a factory floor, in a warehouse, on a construction site?
Interested-party expectations: do customers, especially export customers and multinational clients, ask for climate-related data, supplier codes of conduct with environmental clauses, or continuity assurances? Do lenders or regulators? If so, the expectation enters through 4.2, whether or not you consider the physical risk material.
Legal and market direction: are there regulations, tender conditions or industry schemes that bring climate requirements into your products or services (energy efficiency, packaging, disclosure)?
If any answer is yes, climate change is a relevant issue and it flows into 6.1 as a risk (6.1.2, whose NOTE 1 now names disruption explicitly) and sometimes as an opportunity (6.1.3, for example a product that customers want because of its climate performance). If every answer is no, record that conclusion with the reasons.
How to show you decided
Although 4.1 has no documented-information requirement, the determination is impossible to demonstrate without a record, and since 2024 auditors have expected one. The minimum that works: a dated entry in the context analysis (4.1) stating the determination and the reasons; where relevant, an entry in the interested-party table (4.2) for any party with a climate-related expectation and whether the QMS addresses it (4.2 c)); where relevant, the corresponding risk or opportunity in the register (6.1.2, 6.1.3) with its action; and the topic on the management review agenda under changes in external issues (9.3.2 b)) and interested-party expectations (9.3.2 c)), so that the determination is revisited rather than filed. Two paragraphs are enough. A separate climate policy is not required and, for an organisation that concluded “not relevant”, would be contradictory.
What an auditor will ask
Did you consider whether climate change is relevant, and where is that recorded? What was your reasoning? Did any customer, regulator or lender ask you for anything climate-related, and how did you treat that expectation? Where climate is relevant, where is the risk or opportunity and what did you do about it? When did you last revisit the decision? A reasoned “not relevant” with a date will pass. Silence will not, and neither will a generic sustainability statement pasted from a template that does not mention the organisation’s own sites, products or customers.
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Frequently asked questions
Is climate change a new requirement in ISO 9001:2026? No. It was added to ISO 9001:2015 by Amendment 1:2024. The 2026 edition carries the same two sentences into the base text of 4.1 and 4.2. It is new only for organisations that never applied the amendment.
Does ISO 9001:2026 require carbon accounting or emissions reporting? No. It requires the organisation to determine whether climate change is a relevant issue for its QMS and to consider interested-party requirements related to climate change. Emissions accounting belongs to ISO 14064 and voluntary or regulatory reporting, not to ISO 9001.
Can we decide that climate change is not relevant? Yes, if that is the considered conclusion for your organisation. Record the determination and the reasons, and revisit it when your context or your interested parties’ expectations change.
Do we need a documented climate-change assessment? The standard does not require documented information for 4.1. Because the determination must be demonstrable, a dated entry in the context analysis with reasons is the practical minimum, and it is what auditors expect.
Where does a climate-related risk go? Into the risk register under 6.1.2, which now requires risks to be determined, analysed and evaluated, and whose NOTE 1 names disruption to the provision of products and services. A climate-related opportunity goes under 6.1.3.
Does this make ISO 9001 an environmental standard? No. The introduction states that ISO 9001 does not include requirements specific to environmental management. Environmental performance is the province of ISO 14001, which was itself revised in April 2026.
Read next
Risks and opportunities in ISO 9001:2026; the clause-by-clause register; the documented information list; the ISO 9001:2026 playbook; and ISO 14001 certification in the Philippines for organisations that want environmental performance managed as well as quality.
Sources
ISO 9001:2026, Quality management systems — Requirements, sixth edition (published 16 September 2026): 0.4, 4.1 and NOTES, 4.2 and NOTE, 6.1.2 NOTE 1, 7.1.4, 9.3.2 b) c), Annex A.4.1 and A.4.2. ISO 9001:2015/Amd 1:2024 for the origin of the climate-change text.
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