Clause 5 of ISO 9001:2026 asks more of top management than the 2015 edition did, in three specific places. The list of ways top management demonstrates leadership and commitment grows from ten items to twelve (5.1.1 a) to l)), adding the promotion of quality culture and ethical behaviour and of opportunity-based thinking. The quality policy gains a fifth requirement, that it takes the organisation’s context into account and supports its strategic direction (5.2.1 e)), and must now be implemented as well as understood and applied (5.2.2 d)). And the responsibilities top management must assign grow from five to six, with reporting on opportunities for improvement becoming an assignment in its own right (5.3 e)). None of this needs a new document. All of it needs leaders who can answer for it in an interview.
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5.1.1: the twelve commitments, and what moved
| 2026 item | What top management must do | Compared with ISO 9001:2015 |
|---|---|---|
| a) | Ensure the quality policy and objectives are established and compatible with the strategic direction | Same as 2015 b) |
| b) | Ensure the QMS requirements are integrated into the organisation’s business processes | Same as 2015 c) |
| c) | Ensure the resources the QMS needs are available | Same as 2015 e) |
| d) | Communicate the importance of effective quality management and of conforming to the QMS requirements | Same as 2015 f) |
| e) | Ensure the QMS achieves its intended results | Same as 2015 g) |
| f) | Direct and support persons to contribute to the effectiveness of the QMS | 2015 h) said “engaging, directing and supporting” |
| g) | Promote continual improvement | 2015 i) said “promoting improvement” |
| h) | Support other relevant roles to demonstrate their leadership in their areas | Same as 2015 j) (“other relevant management roles”) |
| i) | Promote quality culture and ethical behaviour | New |
| j) | Promote the use of the process approach | Split from 2015 d) |
| k) | Promote risk-based thinking and opportunity-based thinking | 2015 d) said risk-based thinking only |
| l) | Take accountability for the effectiveness of the QMS | Same as 2015 a), now listed last |
Two NOTEs sit under the list. NOTE 1 (as in 2015) says “business” is to be read broadly as the activities core to the organisation’s existence. NOTE 2 is new: an organisation’s quality culture and ethical behaviour are reflected in its shared values, attitudes, practices and actions. That sentence is the standard’s only description of what the new item i) means, and it is deliberately behavioural rather than documentary.
Annex A.5.1 explains the intent: visible support, involvement and commitment from top management demonstrate the organisation’s priority for quality; top management plays a key role in promoting quality culture and awareness of the QMS; ethical behaviour supports confidence in the organisation’s ability to meet interested parties’ needs and can affect all aspects of quality. ISO 10010 is cited for guidance on quality culture.
What “promote quality culture and ethical behaviour” looks like in evidence
Because there is no documented-information requirement attached to 5.1.1 i), the evidence is behavioural and the audit method is the interview. The pattern that satisfies auditors has four parts. A statement of what the organisation values in how work is done and how people deal with customers, suppliers and each other, in whatever form fits the organisation (a values statement, a code of conduct, a page in the induction pack). Leaders who refer to it and act on it, which an auditor tests by asking staff for an example. A route for raising a quality or ethical concern that does not run only through the person’s own manager, and evidence it has been used without penalty. And consistency between the statement and what the organisation actually rewards, which is where most cultures fail: a bonus scheme that pays for volume with no quality condition contradicts everything on the wall. Under 7.3 e), people doing work under the organisation’s control must also be aware of the organisational quality culture and ethical behaviour, so induction and briefing content is the natural place to make the statement visible.
5.1.2: customer focus, unchanged
The three customer-focus commitments are the same as in 2015: customer and applicable statutory and regulatory requirements are determined, understood and consistently met; the risks and opportunities that can affect conformity and customer satisfaction are determined and addressed; and the focus on enhancing customer satisfaction is maintained. Item b) now points to the split treatment of risks and opportunities in 6.1.2 and 6.1.3.
5.2: the quality policy, with one new requirement and one new word
| Requirement | ISO 9001:2015 | ISO 9001:2026 |
|---|---|---|
| Appropriate to the purpose and context of the organisation and supports its strategic direction | 5.2.1 a) | 5.2.1 a) is “appropriate to the purpose of the organization”; the context and strategic-direction elements move to a new e) |
| Framework for setting quality objectives | 5.2.1 b) | 5.2.1 b), unchanged |
| Commitment to satisfy applicable requirements | 5.2.1 c) | 5.2.1 c), unchanged |
| Commitment to continual improvement of the QMS | 5.2.1 d) | 5.2.1 d), unchanged |
| Takes into account the context of the organisation and supports its strategic direction | Part of 5.2.1 a) | 5.2.1 e), a separate requirement |
| Available and maintained as documented information | 5.2.2 a) | 5.2.2 a): available as documented information |
| Communicated, understood and applied | 5.2.2 b) | 5.2.2 b): communicated within the organisation; 5.2.2 d): implemented, understood and applied |
| Available to relevant interested parties, as appropriate | 5.2.2 c) | 5.2.2 c), unchanged |
Readers of the 2015 text will notice that context and strategic direction were already present in 5.2.1 a). What the 2026 edition does is separate them into their own item and change the verb from “appropriate to” to “takes into account” and “supports”, which under Annex A.2 b) means they must be included in the decision rather than merely thought about. The practical test is whether the policy could only have been written by your organisation. A policy that reads identically for a Manila logistics firm and a Cebu furniture maker has not taken the context into account. Annex A.5.2 adds that the policy can reflect the organisation’s quality culture and expectations for ethical behaviour, which is a sensible place to put them.
“Implemented” in 5.2.2 d) is the other change. Communicated and understood can be shown by a briefing record and an interview; implemented requires an example of a decision or a practice that the policy shaped. Auditors will ask leaders for one.
5.3: six assigned responsibilities
Top management must ensure that responsibilities and authorities for relevant roles are assigned and communicated, and must assign responsibility and authority for six things: a) ensuring the QMS conforms to the standard; b) reporting on the performance of the QMS to top management; c) ensuring the processes deliver their intended results; d) ensuring the promotion of customer focus throughout the organisation; e) reporting on opportunities for improvement to top management; f) ensuring the integrity of the QMS is maintained when changes are planned and implemented. In 2015 items b) and e) were a single item. The separation matters in two ways: someone must now be visibly responsible for bringing improvement opportunities to leadership, which connects to 10.1 and to 9.3.2 e), and the old habit of leaving both reporting duties to one quality manager who reports once a year will look thin. There is still no management representative requirement, and the six responsibilities can be spread across several roles (Annex A.5.3).
Annex A.5.3 also adds a sentence that reads as a nod to automation: where technologies are used to support the management of the QMS, confidence in its integrity depends on the availability of reliable information for decisions and clarity about who has the responsibility and authority for those decisions. If a platform generates your performance reports, someone still owns them.
What an auditor will ask top management in 2026
Expect the leadership interview to contain these: how does the policy support where the business is going; give me an example of a decision the policy shaped; what do you do, personally, to promote a culture of doing the job right and behaving ethically; what opportunities did you decide to pursue this year and why; who brings improvement opportunities to you and when did they last do so; what changed in the business this year and how did you keep the system intact through it. Prepared answers are not the point; true ones are, and the interview will be triangulated with what staff say.
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Brief your leadership team on the twelve commitments of 5.1.1
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Frequently asked questions
What is new in clause 5.1.1 of ISO 9001:2026? Two items: i) promoting quality culture and ethical behaviour, and the extension of k) to opportunity-based thinking alongside risk-based thinking. The list now runs a) to l), with accountability moved to the end.
Does ISO 9001:2026 require a code of ethics? No. It requires top management to promote ethical behaviour (5.1.1 i)) and people to be aware of it (7.3 e)). A code of conduct or values statement is the common way to make the expectation visible, but the evidence auditors weigh is behaviour and interviews.
What does 5.2.1 e) add to the quality policy? That the policy takes into account the organisation’s context and supports its strategic direction. In 2015 those ideas sat inside 5.2.1 a) with softer wording. The practical test is whether the policy is specific to your organisation and its direction.
What does “implemented” mean in 5.2.2 d)? That the policy is put into practice, not only communicated and understood. Auditors will ask for an example of a decision or practice the policy shaped.
Is a management representative required in ISO 9001:2026? No. The six responsibilities in 5.3 must be assigned and communicated; they can be spread across several roles.
What changed in 5.3? Reporting on QMS performance (b)) and reporting on opportunities for improvement (e)) are now separate assignments; the list runs a) to f).
Read next
Quality culture and ethical behaviour in ISO 9001:2026; risks and opportunities; the clause-by-clause register; the ISO 9001:2026 playbook; and Sterling Revise™ for a fixed-scope transition.
Sources
ISO 9001:2026, Quality management systems — Requirements, sixth edition (published 16 September 2026): 5.1.1 and NOTES 1 and 2, 5.1.2, 5.2.1, 5.2.2, 5.3, 7.3 e), Annex A.2 b), A.5.1 to A.5.3. ISO 9001:2015, Clause 5, for the comparison. ISO 10010, Quality management — Guidance to understand, evaluate and improve organizational quality culture (Bibliography reference).
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