If you’re transitioning from ISO 14001:2004 to ISO 14001:2015, a gap-analysis is one of the smartest places to start. It gives you a clear picture of what’s already aligned with the new requirements and what still needs attention. Without it, teams often underestimate the work involved or focus energy in the wrong areas.
In my experience, organizations that complete a structured gap-analysis usually transition smoother, close findings faster, and avoid late surprises during certification or surveillance audits. Think of this template as your transition roadmap. Once it’s completed, you’ll know exactly where you stand and what steps are needed next.
Instructions — How to Use This Gap-Analysis Template
Using this template isn’t complicated, and you don’t need to overthink it. The goal is clarity—not perfection.
Here’s a simple way to work through each requirement:
Read the clause and requirement.
Compare it to what your EMS currently includes.
Score the level of compliance.
Record what evidence exists and what’s missing.
Assign actions and responsibilities.
A simple scoring scale keeps things objective:
Score
Meaning
0
Not implemented
1
Partially implemented
2
Fully implemented
A quick tip: be honest. Inflating the score doesn’t help anyone—especially during audit time.
Once the assessment is complete, you’ll have a clear view of your real compliance level and a list of priority actions.
Gap-Analysis Table by ISO 14001:2015 Clause Structure
This section follows the ISO 14001:2015 Annex SL structure. Each requirement includes space to score compliance, note evidence, identify gaps, and assign corrective actions.
Clause 4 — Context of the Organization
This is new compared to the 2004 version and often where teams hesitate. The goal is to define the environment your business operates in—internal, external, and stakeholder expectations.
Checklist includes:
Have internal and external issues been identified?
Have interested parties and their expectations been defined?
Has the EMS scope been reviewed and documented?
A quick example: if regulatory pressure, customer expectations, or environmental risks have changed, they should be reflected here.
Clause 5 — Leadership
ISO 14001:2015 puts leadership front and center. The environmental manager can’t carry responsibility alone anymore.
Assess whether:
Leadership roles and responsibilities are clearly defined
The environmental policy aligns with 2015 requirements
Commitment is demonstrated—not just documented
If leadership isn’t visibly engaged, this will show up during the audit.
Clause 6 — Planning
This is where most gaps appear during transition, especially around lifecycle thinking and risk-based planning.
Evaluate whether the organization has:
Updated environmental aspects and impacts considering lifecycle perspective
Identified risks and opportunities—not just traditional hazards
Updated compliance obligations
Documented and measurable objectives with clear plans to achieve them
If your EMS still looks like the 2004 model, this is likely an area that needs careful attention.
Clause 7 — Support
This section ensures the organization has the resources, competence, communication strategy, and documented information systems needed to support the EMS.
Key areas to review:
Are resources adequate?
Is competence verifiable—not assumed?
Do communication processes cover internal and external needs?
Is documented information aligned with the new terminology and format?
If training records exist but competence isn’t demonstrated, that’s a red flag.
Clause 8 — Operation
Operational controls should reflect your risk-based approach, environmental aspects, and compliance obligations.
Checklist includes:
Are operational controls updated to reflect lifecycle impacts?
Is emergency preparedness aligned with the new approach and tested regularly?
Even small adjustments here can reduce waste, emissions, or regulatory risk.
Clause 9 — Performance Evaluation
This requirement strengthens monitoring and review expectations. It’s not just about collecting data—it’s about understanding and improving performance.
Evaluate whether:
KPIs are meaningful and aligned with objectives
Compliance evaluation is scheduled and documented
Internal audits follow Annex SL structure
Management review reflects ISO 14001:2015 inputs and outputs
If reports exist but no decisions are made from them, improvement may be needed.
Clause 10 — Improvement
This is where continual improvement becomes measurable—not conceptual.
Assess whether:
Nonconformities are recorded with root-cause corrections
Corrective actions prevent recurrence—not just solve symptoms
Improvement is demonstrated and tracked
Organizations doing this well don’t just respond to problems—they anticipate them.
Summary Dashboard — Your One-Page Snapshot
The goal of this page is simple: see your transition status at a glance.
A pie chart or color-coded summary works well:
Green = fully implemented
Yellow = partially implemented
Red = not implemented
You’ll instantly see where to focus your effort.
Priority Action Plan
Once the gaps are clear, list the needed actions, assign responsibility, and set deadlines. This section turns the assessment into a real transition plan—not just a checklist.
A useful addition is a priority rating (High / Medium / Low) based on risk, audit deadlines, and resource availability.
Evidence Binder Checklist
This makes audit preparation much easier. It’s simply a list of the documents and records needed to demonstrate transition compliance—environmental policy, lifecycle assessment summary, risks register, stakeholder analysis, training evidence, and so on.
Keeping this binder up to date saves hours before an audit.
Sign-Off & Readiness Confirmation
Once the template is complete, someone senior—usually the EMS lead or executive sponsor—approves it.
This confirms the transition plan is aligned with strategy and ready for implementation.
Optional Digital Enhancements
If you’re using Excel, Google Sheets, or QMS software, this template can include:
Drop-down scoring fields
Automatic compliance percentage calculations
Evidence document hyperlinks
Change-tracking history
Small digital improvements can save a lot of time later.
Melissa Lavaro is a seasoned ISO consultant and an enthusiastic advocate for quality management standards. With a rich experience in conducting audits and providing consultancy services, Melissa specializes in helping organizations implement and adapt to ISO standards. Her passion for quality management is evident in her hands-on approach and deep understanding of the regulatory frameworks. Melissa’s expertise and energetic commitment make her a sought-after consultant, dedicated to elevating organizational compliance and performance through practical, insightful guidance.
