ISO 14001:2026 and Climate Change: How to Handle Clauses 4.1 and 4.2
Yes, ISO 14001:2026 requires you to address climate change in clauses 4.1 and 4.2. No, it does not require you to launch a carbon program, set a net-zero target, or measure your greenhouse gas emissions. Those two statements sound contradictory, and the gap between them is exactly where I see organizations either panic or get a nonconformity at audit. Let me be direct about what the standard actually asks: clauses 4.1 and 4.2 require a determination. You must consider climate change (alongside four other named environmental conditions) and decide whether it is relevant to your environmental management system. That is the requirement. In practice you record that determination, because your context feeds the scope (4.3) and the risk-and-opportunity work (6.1.4) that the standard does require you to keep as documented information.
A documented “not relevant, and here is why” is a perfectly acceptable answer for some organizations. A vague “we’ll deal with climate later” is not. In my consulting work, the cleanest way to close this out is to write the determination once, in plain language, and file it with your context analysis. This article gives you copy-paste-ready wording for both outcomes, the relevant case and the justified not-relevant case, and shows how a “yes” flows into the rest of your system. For the full clause picture beyond context, see our ISO 14001:2026 requirements explained guide.
The 2024 Amendment and the 2026 Edition Are Not the Same Change
There are two distinct events here, and people keep blurring them. The first was the climate amendment, ISO 14001:2015/Amd 1:2024, which added text in two places: a requirement in 4.1 to consider climate change as an issue, and a note in 4.2 that interested parties can have climate-related expectations. That amendment applied to the 2015 edition and was already in force before the new edition arrived.
ISO 14001:2026, the fourth edition, was published on 15 April 2026. It cancels and replaces the 2015 edition and incorporates the 2024 amendment into the body of the standard. It also goes further than the amendment did. Where the amendment named only climate change, the 2026 edition expands 4.1 to a named set of environmental conditions: pollution levels, availability of natural resources, climate change, biodiversity, and ecosystem health. So if you handled the 2024 amendment by adding one line about climate to your context analysis, you have a gap. The 2026 edition asks you to consider five conditions, not one.
| Aspect | ISO 14001:2015/Amd 1:2024 (the climate amendment) | ISO 14001:2026 (4th edition) |
|---|---|---|
| Applies to | The 2015 edition (amended in 2024) | The new edition, published 15 April 2026 |
| What 4.1 names | Climate change as an issue to consider | Pollution levels, availability of natural resources, climate change, biodiversity, ecosystem health |
| What 4.2 says | Note: interested parties can have climate-related needs and expectations | Note: those needs and expectations are linked to the same environmental conditions |
| Practical action if you already did the amendment | Climate covered | Add the other four conditions and document your judgment on each |
Clause 4.1 vs Clause 4.2: What Each One Actually Asks
These two clauses get treated as one task. They are not. They ask different questions and produce different outputs, and an auditor will check them separately.
Clause 4.1: your issues, looked at both ways
Clause 4.1 says the organization shall determine external and internal issues relevant to its purpose and that affect its ability to achieve the intended outcomes of its environmental management system. The 2026 edition then adds the line that matters for this article: those issues shall include environmental conditions being affected by the organization or capable of affecting the organization, such as pollution levels, availability of natural resources, climate change, biodiversity or ecosystem health.
Read that twice, because the phrasing is deliberate. It is a two-way test. You consider how your activities affect each condition (your operations releasing pollutants, drawing down water, clearing habitat), and you consider how each condition could affect you (a drought restricting your process water, a heatwave disrupting operations, a flood-prone site). Annex A reinforces that these conditions are interconnected and that climate interacts with many of the others, which is why the standard lists five rather than treating climate in isolation. The word “such as” tells you the list is examples to consider, not a fixed checklist you must answer “yes” to.
Clause 4.2: what your interested parties expect
Clause 4.2 asks you to determine the interested parties relevant to the environmental management system, their relevant needs and expectations, and which of those become your compliance obligations. A 2026 note attaches climate directly: relevant interested parties can have needs and expectations related to environmental conditions, such as pollution levels, availability of natural resources, climate change, biodiversity or ecosystem health. Annex A makes the same point and adds a useful caution, that while climate change is a focal point for many interested parties, it is not the only relevant issue.
The practical hinge in 4.2 is the second note: an expectation becomes a compliance obligation only when it is legally binding or when you decide to comply with it. A customer asking for your carbon footprint is an expectation. The moment you sign a contract promising to report it, or a regulation requires it, it becomes an obligation you must manage. That distinction is where 4.2 connects to the rest of the system, and it is the line most internal audits probe. If you are mapping how 4.1 and 4.2 sit against every other clause, our ISO 14001:2026 transition guide lays out the full clause-by-clause plan and deadlines.
How to Make the Determination (and How to Document a No)
Here is where I’d push back on the common reading. The requirement is to consider climate change and the other four conditions, not to conclude that all five are significant for you. Consideration plus a reasoned judgment is what conformity looks like. For a small professional-services firm in a leased office, “climate change is not a significant issue for our operations, for these reasons” is a defensible determination, provided you wrote down the reasons. For a food manufacturer drawing large volumes of water, or a logistics operator exposed to extreme weather, a “not relevant” answer would not survive five minutes of audit scrutiny.
So the determination is a short, honest reasoning exercise. For each of the five conditions, ask two questions from 4.1: do our activities affect this condition, and could this condition affect us? Then for 4.2, ask whether any relevant interested party has a need or expectation tied to it, and whether that has become, or could become, a compliance obligation. Write the answer either way. The one thing the standard’s guidance rules out is using your scope or your judgment to dodge something material. Annex A is explicit that scoping should not be used to exclude activities with significant aspects or to evade compliance obligations. A documented “no” is fine. A convenient “no” that ignores an obvious exposure is a finding waiting to happen.
The two blocks below are the wording I hand to clients as a starting point. Lift them, change the specifics to match your operations, and file them with your context analysis. They are templates, not answers, so do not paste them unedited.
Worked Example 1: Climate Change Determined as Relevant
Use this pattern when your operations clearly interact with climate, or an interested party has tied an expectation to it. The example below is written for a mid-size manufacturer. Notice that it states the reasoning, names the interested party, and points to where the issue is carried forward.
Context determination (4.1 / 4.2), climate change: RELEVANT.
Under clause 4.1, we have considered climate change as an environmental condition both ways. Our activities affect climate through energy use and process emissions at our two production sites. Climate also affects us: our primary site sits in an area with rising summer peak temperatures that strain cooling and increase the risk of production stoppages, and one warehouse is in a recognized flood-risk zone. Under clause 4.2, our largest customer requires annual reporting of site-level energy use and greenhouse gas emissions as a condition of the supply contract; this expectation is a compliance obligation. We therefore determine climate change to be a relevant issue. It is carried into our risk and opportunity register (6.1.4) and reflected in our environmental objectives (6.2).
If a structured register suits your documentation better than prose, the same determination drops into a table. Auditors accept either format, as long as the reasoning is visible.
| Determination element | Entry (relevant case) |
|---|---|
| Condition (4.1) | Climate change |
| How we affect it | Energy use and process emissions at two production sites |
| How it affects us | Rising peak temperatures strain cooling; one warehouse in a flood-risk zone |
| Interested-party expectation (4.2) | Key customer requires annual energy and emissions reporting; contractual, so a compliance obligation |
| Determination | Relevant |
| Carried into | Risk and opportunity register (6.1.4); environmental objectives (6.2) |
Worked Example 2: Climate Change Justified as Not Relevant
Use this pattern only when you can honestly defend it. The example is written for a small consultancy operating from a single leased office. The key is that it does not just assert “not relevant,” it shows the consideration that led there, which is exactly what an auditor wants to see.
Context determination (4.1 / 4.2), climate change: CONSIDERED, NOT RELEVANT AS A SIGNIFICANT ISSUE.
Under clause 4.1, we have considered climate change as an environmental condition. We operate from a single leased office and provide advisory services with no manufacturing, no process emissions, and no significant on-site energy demand beyond standard office use. Our effect on climate is limited to office electricity and staff travel, both already addressed under our general environmental aspects. Our location is not subject to identified climate-related operational risks such as flooding or heat-driven disruption. Under clause 4.2, no relevant interested party has raised a climate-related need or expectation, and we hold no contractual or legal obligation tied to climate reporting. On this basis we determine climate change not to be a significant issue for our environmental management system at this time. This determination will be reviewed if our activities, location, or interested-party expectations change.
Two details make that “no” hold up. First, it records what was checked rather than skipping the condition, so the auditor sees consideration, not avoidance. Second, it commits to a review trigger, which signals the judgment is current rather than permanent. Drop either detail and the same wording becomes a weak determination.
If Climate Is Relevant, Where Does It Go Next?
A “relevant” determination is not the finish line, it is the on-ramp. Once you decide climate change (or any of the five conditions) is a relevant issue, the standard expects it to travel through the system rather than sit in your context document. Two clauses are the immediate destinations.
Clause 6.1.4, risks and opportunities. When planning the environmental management system, you consider the 4.1 issues, the 4.2 needs and expectations, and your scope, then determine the risks and opportunities that need to be addressed. The standard specifically calls out preventing or reducing the potential for external environmental conditions to affect the organization. So the flood-risk warehouse from the relevant example becomes a documented risk here, and a customer’s emissions-reporting requirement may surface as both a risk (losing the contract) and an opportunity (differentiation). The risks and opportunities determined must be kept as documented information.
Clause 6.2, environmental objectives. Objectives are set taking into account significant aspects, compliance obligations, and the risks and opportunities you just determined. This is where a relevant climate issue can turn into a measurable target, an energy reduction goal, a site resilience action, an emissions data process to satisfy that contract. Note the chain: 4.1 and 4.2 feed 6.1.4, and 6.1.4 feeds 6.2. That is the thread an auditor follows, and a determination that stops at the context document with no onward trace is a common weak point.
If your determination is “not relevant,” there is nowhere onward to go, and that is correct. You keep the documented reasoning, revisit it when circumstances change, and move on. Either way, the official scope of the standard sits at the ISO 14001 page on iso.org if you want to confirm the framing against the source.
Frequently Asked Questions
The Bottom Line on 4.1 and 4.2
After enough transition projects, I have come to see clauses 4.1 and 4.2 as a test of honesty rather than effort. The standard is not asking you to become a climate scientist. It is asking you to look at five environmental conditions, say plainly how they relate to your organization in both directions, and write it down. Organizations that overthink it build elaborate climate programs they do not need. Organizations that underthink it write one breezy line and get a finding. The right answer sits in the middle: a short, reasoned determination, filed with your context analysis, with a clear trace forward if the answer is “relevant.”
If you would rather start from a structured set of context and planning templates than from a blank page, our ISO 14001:2026 Documentation Kit includes editable context-analysis, interested-party, and risk-and-opportunity registers that carry your 4.1 and 4.2 determinations straight through to 6.1.4 and 6.2.
