Clause 5.1StrengthenedHigh impact typical effort 2-4 hours
Top management accountability — personal and non-delegable
What changed in the 2026 revision
The 2026 revision strengthens top management accountability, making it personal and non-delegable. Top management must now support leadership in ALL relevant roles, not just management roles.
What auditors will look for
Ensure top management demonstrates personal, active leadership — not just sign-off. Management review minutes should show decisions based on environmental performance data. The 2026 revision expects leadership support extended to non-management roles, promoting a culture of environmental responsibility and employee engagement.
How to close the gap
- 1Document how top management demonstrates personal accountability for EMS
- 2Show evidence of active decision-making based on environmental data
- 3Demonstrate support for environmental leadership in non-management roles
- 4Embed environmental responsibility into organisational culture
Does your documentation meet this requirement?
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More changes in Clause 5
5.2 — Environmental policy — broader commitments an…5.1 — Supporting leadership in non-management roles5.1 — Environmental champions and employee engageme…5.3 — Roles, responsibilities and authorities — ass…
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