Clause 9.1StrengthenedHigh impact typical effort 4-8 hours
Explicit evaluation of environmental performance and EMS effectiveness
What changed in the 2026 revision
The 2026 revision makes the evaluation of environmental performance and EMS effectiveness the primary focus of Clause 9. 'The effectiveness of the environmental management system is fundamental to this clause and is now included in the first sentence.' Monitoring alone is not sufficient.
What auditors will look for
Move beyond basic monitoring to active evaluation. The key question is: 'Is the EMS achieving its intended outcomes?' Establish KPIs tied to objectives, evaluate trends, and include effectiveness criteria in management review inputs.
How to close the gap
- 1Define KPIs for each environmental objective
- 2Establish trend analysis and performance evaluation processes
- 3Include EMS effectiveness as a standing agenda item in management review
- 4Document evidence that evaluation leads to improvement actions
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More changes in Clause 9
9.2 — Internal audit — defined objectives and docum…9.3 — Management review restructured into three sub…9.1.2 — Evaluation of compliance — maintained and str…9.3 — Management review inputs and outputs — comple…
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