Management system guidance
10.0 Improvement
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10.1 Continual improvement
Clause 10.1 requires your organization to keep improving the suitability, adequacy and effectiveness of its environmental management system (EMS) so that environmental performance gets better. It does this by identifying opportunities for improvement, drawing on the performance evaluation activities in Clause 9 and on nonconformity and corrective action in clause 10.2, and then putting in place the actions needed to achieve the intended outcomes of the EMS.
What changed in ISO 14001:2026: in ISO 14001:2015, Clause 10 had three sub-clauses: 10.1 General, 10.2 Nonconformity and corrective action, and 10.3 Continual improvement. The 2026 edition merges the old 10.1 General and 10.3 Continual improvement into a single clause 10.1 Continual improvement, so clause 10.3 no longer exists. The combined requirement now explicitly links improvement to the sources in Clause 9 and 10.2 and to the intended outcomes of the EMS. Nothing of substance has been removed, but procedures, manuals and audit checklists that refer to 10.3 should be renumbered.
Where do improvement opportunities come from?
Annex A says the organization should consider the results of the following when deciding what to improve:
- analysis and evaluation of environmental performance (clause 9.1.1);
- evaluation of compliance (clause 9.1.2);
- internal and external audits (clause 9.2);
- management review (clause 9.3);
- nonconformities and corrective actions (clause 10.2).
Other useful sources include your risks and opportunities (clause 6.1.4), significant environmental aspects (clause 6.1.2), suggestions from workers, feedback and complaints from neighbors, customers and regulators, and new technology. Improvement can come from any EMS process, and also from breakthrough change, innovation or reorganization.
How much improvement is required?
The standard does not set a rate. Your organization decides the rate, extent and timescale of improvement actions. Environmental performance can be enhanced by applying the EMS as a whole or by improving one or more of its elements. What auditors expect to see is a working mechanism that identifies opportunities, decides which to pursue, implements them and checks the results, together with evidence that environmental performance is moving in the right direction over time.
Practical approach
The Plan-Do-Check-Act cycle is a simple way to manage improvement:
- Plan: identify the opportunity (for example reducing energy use per unit of output, cutting waste to landfill or replacing a hazardous substance), set an objective where appropriate (clause 6.2.1) and plan the actions, resources and responsibilities (clause 6.2.2).
- Do: implement the change, on a small scale first if the outcome is uncertain. Where the change affects the EMS, manage it as a planned change (clause 6.3).
- Check: monitor and measure the result against the baseline and confirm there are no unintended environmental impacts elsewhere.
- Act: if the change works, standardize it by updating procedures, operational controls and training; if not, learn from it and try another option.
Keep an improvement register or action log that records each opportunity, its source, owner, target date, status and the benefit achieved. This provides a single view for management review and makes it easy to demonstrate continual improvement to an auditor. Involve the people, departments and external providers affected by the changes, and update documented information when the way of working changes.
Typical evidence of improvement
- trend data showing reductions in resource use, emissions, discharges or waste;
- environmental objectives achieved and new, more demanding ones set;
- fewer or less serious environmental incidents and nonconformities;
- improved results from evaluation of compliance and audits;
- changes to EMS processes, controls or documentation that made them simpler or more effective.
You should seek and record evidence that your organization identifies opportunities for improvement from performance evaluation, audits, management review and corrective action; that it decides which opportunities to act on and implements the necessary actions in a controlled way; that the effect of those actions on environmental performance and the EMS is checked; and that the EMS as a whole is becoming more suitable, adequate and effective over time.
More information on PDCA
Planning
Context
Planning
Support
Doing
Support
Operations
Checking
Monitoring, measurement, analysis and evaluation
Acting
Improvement
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