Management system guidance
4.0 Context of the Organization
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4.2 Understanding the needs and expectations of interested parties
Clause 4.2 asks your organization to work out who has a genuine stake in its environmental management system and what they need or expect from it. Specifically, you must identify the interested parties (stakeholders) relevant to the EMS, establish their relevant needs and expectations, and then decide which of those needs and expectations become compliance obligations that the EMS will address.
Interested party requirements are not automatically requirements of your organization. Some are mandatory because they have been written into laws, regulations, permits or licenses. Others, such as a customer’s request for carbon reporting or a commitment to a voluntary industry scheme, only become compliance obligations once your organization decides to adopt them.
What changed in ISO 14001:2026
Item c) now makes clear that you must not only identify which needs and expectations become compliance obligations, but also confirm that they will be dealt with through the EMS. Two new notes have been added. The first explains that relevant parties may have needs related to environmental conditions, giving pollution levels, natural resource availability, climate change, biodiversity and ecosystem health as examples. This replaces the narrower climate change note added by Amendment 1:2024. The second confirms that requirements other than legal requirements become compliance obligations at the point your organization decides to comply with them. The term ‘stakeholder’ is also now formally accepted as an alternative to ‘interested party’.
Identifying relevant interested parties
Allow time to build a picture of your internal and external stakeholders. A useful test of relevance is to ask: ‘could this party, or what it needs, affect our ability to achieve the intended outcomes of the EMS, or is it affected by our environmental performance?’ If the answer is yes, capture its needs and expectations and consider them when planning the EMS.
Brainstorming in a cross-functional workshop works well, because different functions deal with different stakeholders: procurement with suppliers, sales with customers, facilities with neighbors and the regulator. This can be run alongside the context review described in 4.1. Typical interested parties include:
- Environmental regulators, local authorities and permitting bodies;
- Neighbors, local communities and community groups;
- Customers and end users seeking lower-impact products and services;
- External providers, contractors and waste carriers;
- Employees and their representatives;
- Owners, shareholders, investors, insurers and lenders;
- Non-governmental organizations and environmental campaign groups;
- Trade associations and certification or industry schemes you belong to.
Where a party believes it is affected by your environmental decisions or activities, you only need to consider the needs and expectations it has actually made known to you, for example through a complaint, a consultation response or a planning objection.
Examples of needs and expectations
| Interested party | Possible needs and expectations | How to capture them |
| Regulators | Permit and license conditions, emission limits, waste duty of care, statutory reporting | Permits, legal register, inspection reports, correspondence |
| Neighbors and communities | Low noise, dust and odor, protection of local watercourses and habitats | Complaints log, community meetings, liaison groups |
| Customers | Greenhouse gas and resource-use data, recyclable packaging, supplier environmental questionnaires | Contracts, tenders, account reviews |
| Investors and lenders | Disclosure of climate and nature-related risks, sustainability reporting | Board papers, annual report, investor questionnaires |
| Employees | Visible environmental commitment, opportunities to contribute ideas | Staff meetings, suggestion schemes, surveys |
| External providers | Clear environmental requirements, fair terms, long-term relationships | Supplier reviews, purchase specifications |
Climate change is a major concern for many stakeholders, but it is not the only one. Annex A reminds organizations to look also at pollution, depletion of natural resources, loss of biodiversity and declining ecosystem health when considering what interested parties expect.
Deciding which needs become compliance obligations
Once needs and expectations have been identified, decide which of them your organization has to comply with (legal requirements) and which it chooses to adopt (other requirements). Identify legal requirements first. Record the adopted requirements as compliance obligations so that they flow into the more detailed analysis in 6.1.3 and are reflected in the EMS. Needs that you decide not to adopt should still be kept under review, as stakeholder expectations can change.
There are several ways to capture this information, for example:
- A simple interested parties register or spreadsheet under version control;
- An input to the compliance obligations (legal and other requirements) register;
- An input to the environmental aspects register (6.1.2) and the risks and opportunities register (6.1.4);
- Agenda items and minutes of management review meetings.
Links to other clauses
- 4.3 – compliance obligations must be considered when setting the scope;
- 4.4 – knowledge gained in 4.2 must be considered when establishing and maintaining the EMS;
- 5.2 – the policy includes a commitment to meet compliance obligations;
- 6.1.4 – risks and opportunities are determined taking interested party needs into account;
- 7.4.3 – communication with relevant external parties;
- 9.3 – changes in the needs and expectations of interested parties are a management review input.
There is no requirement to keep documented information for 4.2 itself, but registers, meeting minutes, complaint records, contracts and stakeholder correspondence will help demonstrate that the process is working.
You should seek and record evidence that your organization has identified its relevant interested parties and their needs and expectations, has decided which of these become compliance obligations to be addressed through the EMS, and reviews this information when stakeholder requirements change or when changes to the EMS are planned.
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