Management system guidance
5.0 Leadership
ISO Navigator Pro™ is a free tool that provides practical, expert guidance for businesses wishing to interpret and better implement the requirements of ISO 9001:2026, ISO 14001:2026 and ISO 45001:2018.
Our range of ISO templates cover the requirements of ISO 9001:2026, ISO 14001:2026 and ISO 45001:2018, and offer an easy way to implement your next management system.
5.2 Environmental policy
Clause 5.2 requires top management to establish, implement and maintain an environmental policy within the defined scope of the EMS. The policy must suit the organization’s purpose and context, reflecting the nature and scale of what it does and the environmental impacts of its activities, products and services, and it must provide a framework for setting environmental objectives. The policy must be available as documented information, communicated within the organization and available to interested parties. Three specific commitments have to be included in the policy:
- To protect the environment, covering pollution prevention plus any other specific commitment(s) that fit the organization’s context;
- To meet its compliance obligations;
- To continually improve the EMS to enhance environmental performance.
What changed in ISO 14001:2026
The policy requirements are unchanged in substance. The compliance commitment is now worded as a commitment to “meet” compliance obligations (previously “fulfil”), the policy must be “available as documented information” (previously “maintained”), and the note on other specific commitments now lists preservation or conservation of natural resources alongside sustainable resource use, climate change mitigation and adaptation, and protection of biodiversity and ecosystems. Annex A.5.2 adds that commitments should reflect local or regional environmental conditions and can include restoration. An existing policy that says “fulfil compliance obligations” does not need rewriting for the wording alone, but it is a good time to check that it still reflects your context.
Making the policy appropriate to your context
Your organization’s environmental policy must be appropriate to both its purpose and context. This means that once your organization has determined its context, including the environmental conditions now named in 4.1, and the relevant requirements of its interested parties (4.2), top management must review its environmental policy in light of that information. A generic policy copied from another organization rarely passes this test.
Examples of commitments that support protection of the environment, as well as providing a framework for objectives, may include:
- Sustainable resource use;
- Preservation or conservation of natural resources;
- Climate change mitigation and adaptation;
- Protection of biodiversity and ecosystems;
- Addressing other relevant environmental issues such as water quality, air quality or recycling.
Your organization will need to review its environmental policy as necessary to ensure that any changes in its context, interested parties or their requirements are reflected in the policy, and to consider whether your organization’s environmental objectives are affected (see 6.2.1).
Although the environmental policy statement need not include the exact wording of the required commitments, each commitment must be clearly included in the documented policy. The meaning and intent of the standard must be met. The commitment to “comply with legal and other requirements” could continue to be used, as this can be considered equivalent to “meeting compliance obligations.”
Following the compliance commitment through
The commitment to meet compliance obligations is the one many interested parties, especially regulators, care about most, and it is supported by several linked requirements. An auditor will expect to see the commitment carried through into determining compliance obligations (6.1.3), operating in line with them (8.1), periodically evaluating compliance (9.1.2) and correcting any nonconformities (10.2).
Communicating the policy
Objective evidence should include an interview with top management covering points a) to e) of the clause to confirm thorough understanding and leadership at the highest level. If top management is not involved, a nonconformity will likely be raised.
Auditors will wish to determine whether the policy meets the intent of the standard and is understood, by interviewing personnel at all levels. Although interviewees do not need to recite the exact content of the policy, their awareness of the policy and of how their job affects the environmental objectives should be determined (see 7.3 Awareness). This does not require your employees to memorize the policy, but it does mean they should be aware of it, know where it may be found and be able to paraphrase it, or give an interpretation as it applies to them.
If the personnel interviewed do not know what their objectives are and/or do not know which organizational objectives they have a direct effect upon, the auditor would be further directed to evaluate top management’s communication of the policy and objectives.
Inferred awareness through knowledge of procedures is not considered sufficient; otherwise why have the requirement in the first place? A quick and convenient way to promote and communicate the policy might be to create a shortened version of the main policy; try condensing it to five key words or even a couple of short sentences. This can be posted on bulletin boards in each department.
You could even add it to the reverse side of staff security passes or ID badges. If an auditor asks an employee whether they are aware of the policy, they can point to the bulletin board, or to their badge. The employee can then explain to the auditor what the policy means to them and how it influences their work. Remember that the policy must also be available to interested parties – publishing it on your website is the simplest way to achieve this.
You should seek and record evidence that the environmental policy has been established by top management, is appropriate to the organization’s purpose and context, contains the three required commitments, provides a framework for environmental objectives, is available as documented information, has been communicated within the organization and is understood, and is available to interested parties.
More information on PDCA
Planning
Context
Planning
Support
Doing
Support
Operations
Checking
Monitoring, measurement, analysis and evaluation
Acting
Improvement
Want to know more?
- Read our customer's feedback
- Client list - who's using our templates?
- How the templates are formatted and download examples
- Why we use turtle diagrams and process maps
- What's the difference between a process and a procedure?
- About documented information
SSL certification
A certificate guarantees the information your internet browser is receiving now originates from the expected domain - https://www.iso9001help.co.uk. It guarantees that when you make a purchase, sensitive data is encrypted and sent to the right place, and not to a malicious third-party.
Free PDCA guidance
ISO Navigator™ is our FREE online training tool that shows you how to apply the principles of PDCA to your operations. We also offer many helpful templates that get you on the road to documenting your management system, please visit the download page.