Management system guidance
6.1 Actions to Address Risks and Opportunities
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6.1.1 General
Clause 6.1 of ISO 14001:2026, “Actions to address risks and opportunities”, is where the environmental management system (EMS) is planned. Clause 6.1.1 is the umbrella sub-clause: it requires the organization to establish, implement and maintain the process or processes it needs to meet the requirements of 6.1.2 to 6.1.5. Those processes must be available as documented information to the extent needed to have confidence that they are carried out as planned.
The overall intent is to make sure the EMS delivers its intended outcomes, that undesired effects are prevented or reduced, and that continual improvement is achieved. Planning follows a risk-based approach: you work out what matters environmentally, what you are obliged to do, and what could help or hinder the EMS, and then plan action on all three.
What changed in ISO 14001:2026
Clause 6.1 has been restructured. In ISO 14001:2015, 6.1.1 contained the requirement to consider context, interested parties and scope, determine risks and opportunities and identify potential emergency situations. In the 2026 edition, 6.1.1 only requires the planning process(es) themselves. The risks and opportunities content has moved to a new sub-clause, 6.1.4, potential emergency situations are now determined as part of environmental aspects in 6.1.2, and planning action has been renumbered from 6.1.4 to 6.1.5. A new clause, 6.3 Planning of changes, has also been added to clause 6.
How clause 6.1 fits together
- 6.1.1 General – establish the planning process(es) for 6.1.2 to 6.1.5 and document them as needed.
- 6.1.2 Environmental aspects – determine the aspects you can control and influence and their impacts, using a life cycle perspective; take account of normal and abnormal conditions, change and potential emergency situations; decide which aspects are significant using established criteria.
- 6.1.3 Compliance obligations – determine and have access to the legal and other requirements related to your aspects, and work out how they apply to you.
- 6.1.4 Risks and opportunities – considering your context (4.1), interested parties (4.2) and scope (4.3), determine the risks and opportunities linked to your aspects, compliance obligations and other issues, including the potential for external environmental conditions such as climate change to affect the organization.
- 6.1.5 Planning action – plan actions to address significant aspects, compliance obligations and risks and opportunities, decide how to build them into EMS or other business processes, and how to evaluate their effectiveness.
The outputs of 6.1 feed directly into 6.2 Environmental objectives, operational control (8.1), emergency preparedness (8.2) and monitoring (9.1).
One process or several?
ISO 14001 does not prescribe a method, a number of steps or a particular number of processes. A small organization might use a single procedure and one combined register that records aspects, impacts, significance, linked legal requirements, risks, opportunities and planned actions. A larger or more complex organization might run separate processes for aspects evaluation, legal compliance and enterprise risk, provided they are linked. Whichever approach you choose, make sure that:
- Inputs from context, interested parties and scope (4.1, 4.2, 4.3) are actually used;
- Responsibilities, methods, criteria and review frequency are defined;
- Outputs flow through to planned actions in 6.1.5 rather than stopping at a register;
- The process is repeated when things change – new sites, processes, products, legislation or environmental conditions;
- Results are reviewed by top management (see 9.3).
How much documentation?
The 2026 edition asks for the planning process(es) to be available as documented information only to the extent necessary to have confidence they are carried out as planned. For many organizations a short procedure or flowchart, supported by the registers required in 6.1.2 to 6.1.4, is enough. If several people at different sites carry out aspects or risk evaluations, more detailed guidance and criteria will be needed to obtain consistent results. Our environmental management system templates include a planning procedure and registers that can be adapted to your organization.
You should seek and record evidence that the organization has established, implemented and maintains a process (or processes) covering environmental aspects, compliance obligations, risks and opportunities and planning action; that the process is documented to the extent needed to give confidence it is carried out as planned; that it is applied consistently; and that its outputs are kept up to date and used to plan actions, objectives and operational controls.
More information on PDCA
Planning
Context
Planning
Support
Doing
Support
Operations
Checking
Monitoring, measurement, analysis and evaluation
Acting
Improvement
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