Management system guidance
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7.5 Documented information
Clause 7.5 sets out what documented information your environmental management system (EMS) must contain and how it must be created and controlled. “Documented information” covers both what used to be called documents (policies, procedures, work instructions, registers) and records (evidence of what was done). It can be held in any format or medium – paper, electronic files, databases, photographs, video or signage.
7.5.1 General
Your EMS must include the documented information that ISO 14001 specifically requires, plus whatever your organization decides is necessary for the EMS to be effective. The amount will vary between organizations depending on their size and type of activities, processes, products and services, the need to demonstrate that compliance obligations are met, the complexity of processes and how they interact, and the competence of the people doing the work. A small office with competent staff may need very little; a complex permitted manufacturing site will need much more.
Annex A stresses that the focus should be on implementing the EMS and improving environmental performance, not on building a complicated document control system. Documents created for other purposes (for example a quality or safety system, or permit applications) can be used, the EMS documentation can be integrated with other management systems, and there is no requirement for an environmental manual.
7.5.2 Creating and updating documented information
When documented information is created or updated, your organization must make sure it has suitable:
- Identification and description – such as a title, date, author or reference number;
- Format and media – such as language, software version and graphics, on paper or electronically;
- Review and approval – confirming that it is suitable and adequate before use.
7.5.3 Control of documented information
Documented information required by the EMS and by ISO 14001 must be controlled so that it is available and fit for use where and when it is needed, and properly protected, for example against loss of confidentiality, misuse or loss of integrity. As applicable, your organization needs to address:
- Distribution, access, retrieval and use (access may mean permission to view only, or to view and change);
- Storage and preservation, including keeping it legible;
- Control of changes, e.g. version control;
- Retention and disposition.
Documents of external origin that your organization needs for planning and operating the EMS – for example environmental permits and regulatory approvals, equipment manufacturers’ manuals, applicable standards and external environmental databases – must be identified as appropriate and controlled, so that the correct version reaches the people who need it.
What changed in ISO 14001:2026
The requirements of 7.5 are substantively the same as in ISO 14001:2015; 7.5.2 is now titled “Creating and updating documented information”. The main change is terminology used throughout the standard: “maintain documented information” has been replaced by “shall be available as documented information”, and “retain documented information as evidence” by “documented information shall be available as evidence of”. In practice the old document/record distinction still applies – the first kind is kept current, the second is kept unchanged as evidence – but you may wish to update your procedures and document lists to the new wording. Note also that the planning process(es) now cover 6.1.2 to 6.1.5 and that risks and opportunities are now in 6.1.4.
Documented information required by ISO 14001:2026
The table below lists the documented information that ISO 14001:2026 requires to be available, by clause. Use it as a checklist when building or reviewing your document and record register.
| Clause | Topic | Documented information to be available |
| 4.3 | Scope of the EMS | The scope, also available to interested parties |
| 5.2 | Environmental policy | The environmental policy |
| 6.1.1 | Planning process(es) | The process(es) for 6.1.2 to 6.1.5, to the extent needed for confidence that they are carried out as planned |
| 6.1.2 | Environmental aspects | Environmental aspects and associated impacts; the criteria used to determine significance; the significant environmental aspects |
| 6.1.3 | Compliance obligations | The compliance obligations (e.g. a legal and other requirements register) |
| 6.1.4 | Risks and opportunities | The risks and opportunities that need to be addressed |
| 6.2.1 | Environmental objectives | The environmental objectives |
| 7.2 | Competence | Appropriate evidence of competence (e.g. training records, qualifications) |
| 7.4.1 | Communication | Appropriate evidence of the organization’s communications |
| 7.5.1 | Documented information – general | Documented information the organization itself determines is needed for an effective EMS |
| 7.5.3 | External origin documents | Externally originated documents needed for planning and operation of the EMS, identified and controlled |
| 8.1 | Operational planning and control | The process(es) for 8.1, to the extent needed for confidence that they are carried out as planned |
| 8.2 | Emergency preparedness and response | The process(es) for 8.2, to the extent needed for confidence that they are carried out as planned |
| 9.1.1 | Monitoring, measurement, analysis and evaluation | Appropriate evidence of the monitoring, measurement, analysis and evaluation results |
| 9.1.2 | Evaluation of compliance | Appropriate evidence of the compliance evaluation result(s) |
| 9.2.2 | Internal audit programme | The audit program(s); evidence of their implementation; evidence of the audit results |
| 9.3.3 | Management review results | Evidence of the results of management reviews |
| 10.2 | Nonconformity and corrective action | Evidence of the nature of nonconformities and actions taken; the results of any corrective action |
In addition to the items above, many organizations choose to keep further documented information for transparency, consistency, training or ease of auditing – for example operating procedures and work instructions, waste and chemical inventories, emergency plans and drill records, monitoring and calibration records, supplier and contractor evaluations, and complaint logs. Records also help demonstrate that compliance obligations have been met, so set retention periods that are at least as long as those your compliance obligations require.
Practical tips
- Maintain a master list or register of EMS documented information showing owner, current version, location, access rights and retention period;
- Use your existing document management system or shared drive with controlled permissions rather than creating a separate system for environmental documents;
- Back up electronic records and protect paper records from damage, fire and flood;
- Withdraw or clearly mark obsolete documents, and keep superseded permits and procedures only where needed as evidence;
- Keep a register of external documents and check periodically for new versions of permits, legislation and standards.
Our environmental manual templates include a document and record control procedure and supporting forms.
You should seek and record evidence that your organization’s EMS includes the documented information required by ISO 14001:2026 and the documented information it has determined to be necessary for effectiveness; that documents are suitably identified, formatted, reviewed and approved when created or updated; that documented information is available where needed and protected; that distribution, access, storage, preservation, changes, retention and disposition are controlled; and that necessary documents of external origin are identified and controlled. Sample several documents and records at the point of use to confirm that the current version is available and legible.
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