Management system guidance
9.0 Performance Evaluation
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9.3 Management review
Clause 9.3 requires top management to step back, at intervals it has planned, and review the environmental management system (EMS) as a whole. The purpose is to confirm that the EMS is still suitable, adequate and effective, and to decide what needs to change. ISO 14001:2026 sets the requirement out in three parts: 9.3.1 (general), 9.3.2 (the inputs the review must cover) and 9.3.3 (the results it must produce).
What changed in ISO 14001:2026: the single 2015 clause has been split into sub-clauses 9.3.1, 9.3.2 and 9.3.3, and the term ‘outputs’ has been replaced by ‘results’. Changes in the needs and expectations of interested parties are now qualified as those relevant to the EMS, trends in ‘fulfilment’ of compliance obligations now read ‘meeting’ compliance obligations, and documented information of the results must be available as evidence (previously ‘retained’). The content of the inputs and results is otherwise the same as in 2015.
9.3.1 Management review - general
Annex A explains the three review criteria. Suitability is about how well the EMS fits the organization, its operations, culture and business systems. Adequacy is about whether it meets the requirements of ISO 14001 and is properly implemented. Effectiveness is about whether it is delivering the intended results, such as better environmental performance, meeting compliance obligations and achieving environmental objectives.
The review is a top-level, strategic look at the system; it does not need to examine every detailed record. Top management, who are accountable for the EMS (see clause 5.1), must take part. Other attendees might include the EMS coordinator, managers of operations with significant environmental aspects, the person responsible for compliance obligations, and the internal auditor(s).
How often, and in what format?
ISO 14001 does not set a frequency. Choose intervals that let decisions be acted on in good time; a single annual meeting is rarely enough to respond to emerging environmental issues. The topics do not have to be covered all at once, and the review does not have to be a separate meeting. Many organizations spread the inputs across a review program, for example:
- monthly or quarterly: environmental performance data, progress on objectives, incidents, nonconformities and corrective actions;
- six-monthly: evaluation of compliance results, audit findings and communications from interested parties;
- annually: context, interested parties, significant aspects, risks and opportunities, the environmental policy and the strategic direction of the business.
Board meetings, operational management meetings and reviews of other management systems (for example an integrated ISO 9001 or ISO 45001 review) can all count, provided the required inputs are considered and the results are recorded.
9.3.2 Management review inputs
Your review must consider:
- the status of actions raised at earlier management reviews;
- changes in:
- external and internal issues relevant to the EMS (clause 4.1);
- the needs and expectations of interested parties that are relevant to the EMS, including compliance obligations (clause 4.2 and clause 6.1.3);
- significant environmental aspects (clause 6.1.2);
- risks and opportunities (clause 6.1.4);
- how far environmental objectives have been achieved (clause 6.2.1);
- information on environmental performance, including trends in nonconformities and corrective actions (clause 10.2), monitoring and measurement results (clause 9.1.1), meeting compliance obligations (clause 9.1.2) and audit results (clause 9.2);
- whether resources are adequate (clause 7.1);
- relevant communications from interested parties, including complaints (clause 7.4.3);
- opportunities for continual improvement (clause 10.1).
Gather and summarize this information before the meeting so that top management can evaluate it rather than read raw data. Trend charts of energy, water, waste, emissions and similar indicators are far more useful than single figures. Annex A notes that complaints and other communications from interested parties should be reviewed to identify improvement opportunities.
9.3.3 Management review results
The review must lead to:
- conclusions about whether the EMS remains suitable, adequate and effective;
- decisions on opportunities for continual improvement;
- decisions on any changes needed to the EMS, including resources;
- actions where environmental objectives have not been met;
- where needed, opportunities to integrate the EMS better with other business processes;
- any implications for the organization’s strategic direction.
When deciding whether the EMS needs to change, top management should look in particular at situations where its intended outcomes have not been achieved. Changes to the EMS that come out of the review should be handled as planned changes (see clause 6.3). Record each action with an owner and target date, communicate it to those affected, and track it to completion; the status of these actions becomes the first input to the next review.
The results can be recorded in any format: minutes, an annotated agenda, a presentation with decisions noted, or entries in a management system database. Our environmental management system templates include a management review agenda and minutes form.
You should seek and record evidence that top management reviews the EMS at planned intervals; that every input listed in 9.3.2 has been considered over the review cycle; that the review reached conclusions on suitability, adequacy and effectiveness; that decisions on improvement, changes to the EMS, resources and missed objectives were made; and that documented information of the results is available and the resulting actions have been followed through.
More information on PDCA
Planning
Context
Planning
Support
Doing
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Operations
Checking
Monitoring, measurement, analysis and evaluation
Acting
Improvement
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