Based on the Draft International Standard (DIS) published August 2025. Final requirements may vary upon publication, expected Autumn 2026.
Before You Begin: Understanding the Transition
This checklist is for SMEs either transitioning from ISO 9001:2015 or implementing the standard for the first time in 2026.
The first thing to understand is the scale of change involved. The DIS reveals a standard that evolves rather than revolutionises. The core requirements in Clauses 4 to 10 feature only minor changes, meaning a minimal transition burden for organisations already compliant with ISO 9001:2015.
Timing for the Transition
The standard is targeted for publication in September 2026, after which a three-year transition period is expected, meaning the 2015 version would remain valid until approximately September 2029. Additionally, certification bodies (registrars) will require 9 to 12 months to become accredited to audit against the new version, meaning the first ISO 9001:2026 certificates are unlikely to be issued before mid-to-late 2027. There is time to plan properly, but acting early gives you the advantage.
Section 1: The Three Confirmed Changes in ISO 9001:2026
These are the substantive changes confirmed in the DIS. Everything else is either clarification, editorial improvement, or expanded guidance in the new Annex A.
1.1 Climate Change Consideration (Clause 4.1)
Clause 4.1, which covers understanding the organisation and its context, now requires organisations to determine whether climate change is a relevant issue for their QMS. This does not mean you must build an environmental management system, it simply means the question must be asked and answered.
What to document:
- A written assessment within your context analysis (SWOT/PESTLE or equivalent) recording whether climate change is relevant to your operations
- If relevant: how that feeds into your risk and opportunity register
- If not relevant: a brief, justified rationale explaining why
Editor Note: This requirement was actually introduced via Amendment 1 in February 2024 and is already in force. Certification bodies are now checking for compliance with the climate clauses during regularly scheduled audits. If you haven't addressed this yet, it is the most urgent item on this list.
1.2 Quality Culture and Ethical Behaviour (Clause 5.1)
Promoting quality culture and ethical behaviour has been added as a new entry in Clause 5.1 "Leadership and Commitment", with new guidance on how such promotion can be demonstrated.
Commitment on paper will no longer be sufficient - organisations will need to demonstrate how this culture is practised daily.
What to document:
- Evidence of how top management actively promotes quality culture (examples: leadership briefings, all-staff communications, visible participation in audits or reviews)
- An updated Quality Policy that reflects ethical behaviour as a stated value
- Updated awareness training records showing that staff at all levels understand what quality culture and ethical behaviour mean in practice (this is also a new awareness requirement under Clause 7.3)
1.3 Separated Risk and Opportunity Management (Clause 6.1)
The 2026 version reorganises Clause 6.1 into sub-clauses 6.1.1 to 6.1.3, providing a clearer separation between actions for addressing risks and pursuing opportunities.
ISO/DIS 9001 separates risk from opportunity and introduces stronger "opportunity-based thinking". Your organisation may need to show clearer structures for resilience planning and demonstrate how risks are balanced with proactive opportunities.
What to document:
- A revised risk register that clearly distinguishes risks (things that could go wrong) from opportunities (things you could do better)
- Evidence of analysis and evaluation, not just a list - auditors will want to see that risks have been assessed for likelihood and impact
- Documented actions taken in response to both risks and opportunities, with outcomes recorded
Section 2: Existing Documentation to Review
These documents are not new requirements, but the 2026 changes mean they need revisiting.
| Document | What to Check |
|---|---|
| Scope Statement | Still accurate? Reflects current activities and any justified exclusions? |
| Interested Parties Register | Does it note whether any stakeholders have climate-related requirements? (Clause 4.2) |
| Quality Manual (if used) | Reflects updated clause structure and new Clause 5.1 language? |
| Internal Audit Schedule | Planned against 2026 clause structure before your external audit? |
| Management Review Minutes | Do they reference climate relevance and quality culture progress? |
| Competence and Training Records | Updated to include ethics and quality culture awareness? |
Section 3: Preparing for Your Transition Audit
A few practical steps to take before your auditor arrives:
- Conduct a gap analysis against the three confirmed changes above. Many certification bodies offer templates or pre-audit workshops.
- Brief top management on their new obligations under Clause 5.1. Leadership buy-in needs to be visible and evidenced, not just stated.
- Check your version control - make sure superseded 2015-era documents are archived and new templates are clearly dated and distributed.
- Speak to your certification body early about their transition audit timeline and what evidence they will expect.
A Note on ISO 14001 and ISO 42001
The original version of this checklist combined ISO 9001:2026 transition requirements with those of ISO 14001 and ISO 42001. These are separate standards with separate certification scopes, and their inclusion alongside ISO 9001:2026 transition guidance risks confusion.
- ISO 14001 (Environmental Management): If you hold or are pursuing ISO 14001 certification, speak directly to your certification body for current requirements.
- ISO 42001 (AI Management): A separate standard for organisations that develop or use AI systems. If this is relevant to your business, it warrants its own dedicated checklist rather than being appended here.
If you need guidance on either standard, the ISOCentral directory can connect you with a specialist ISO consultant.
ISOCentral Implementation Tip
Many SMEs struggle with document version control during a transition period. A dedicated Management System Software platform can automate the archiving of 2015-era documents whilst ensuring updated 2026 templates are distributed correctly across your team. Search the ISOCentral directory to find ISO consultants and software providers who specialise in ISO 9001:2026 transition support.