In February 2025, a revised edition of the international standard for anti-bribery management systems was released. ISO 37001:2025 replaces the earlier ISO 37001:2016 version. All certified sites must complete the transition to the new standard by February 28, 2027. Key updates include:
ISO 37001:2025 follows the Harmonized Structure (HS)
In May 2021, ISO replaced its High-Level Structure (HLS) with the Harmonized Structure (HS) – a revised version with minor adjustments to content and terminology. The aim of the harmonized structure is to give all ISO management system standards a uniform basic structure with similar core requirements, terms and definitions in order to improve comparability and facilitate the integration of different ISO standards. The new version ISO 37001:2025 follows this Harmonized Structure (HS). As a result, some terms and definitions have been changed – for example, the term “interested parties” is now used instead of “stakeholders”.
Main Changes to the Structure of ISO 37001
Clause 4.1 and 4.2 on climate action
In clause 4.1, a sentence about considering climate change in the context of the organization has been added. Also with NOTE 1, in clause 4.2 it is now explicitly requested to take into account potential concerns around climate change, when considering the relevant requirements of their interested parties. However, these requirements are not actually new: with the ISO document “AMENDMENT 1: Climate action changes” published in February 2024, this requirement was already added to all management system standards, including ISO 37001:2016. Now it is simply incorporated directly into the new version.
New paragraph titles in chapter 9.2 and 9.3
Reversal of clauses 10.1 and 10.2 in chapter 10 Improvement
In chapter 10 of ISO 37001:2016, the first clause is 10.1 Nonconformity and corrective action, whereas 10.2 covers Continuous improvement. The new version, however, starts with Continuous improvement (10.1), followed by Nonconformity and corrective action (10.2).
Clarification of specific requirements in ISO 37001:2025
In addition to the structural changes listed above, ISO 37001:2025 also introduces some additional clarification on specific topics of anti-bribery management systems, to highlight the relevance of these topics.
New clause 5.1.3 Anti-bribery culture
To highlight the importance of anti-bribery culture, this topic gets its own section.
Additional clause 6.3 Planning of changes
The requirement of planning changes in anti-bribery management systems now has a dedicated clause, in accordance with Harmonized Structure (HS).
New point in chapter 7.2.2 on Employment process
Awareness on conflicts of interest was added to the list of requirements referenced in 7.2.2.1 e)
New title chapter 7.3 Awareness
In the chapter Awareness, the requirements for awareness and training have been restructured. The requirements for training business partners have their own section, 7.3.3.
8.4 Non-financial controls – a new risk area is mentioned
In this clause 8.4 an additional area mergers and acquisitions has been listed