ISO 37001:2025 – A New Anti-Bribery Management system standard

This updated standard supersedes the 2016 edition and reflects the evolving global focus on ethics, governance, and sustainability.

In anticipation of the 2025 update, ISO has published Amendment 1:2024 to ISO 37001:2016, effective February 2024, which introduced changes -including the incorporating climate action considerations into anti-bribery management systems.

Key Enhancements in ISO 37001:2025

1. Stronger Emphasis on Integrity and Ethical Culture

Clause 5.1.3 Anti-bribery culture states: “The organization shall develop, maintain and promote an anti-bribery culture at all levels within the organization.”

The new edition reinforces the importance of cultivating a culture of integrity. Leadership is now responsible for promoting anti-bribery values, fostering a transparent and accountable environment that strengthens organizational reputation.

This requirement underscores the critical role of leadership in fostering an environment where ethical behavior is prioritized, and anti-bribery principles are integrated into the organization’s core values and operations.

By explicitly addressing the need for an anti-bribery culture, ISO 37001:2025 aligns with contemporary expectations for organizations to not only implement policies and procedures but also to cultivate an ethical organizational culture that actively deters bribery and corruption.

2. The requirement for clarifying anti-corruption roles and responsibilities

Clause 5.3 Roles, responsibilities and authorities has been refined and expanded to provide greater clarity and emphasis on:

• The assignment of anti-bribery responsibilities across the organization
• The role of top management in ensuring accountability
• The authority and independence of the anti-bribery compliance function
• Ensuring personnel understand and fulfill their duties related to bribery prevention

Top management shall define and communicate the roles, responsibilities, and authorities necessary to establish, implement, maintain, and improve the anti-bribery management system. This clarification is key to ensuring an effective anti-bribery management system by making sure everyone knows their specific duties in preventing, detecting, and responding to bribery, especially in complex or global organizations, thereby strengthening the organization’s overall anti-corruption efforts.

3. Integration of Climate Action Considerations

The updated standard Clauses 4.1 Understanding the organization and its context and 4.2. Understanding the needs and expectations of interested parties embeds climate action into anti-bribery frameworks. Organizations are required to assess the relevance of climate change to their operations. This includes evaluating how climate-related risks, such as extreme weather events and regulatory changes, may impact business activities. Climate change, should be determined as relevant or not and if relevant, considered within an evaluation of risk, within the scope of the management systems standards.

In addition, organizations are required to understand the climate-related needs and expectations of interested parties.

As changes was already published in Amendment 1:2024 to ISO 37001:2016, with effective date February 2024, no transition period stated, which means that organizations need to act immediately and to consider climate change aspects and risks within the development, maintenance and effectiveness of their management system.

4. Improved Conflict of Interest Management

The standard Clause 8.2 Due diligence now offers clearer and more detailed guidance on identifying and managing and mitigating conflicts of interest, as part of their due diligence processes. Therefore, organizations are now required to establish mechanisms to detect, prevent, and control conflicts of interest, such as maintaining a register of conflict of interest declarations with annual reviews. The updated standard recognizes conflicts of interest as significant risks in preventing bribery and ensuring operational impartiality and credibility.

5. Harmonisation with other Management System Standards

ISO 37001:2025 enhances alignment with other management system standards like ISO 9001, ISO 14001, making integration easier for organizations adopting multiple standards. This supports streamlined implementation across multiple systems.

Why These Changes Matter?

These updates are designed to make anti-bribery programs more effective, resilient, and aligned with today’s ethical and environmental expectations. The inclusion of sustainability and governance considerations supports organizations in building long-term trust and compliance.

Transition and Implementation Guidance

ISO has proposed a two-year transition period following the publication of ISO 37001:2025 – until February 2027, though final confirmation from the International Accreditation Forum (IAF) is still pending.

At the same time climate-related amendments (clauses 4.1 and 4.2) from 2024 require immediate implementation.