The ISO 37001 standard helps companies to demonstrate their commitment to the prevention of bribery and to ensure compliance with legal requirements. By implementing an anti-bribery management system in accordance with the requirements of ISO 37001, organizations can systematically prevent, detect and combat bribery. Certification by an accredited third-party like DQS helps to showcase the effectiveness of the chosen approach, thereby reducing risks for all stakeholders.

Although the revised version of ISO 37001 comes with a number of changes, the impact of the changes on certified sites will be minimal. According to the foreword of ISO 3700:2025, the main changes can be summarized as follows:

• Subclauses on climate change and stressing the importance of the compliance culture have been added.
• Conflicts of interests have been addressed.
• The concept of the anti-bribery function has been clarified.
• The wording has been harmonized with other standards where appropriate and reasonable.
• The latest harmonized structure has been introduced.

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

The changes in the new version are generally not very extensive. We recommend checking whether and how the changes in structure and the specific requirements affect your anti-bribery management systems. In this context, we would also like to point out few new guidelines you can use. These include e.g. the following published guidelines:

• ISO 37000 - Governance of organizations - Guidance
• ISO 37002 - Whistleblowing management systems - Guidelines
• ISO/FDIS 37003 - Fraud control management systems - Guidance for organizations managing the risk of fraud
• ISO 37004 - Governance of organizations - Governance maturity model - Guidance
• ISO 37005 Governance of organizations - Developing indicators for effective governance
• ISO/TS 37008 - Internal investigations of organizations - Guidance
• ISO/FDIS 37009 - Conflict of interest in organizations - Guidance