Revision of Anti-bribery Management System - ISO 37001

Strengthening organizational integrity and anti-bribery culture, ISO 37001 emphasizes the importance of cultivating a culture of integrity and ethical behaviour across the organization. It empowers leadership to actively champion anti-bribery values, creating a transparent and accountable environment that protects the organization’s reputation and builds stakeholder trust.

Update ISO 37001:2016

The update for ISO 37001 was released on February 3, 2025.  The structure remains similar, following the common pattern of ISO management system standards, but ISO 37001:2025 includes additional subclauses to address new aspects.

Main changes appear to be:

• The text of ISO 37001:2025 has been harmonized with other management system standards, such as ISO 37301 (compliance management systems), ISO 37000 (governance of organisations) and ISO/TS 37008 (internal investigations of organizations) to ensure consistency and easier integration.
• ISO 37001:2025 formally introduces the concept of anti-bribery culture and emphasizes its importance for the effectiveness of the management system.
• The term anti-bribery compliance function in ISO 37001:2016 has been replaced with anti-bribery function in ISO 37001:2025, with a clearer description of its responsibilities and operational independence.
• Greater emphasis on the role of the governing body and top management with more involvement in overseeing the management system and its intended results.
• Awareness and training as fundamental asset for ABMS results.
• New subsections on climate change.
• More comprehensive definition of conflict-of-interest as well as procedures to raise awareness on reporting potential and actual conflicts.
• Chapter 8 - Operation - which contains the description of operational control, has not been amended.

No major changes have been made in Annex A.

Transition rules and timeline

The transition period for ISO standards is typically a maximum of three years, but in the case of limited changes it may be shorter and for ISO 37001, the anticipated transition timeline is two years. The International Accreditation Forum (IAF) is expected to develop mandatory documents for the transition of certificates to the new standards which are expected to be available in August 2025.

Preparing for implementation

For now, we are awaiting news from the IAF. Therefore, it is suggested that you wait with tangible preparations to transition until the needed documents have further progressed.

Then we recommend you start preparing for the transition as early as possible and plan properly to incorporate needed changes into your management system.
Recommended steps for the transition:

• Get to know the content and requirements of the new standard as soon as possible now that it has been published bearing in mind that the transition time may be as little as two years. Focus on the changes implied by the revised standard.
• Ensure that relevant personnel in your organization are trained and understand the requirements and key changes.
• Identify gaps which need to be addressed to meet the new requirements and establish an implementation plan.
• Implement actions and update your management system to meet the new requirements.

How we can support

Once you start preparing to transition to the new version of ISO 37001:2025, DNV can support your journey.
We will be able to support you with:

• Trainings where you learn about the revision and get a basic overview of key changes and the transition process.
• Online self-assessment tools and onsite/off-site gap assessments to measure how well your management system meets the new requirements.
• Transition audit to move your certification in line with the new version of the standard.

We can support you every step of the way.