Planning of Changes for ISO 37001 Anti-Bribery
ISO 37001 Clause 6.3
New in 2025. Changes to the ABMS have to be planned, not just made.
ISO 37001 Clause 6.3 - Planning of Changes
Clause 6.3 is one of the additions in the 2025 revision of ISO 37001. The wording is short - if the organisation determines the need for changes to the ABMS, the changes must be carried out in a planned manner. The clause brings ISO 37001:2025 into line with ISO 9001, ISO 14001, ISO 45001, ISO 27001 and the rest of the Annex SL family, all of which now have an equivalent requirement.
What Counts as a Change to the ABMS
The clause is concerned with deliberate changes to the management system itself - things like a revised policy, a restructured anti-bribery function, a new process for due diligence, a change in scope or a change in the documented procedures. Routine updates - small wording changes, version refreshes, minor improvements - do not need a full change-management process, but the standard expects significant changes to be thought through before they are made.
The clause is not the same as Clause 8.1 which deals with planned changes to operational processes during day-to-day running. Clause 6.3 is at the system level - changes to how the ABMS is structured and operated.
Planning a Change in Practice
A planned change typically considers the purpose of the change, the consequences (intended and potential unintended), the resources needed, the assignment or reassignment of responsibilities and authorities, and how effectiveness of the change will be reviewed afterwards. A change review form or change management entry in the issues and actions register usually does the job - the standard does not require documented information for this clause but evidence of planning is expected.
Most organisations cover this through an existing change control process. Where a quality management system is in place, the change review form used for QMS changes can be extended to ABMS changes. Where there is no formal change process, a short note in the issues and actions register against each significant ABMS change works.
This clause is short for a reason. It does not mean a heavy bureaucratic process - it means stop and think before changing the ABMS. Who needs to know, what could go wrong, what will be different afterwards. A short paragraph in the action register usually covers it.
The standard does not require documented information for Clause 6.3 but auditors will look for evidence that significant changes have been planned. A change review form, a management review minute, or an entry in the issues register that records the consideration of consequences and effectiveness review is enough.
Practical Compliance Guidance
Significant changes to the ABMS - revised policies, restructured anti-bribery function, new procedures - are recorded through the change review process and tracked through to confirmation of effectiveness.
The documents below support the planning of changes required by Clause 6.3.
| alphaZ document | How to use it |
|---|---|
| ISO 37001 Toolkit | Complete documentation set for ISO 37001:2025 compliance, including the anti-bribery policy, the PP-1-19 Anti-bribery procedure, audit checklists, risk assessment and all supporting registers and forms. |
| F-Q23 Change Review Form | Template for reviewing and approving changes including consideration of consequences and effectiveness review. |
| ER1 Issues Actions Register | Tracks the action items arising from change planning through to completion. |
| F-Q3 ABMS Management Review | Captures significant ABMS changes considered or implemented during the review period. |
Note - all the above files can be downloaded with an alphaZ subscription.
Frequently Asked Questions
UK Legislation
The following UK legislation forms part of the legal context that often drives changes to the ABMS - new legislation, regulator guidance updates and case law all trigger reviews of the management system.
