What is ISO 14001 Clause 9 trying to achieve?

Clause 9 asks a simple but vital question: how does the organisation know the EMS is working?

The organisation may have a policy, objectives, procedures, operational controls and emergency arrangements — but Clause 9 is where it checks whether those arrangements are effective.

Clause 9 covers three main areas:

• Clause 9.1 — monitoring, measurement, analysis and evaluation;
• Clause 9.2 — internal audit;
• Clause 9.3 — management review.

Together, these activities help the organisation understand environmental performance, evaluate compliance, identify weaknesses, make informed decisions and drive continual improvement.

Why performance evaluation matters in an EMS

An EMS should not run on hope, habit or paperwork.

The organisation needs evidence to understand whether:

• environmental objectives are being achieved;
• operational controls are working;
• compliance obligations are being fulfilled;
• significant environmental aspects are being controlled;
• risks and opportunities are being addressed;
• internal audits are identifying useful findings;
• top management has the information needed to make decisions;
• the EMS remains suitable, adequate and effective.

Clause 9 helps prevent the EMS from becoming a “set and forget” system. It keeps the organisation checking, learning and improving.

How Clause 9 fits into the EMS

Clause 9 sits mainly in the “Check” part of Plan–Do–Check–Act.

It receives evidence from earlier clauses, including:

• Clause 6.1.2 — environmental aspects;
• Clause 6.1.3 — compliance obligations;
• Clause 6.1.4 — risks and opportunities;
• Clause 6.2 — environmental objectives;
• Clause 8.1 — operational planning and control;
• Clause 8.2 — emergency preparedness and response.

It then feeds evidence and decisions into:

• Clause 10.1 — continual improvement;
• Clause 10.2 — nonconformity and corrective action;
• future EMS planning, resources, objectives and operational controls.

Auditors should see Clause 9 as the EMS evidence-and-decision loop. It checks whether the system is doing what it was designed to do.

Clause 9.1 — Monitoring, measurement, analysis and evaluation

Clause 9.1 asks the organisation to determine what needs to be monitored and measured, how this will be done, when it will happen, and when results will be analysed and evaluated.

This may include monitoring and measurement of:

• environmental objectives;
• significant environmental aspects;
• operational controls;
• energy, water, waste, fuel or emissions;
• compliance-related activities;
• incidents and complaints;
• contractor performance;
• emergency preparedness;
• corrective actions and improvement activity.

Monitoring and measurement should produce useful information. Data should not simply be collected because “the spreadsheet exists”.

Read the detailed SQMC guide to monitoring, measurement, analysis and evaluation.

Clause 9.1.1 — General performance evaluation requirements

Clause 9.1.1 sets the general requirements for monitoring, measurement, analysis and evaluation.

It asks the organisation to decide what performance information matters and how it will be gathered, analysed and evaluated.

For learners and auditors, this sub-clause is best understood as the “performance data” requirement. It helps ensure the organisation is collecting useful information and using it properly, rather than simply keeping scattered records.

Monitoring and measurement should normally link back to significant environmental aspects, compliance obligations, operational controls, objectives, risks and opportunities.

Clause 9.1.2 — Evaluation of compliance

Clause 9.1.2 asks the organisation to evaluate whether it is fulfilling its compliance obligations.

In simple terms, the organisation must check whether it is meeting the environmental legal, customer, contractual and other requirements it has identified.

This may include checking:

• permit or licence conditions;
• waste documentation;
• monitoring results;
• legal register actions;
• customer environmental reporting requirements;
• contractor or supplier obligations;
• inspection and maintenance requirements;
• regulator correspondence or reporting duties.

Evaluation of compliance is more than saying “we haven’t had any fines”. The organisation should actively check compliance at planned intervals and take action where needed.

Read the detailed SQMC guide to evaluation of compliance.

Clause 9.2 — Internal audit

Clause 9.2 asks the organisation to carry out internal audits at planned intervals.

Internal audits should provide information on whether the EMS:

• conforms to the organisation’s own EMS requirements;
• conforms to ISO 14001 requirements;
• is effectively implemented and maintained.

Internal auditing is not a box-ticking exercise. It is one of the organisation’s strongest tools for checking the EMS and identifying improvement opportunities.

Read the detailed SQMC guide to internal audit.

Clause 9.2.1 — Internal audit general requirements

Clause 9.2.1 sets the basic purpose of internal audit.

It focuses on whether the EMS conforms to requirements and whether it is effectively implemented and maintained.

Auditors should remember that internal audit is not just about finding nonconformities. It should provide useful information about EMS performance, effectiveness and improvement needs.

Clause 9.2.2 — Internal audit programme

Clause 9.2.2 asks the organisation to establish, implement and maintain an internal audit programme.

The audit programme should consider matters such as:

• the environmental importance of the processes concerned;
• changes affecting the organisation;
• previous audit results;
• audit criteria and scope;
• audit frequency;
• audit methods;
• auditor objectivity and impartiality;
• reporting of audit results;
• retention of audit programme and audit result evidence.

This is a strong practical area for auditors and QHSE managers. A good audit programme should be risk-based, planned and useful — not simply a repeating calendar of clause numbers.

View the SQMC ISO 14001 audit programme template.

Clause 9.3 — Management review

Clause 9.3 asks top management to review the EMS at planned intervals. In ISO 14001:2026, management review is presented through three subclauses:

• Clause 9.3.1 — general requirement;
• Clause 9.3.2 — management review inputs;
• Clause 9.3.3 — management review results.

The purpose is to ensure top management has enough information to judge whether the EMS remains suitable, adequate and effective, and to make decisions where action or change is needed.

Read the detailed SQMC guide to management review.

Clause 9.3.1 — General management review requirement

Clause 9.3.1 establishes the basic requirement for top management to review the EMS at planned intervals.

The review should help top management understand whether the EMS continues to fit the organisation, has enough structure and resources to work properly, and is achieving the results it is intended to achieve.

Management review does not need to be a ceremonial once-a-year meeting where everyone reads numbers aloud and flees. It can be carried out through suitable management activities, provided the necessary information is reviewed and useful decisions are made.

Clause 9.3.2 — Management review inputs

Clause 9.3.2 identifies the types of information that should feed into management review.

In practical terms, top management should review information such as:

• the status of previous management review actions;
• changes in internal and external issues affecting the EMS;
• changes in interested party needs and expectations, including compliance obligations;
• changes in significant environmental aspects;
• changes in risks and opportunities;
• progress towards environmental objectives;
• environmental performance trends;
• nonconformities and corrective actions;
• monitoring and measurement results;
• fulfilment of compliance obligations;
• audit results;
• resource adequacy;
• relevant communications from interested parties, including complaints;
• opportunities for continual improvement.

These inputs should help top management understand EMS performance and decide what needs to change, continue or improve.

Clause 9.3.3 — Management review results

Clause 9.3.3 focuses on what should come out of management review.

The review should produce useful results, such as:

• conclusions on whether the EMS remains suitable, adequate and effective;
• decisions about continual improvement opportunities;
• decisions about changes needed to the EMS;
• decisions about resource needs;
• actions where environmental objectives have not been achieved;
• opportunities to improve how the EMS is integrated with business processes;
• consideration of any implications for the organisation’s strategic direction.

Documented information should be available as evidence of the results of management review. In plain English, the organisation should be able to show what was reviewed, what was concluded, what decisions were made and what actions were agreed.

Performance evaluation should be connected

Clause 9 works best when monitoring, compliance evaluation, internal audit and management review support each other.

For example:

• monitoring data may show increasing waste levels;
• internal audit may identify weak waste segregation controls;
• evaluation of compliance may find documentation gaps;
• management review may decide to allocate resources and set a new objective;
• corrective action may update training, signage and contractor controls.

The EMS should use performance evaluation to learn and improve. The parts of Clause 9 should not operate as isolated admin tasks.

What auditors typically look for in Clause 9

Auditors look for evidence that the organisation checks EMS performance and uses the results to make decisions.

Evidence may include:

• monitoring and measurement plans;
• environmental performance data;
• analysis and evaluation records;
• environmental objective progress reports;
• evaluation of compliance records;
• internal audit programme;
• internal audit plans and reports;
• audit findings and corrective actions;
• management review inputs;
• management review results;
• decisions and actions from management review;
• evidence of improvement following evaluation.

Common weaknesses in Clause 9

• monitoring data is collected but not analysed;
• environmental objectives are not properly tracked;
• compliance evaluation is informal or incomplete;
• internal audits repeat the same checklist every year;
• audit programmes do not consider environmental importance, changes or previous results;
• auditors are not objective or competent;
• management review is superficial;
• management review inputs are incomplete;
• management review results do not include clear conclusions, decisions or actions;
• resource needs are identified but not addressed;
• performance evaluation outputs do not lead to corrective action or improvement;
• top management does not receive enough useful EMS information.

Weak example

Better example

Real-world example: warehouse and distribution company

A warehouse and distribution company monitors fuel use, waste segregation, packaging waste, spill-kit inspections and contractor performance.

Its Clause 9 activities may include:

• monthly review of fuel use and route efficiency;
• waste data analysis by waste stream;
• periodic compliance evaluation for waste documentation;
• internal audits of loading bays, waste areas and contractor control;
• management review of environmental objectives, audit findings and resource needs;
• corrective actions when waste contamination or missed inspections occur.

An auditor could test whether performance data, audit findings and management decisions connect to real improvement.

Real-world example: office-based organisation

An office-based organisation may evaluate performance using simpler indicators.

Examples include:

• electricity use;
• business travel emissions;
• paper consumption;
• IT equipment disposal records;
• supplier environmental checks;
• progress against objectives;
• internal audit results;
• management review decisions and actions.

Clause 9 should still produce useful insight, even where environmental risks are lower.

Auditor questions for ISO 14001 Clause 9

• What does the organisation monitor and measure?
• How does the organisation decide what needs monitoring?
• How are monitoring results analysed and evaluated?
• How does the organisation evaluate environmental performance?
• How does it evaluate fulfilment of compliance obligations?
• How often are internal audits carried out?
• How is the internal audit programme planned?
• How are audit criteria, scope and methods defined?
• How are internal audit results reported and acted upon?
• How does top management review EMS performance?
• What management review inputs are considered?
• What management review results are recorded?
• What decisions and actions result from management review?
• How does performance evaluation lead to continual improvement?

Related ISO 14001 clauses

• Clause 4.1 — Understanding the organisation and its context
• Clause 5.1 — Leadership and commitment
• Clause 6.1.2 — Environmental aspects
• Clause 6.1.3 — Compliance obligations
• Clause 6.2 — Environmental objectives
• Clause 7.2 — Competence
• Clause 7.5 — Documented information
• Clause 8.1 — Operational planning and control
• Clause 8.2 — Emergency preparedness and response
• Clause 10.1 — Continual improvement
• Clause 10.2 — Nonconformity and corrective action

Continue learning

This page is part of SQMC’s ISO 14001:2026 guidance library for auditors, managers and QHSE professionals.

• Return to ISO 14001:2026 for Auditors
• Monitoring, measurement, analysis and evaluation explained
• Evaluation of compliance explained
• Internal audit explained
• ISO 14001 audit programme template
• Management review explained