Clause 9 of ISO 14001 is about checking whether the Environmental Management System is working. In plain English, this means the organisation must monitor, measure, analyse, evaluate, audit and review the EMS so it can understand performance, compliance and improvement needs.
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:
Together, these activities help the organisation understand environmental performance, evaluate compliance, identify weaknesses, make informed decisions and drive improvement.
An EMS should not run on hope, habit or paperwork.
The organisation needs evidence to understand whether:
Clause 9 helps prevent the EMS from becoming a “set and forget” system. It keeps the organisation checking, learning and improving.
Clause 9 sits mainly in the “Check” part of Plan–Do–Check–Act.
It receives evidence from earlier clauses, including:
It then feeds outputs into:
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 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:
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 sets the general requirements for monitoring, measurement, analysis and evaluation.
It asks the organisation to determine:
For learners and auditors, this sub-clause is best understood as the foundation of EMS performance data. It helps ensure the organisation is collecting useful information and using it properly.
Clause 9.1.2 asks the organisation to evaluate fulfilment of 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:
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 asks the organisation to carry out internal audits at planned intervals.
Internal audits should provide information on whether the EMS:
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 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 asks the organisation to establish, implement and maintain an internal audit programme.
The audit programme should consider matters such as:
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 asks top management to review the EMS at planned intervals.
Management review should consider whether the EMS remains:
It should consider inputs such as audit results, environmental performance, compliance status, objectives, risks and opportunities, resource needs, changes, communications and improvement opportunities.
Management review should lead to useful decisions and actions. It should not be a ceremonial meeting where people read numbers aloud and flee.
Read the detailed SQMC guide to management review.
Clause 9 works best when monitoring, compliance evaluation, internal audit and management review support each other.
For example:
The EMS should use performance evaluation to learn and improve. The parts of Clause 9 should not operate as isolated admin tasks.
Auditors look for evidence that the organisation checks EMS performance and uses the results to make decisions.
Evidence may include:
Clause 9 is about evidence and decisions. Do not only check that monitoring, audits and reviews happened. Check whether the organisation learned anything useful and acted on it.
“The organisation monitors environmental performance, carries out audits and holds a management review once a year.”
This is weak because it does not show what is monitored, whether results are analysed, whether compliance is evaluated, whether audits are meaningful, or whether management review leads to decisions and improvement.
“The organisation monitors significant environmental aspects, evaluates compliance obligations, tracks objectives, carries out risk-based internal audits, and reviews EMS performance through management review. Outputs from performance evaluation are used to update controls, allocate resources, raise corrective actions and identify improvement opportunities.”
This is stronger because it shows Clause 9 working as an evidence-based improvement loop.
A warehouse and distribution company monitors fuel use, waste segregation, packaging waste, spill-kit inspections and contractor performance.
Its Clause 9 activities may include:
An auditor could test whether performance data, audit findings and management decisions connect to real improvement.
An office-based organisation may evaluate performance using simpler indicators.
Examples include:
Clause 9 should still produce useful insight, even where environmental risks are lower.
This page is part of SQMC’s ISO 14001:2026 guidance library for auditors, managers and QHSE professionals.
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