ISO 37001:2025
The second edition of the ISO anti-bribery management system standard (February 2025): context including climate change, bribery risk assessment, governing body and top management leadership, anti-bribery culture, policy, the anti-bribery function, delegated decisions, planning of changes, employment controls including conflicts of interest, awareness and training for personnel and business associates, due diligence, financial and non-financial controls, controlled organizations and business associates, gifts and hospitality, raising concerns, investigations, audit and review. Read against the complete English text; replaces ISO 37001:2016, transition ends 28 February 2027.
ISO 37001:2025 is a compliance framework from International with 7 domains and 47 controls that map to 1 other frameworks. The largest domains are Support – ISO 37001:2025 (11 controls), Operation – ISO 37001:2025 (10 controls), Performance evaluation – ISO 37001:2025 (9 controls). Every control below carries what it requires and what an assessor expects to see.
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Framework Domains (7)
Context of the organization – ISO 37001:2025
| Code | Title |
|---|---|
| iso-37001-2025::4.1 | 4.1 Understanding the organization and its context |
| iso-37001-2025::4.2 | 4.2 Understanding the needs and expectations of interested parties |
| iso-37001-2025::4.3 | 4.3 Determining the scope of the anti-bribery management system |
| iso-37001-2025::4.4 | 4.4 Anti-bribery management system |
| iso-37001-2025::4.5 | 4.5 Bribery risk assessment |
Improvement – ISO 37001:2025
| Code | Title |
|---|---|
| iso-37001-2025::10.1 | 10.1 Continual improvement |
| iso-37001-2025::10.2 | 10.2 Nonconformity and corrective action |
Leadership – ISO 37001:2025
| Code | Title |
|---|---|
| iso-37001-2025::5.1.1 | 5.1.1 Governing body |
| iso-37001-2025::5.1.2 | 5.1.2 Top management |
| iso-37001-2025::5.1.3 | 5.1.3 Anti-bribery culture |
| iso-37001-2025::5.2 | 5.2 Anti-bribery policy |
| iso-37001-2025::5.3.1 | 5.3.1 General |
| iso-37001-2025::5.3.2 | 5.3.2 Anti-bribery function |
| iso-37001-2025::5.3.3 | 5.3.3 Delegated decision-making |
Operation – ISO 37001:2025
| Code | Title |
|---|---|
| iso-37001-2025::8.1 | 8.1 Operational planning and control |
| iso-37001-2025::8.10 | 8.10 Investigating and dealing with bribery |
| iso-37001-2025::8.2 | 8.2 Due diligence |
| iso-37001-2025::8.3 | 8.3 Financial controls |
| iso-37001-2025::8.4 | 8.4 Non-financial controls |
| iso-37001-2025::8.5 | 8.5 Implementation of anti-bribery controls by controlled organizations and by business associates |
| iso-37001-2025::8.6 | 8.6 Anti-bribery commitments |
| iso-37001-2025::8.7 | 8.7 Gifts, hospitality, donations and similar benefits |
| iso-37001-2025::8.8 | 8.8 Managing inadequacy of anti-bribery controls |
| iso-37001-2025::8.9 | 8.9 Raising concerns |
Performance evaluation – ISO 37001:2025
| Code | Title |
|---|---|
| iso-37001-2025::9.1 | 9.1 Monitoring, measurement, analysis and evaluation |
| iso-37001-2025::9.2.1 | 9.2.1 General |
| iso-37001-2025::9.2.2 | 9.2.2 Internal audit programme |
| iso-37001-2025::9.2.3 | 9.2.3 Audit procedures, controls and systems |
| iso-37001-2025::9.2.4 | 9.2.4 Objectivity and impartiality |
| iso-37001-2025::9.3.1 | 9.3.1 General |
| iso-37001-2025::9.3.2 | 9.3.2 Management review inputs |
| iso-37001-2025::9.3.3 | 9.3.3 Management review results |
| iso-37001-2025::9.4 | 9.4 Review by anti-bribery function |
Planning – ISO 37001:2025
| Code | Title |
|---|---|
| iso-37001-2025::6.1 | 6.1 Actions to address risks and opportunities |
| iso-37001-2025::6.2 | 6.2 Anti-bribery objectives and planning to achieve them |
| iso-37001-2025::6.3 | 6.3 Planning of changes |
Support – ISO 37001:2025
| Code | Title |
|---|---|
| iso-37001-2025::7.1 | 7.1 Resources |
| iso-37001-2025::7.2.1 | 7.2.1 General |
| iso-37001-2025::7.2.2 | 7.2.2 Employment process |
| iso-37001-2025::7.3.1 | 7.3.1 Awareness of personnel |
| iso-37001-2025::7.3.2 | 7.3.2 Training for personnel |
| iso-37001-2025::7.3.3 | 7.3.3 Training for business associates |
| iso-37001-2025::7.3.4 | 7.3.4 Awareness and training programmes |
| iso-37001-2025::7.4 | 7.4 Communication |
| iso-37001-2025::7.5.1 | 7.5.1 General |
| iso-37001-2025::7.5.2 | 7.5.2 Creating and updating documented information |
| iso-37001-2025::7.5.3 | 7.5.3 Control of documented information |
Maps to 1 other framework
Coverage is not the same as your position
This page shows what ISO 37001:2025 overlaps with in general. Where your organisation actually stands, against the standard you are going for and the certifications you already hold, is a different question. Same graph and the same recorded refutations, scoped to you rather than to a pair.
The Compliance Position Diagnostic, $5,000 fixed, ten business daysWhat is ISO 37001:2025 and who does it apply to?
ISO 37001:2025 is a compliance framework from International with 7 domains and 47 controls. The second edition of the ISO anti-bribery management system standard (February 2025): context including climate change, bribery risk assessment, governing body and top management leadership, anti-bribery culture, policy, the anti-bribery function, delegated decisions, planning of changes, employment controls including conflicts of interest, awareness and training for personnel and business associates, due diligence, financial and non-financial controls, controlled organizations and business associates, gifts and hospitality, raising concerns, investigations, audit and review. Read against the complete English text; replaces ISO 37001:2016, transition ends 28 February 2027. It is used by organisations to establish and maintain compliance with industry standards and regulatory requirements.
What does ISO 37001:2025 actually require?
ISO 37001:2025 has 47 controls organised across 7 domains. The largest domains are Support – ISO 37001:2025 (11 controls), Operation – ISO 37001:2025 (10 controls), Performance evaluation – ISO 37001:2025 (9 controls). Each control defines specific requirements that organisations must implement to achieve compliance.
If I already comply with another framework, how much of ISO 37001:2025 do I already cover?
ISO 37001:2025 maps to 1 other compliance frameworks. The top mapping partners are ESRS (revised 2026) (2% coverage). Use our comparison tool to explore control-level mappings between frameworks.
How do I implement ISO 37001:2025?
Start your ISO 37001:2025 compliance journey by running a self-assessment on our platform to identify your current compliance posture. Our AI advisory can answer specific questions about ISO 37001:2025 requirements, and cross-framework mapping helps you leverage existing controls from other frameworks you may already comply with. Create a free account to access all 47 controls and track your progress.
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