ISO 37001:2025

International

v2025

7 domains

54 controls

Verified

ISO 37001:2025 is a compliance framework from International with 7 domains and 54 controls. The largest domains are Support – ISO 37001:2025 (14 controls), Performance evaluation – ISO 37001:2025 (11 controls), Operation – ISO 37001:2025 (10 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

5 controls

Controls in the Context of the organization – ISO 37001:2025 domain of ISO 37001:2025 — 5 controls
Code	Title	Description
iso-37001-2025::4.1	Understanding the organization and its context	The organization shall determine the external and internal issues relevant to its purpose that affect its ability to ach...
iso-37001-2025::4.2	Understanding the needs and expectations of interested parties	The organization shall determine the interested parties relevant to the anti-bribery management system, their relevant r...
iso-37001-2025::4.3	Determining the scope of the anti-bribery management system	The organization shall determine the boundaries and applicability of the anti-bribery management system to establish its...
iso-37001-2025::4.4	Anti-bribery management system	The organization shall establish, implement, maintain, continually review and, where necessary, improve an anti-bribery...
iso-37001-2025::4.5	Bribery risk assessment	The organization shall carry out regular bribery risk assessments that identify the bribery risks it could reasonably an...

Improvement – ISO 37001:2025

2 controls

Controls in the Improvement – ISO 37001:2025 domain of ISO 37001:2025 — 2 controls
Code	Title	Description
iso-37001-2025::10.1	Continual improvement	The organization shall continually improve the suitability, adequacy and effectiveness of the anti-bribery management sy...
iso-37001-2025::10.2	Nonconformity and corrective action	When a nonconformity occurs, the organization shall react to it, take action to control and correct it and deal with the...

Leadership – ISO 37001:2025

9 controls

Controls in the Leadership – ISO 37001:2025 domain of ISO 37001:2025 — 7 controls
Code	Title	Description
iso-37001-2025::5.1.1	Governing body	Where the organization has a governing body, that body shall demonstrate leadership and commitment by approving the anti...
iso-37001-2025::5.1.2	Top management	Top management shall demonstrate leadership and commitment by ensuring the system is established, implemented, maintaine...
iso-37001-2025::5.1.3	Anti-bribery culture	New in the second edition: the governing body and top management shall develop, maintain and promote an anti-bribery cul...
iso-37001-2025::5.2	Anti-bribery policy	Top management shall establish, maintain and review an anti-bribery policy that prohibits bribery; requires compliance w...
iso-37001-2025::5.3.1	General	Top management shall have overall responsibility for the implementation of and compliance with the anti-bribery manageme...
iso-37001-2025::5.3.2	Anti-bribery function	Top management shall assign to an anti-bribery function the responsibility and authority for overseeing the design and i...
iso-37001-2025::5.3.3	Delegated decision-making	Where top management delegates to personnel the authority to make decisions in relation to which there is more than a lo...

Operation – ISO 37001:2025

10 controls

Controls in the Operation – ISO 37001:2025 domain of ISO 37001:2025 — 10 controls
Code	Title	Description
iso-37001-2025::8.1	Operational planning and control	The organization shall plan, implement, review and control the processes needed to meet the requirements of the anti-bri...
iso-37001-2025::8.10	Investigating and dealing with bribery	The organization shall implement procedures that require assessment and, where appropriate, investigation of any bribery...
iso-37001-2025::8.2	Due diligence	Where the bribery risk assessment has assessed a more than low bribery risk in relation to specific categories of transa...
iso-37001-2025::8.3	Financial controls	The organization shall implement financial controls that manage bribery risk, such as segregation of duties so that the...
iso-37001-2025::8.4	Non-financial controls	The organization shall implement non-financial controls that manage bribery risk in its procurement, commercial, operati...
iso-37001-2025::8.5	Implementation of anti-bribery controls by controlled organizations and by business associates	The organization shall implement procedures requiring that all organizations it controls either implement the organizati...
iso-37001-2025::8.6	Anti-bribery commitments	For business associates that pose more than a low bribery risk, the organization shall implement procedures that require...
iso-37001-2025::8.7	Gifts, hospitality, donations and similar benefits	The organization shall implement procedures designed to prevent the offering, provision or acceptance of gifts, hospital...
iso-37001-2025::8.8	Managing inadequacy of anti-bribery controls	Where due diligence on a specific transaction, project, activity or relationship establishes that the bribery risks cann...
iso-37001-2025::8.9	Raising concerns	The organization shall implement procedures that encourage and enable persons to report in good faith or on the basis of...

Performance evaluation – ISO 37001:2025

11 controls

Controls in the Performance evaluation – ISO 37001:2025 domain of ISO 37001:2025 — 9 controls
Code	Title	Description
iso-37001-2025::9.1	Monitoring, measurement, analysis and evaluation	The organization shall determine what needs to be monitored and measured, who is responsible, the methods needed to ensu...
iso-37001-2025::9.2.1	General	The organization shall conduct internal audits at planned intervals to provide information on whether the anti-bribery m...
iso-37001-2025::9.2.2	Internal audit programme	The organization shall plan, establish, implement and maintain an audit programme or programmes including the frequency,...
iso-37001-2025::9.2.3	Audit procedures, controls and systems	Internal audits shall be reasonable, proportionate and risk-based, and shall include procedures, controls and systems fo...
iso-37001-2025::9.2.4	Objectivity and impartiality	The organization shall ensure that internal auditors are objective and impartial, in particular that they do not audit t...
iso-37001-2025::9.3.1	General	Top management shall review the organization's anti-bribery management system at planned intervals to ensure its continu...
iso-37001-2025::9.3.2	Management review inputs	The management review shall consider the status of actions from previous reviews; changes in external and internal issue...
iso-37001-2025::9.3.3	Management review results	The results of the management review shall include decisions related to continual improvement opportunities and any need...
iso-37001-2025::9.4	Review by anti-bribery function	The anti-bribery function shall assess on a continuing basis whether the anti-bribery management system is adequate to m...

Planning – ISO 37001:2025

3 controls

Controls in the Planning – ISO 37001:2025 domain of ISO 37001:2025 — 3 controls
Code	Title	Description
iso-37001-2025::6.1	Actions to address risks and opportunities	When planning the anti-bribery management system, the organization shall consider the issues of 4.1, the requirements of...
iso-37001-2025::6.2	Anti-bribery objectives and planning to achieve them	The organization shall establish anti-bribery objectives at relevant functions and levels that are consistent with the p...
iso-37001-2025::6.3	Planning of changes	New in the second edition, from the harmonized structure: when the organization determines the need for changes to the a...

Support – ISO 37001:2025

14 controls

Controls in the Support – ISO 37001:2025 domain of ISO 37001:2025 — 11 controls
Code	Title	Description
iso-37001-2025::7.1	Resources	The organization shall determine and provide the resources needed for the establishment, implementation, maintenance, co...
iso-37001-2025::7.2.1	General	The organization shall determine the necessary competence of persons doing work under its control that affects its anti-...
iso-37001-2025::7.2.2	Employment process	For all personnel, the organization shall implement procedures such that conditions of employment require compliance wit...
iso-37001-2025::7.3.1	Awareness of personnel	Personnel shall be aware of the anti-bribery policy, their contribution to the effectiveness of the anti-bribery managem...
iso-37001-2025::7.3.2	Training for personnel	The organization shall provide personnel with adequate and appropriate anti-bribery awareness and training that addresse...
iso-37001-2025::7.3.3	Training for business associates	In relation to business associates that pose more than a low bribery risk, the organization shall implement procedures t...
iso-37001-2025::7.3.4	Awareness and training programmes	The awareness and training programmes shall be periodically updated as necessary to reflect relevant new information, su...
iso-37001-2025::7.4	Communication	The organization shall determine the internal and external communications relevant to the anti-bribery management system...
iso-37001-2025::7.5.1	General	The anti-bribery management system shall include the documented information required by the standard and the documented...
iso-37001-2025::7.5.2	Creating and updating documented information	When creating and updating documented information the organization shall ensure appropriate identification and descripti...
iso-37001-2025::7.5.3	Control of documented information	Documented information required by the system and by the standard shall be controlled so that it is available and suitab...

What is ISO 37001:2025 and who does it apply to?

ISO 37001:2025 is a compliance framework from International with 7 domains and 54 controls. 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 54 controls organised across 7 domains. The largest domains are Support – ISO 37001:2025 (14 controls), Performance evaluation – ISO 37001:2025 (11 controls), Operation – ISO 37001:2025 (10 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 does not currently have cross-framework mappings in our system. Check back as we continuously expand our mapping database.

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 54 controls and track your progress.

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