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ISO 37001:2025 Key Changes and Guide for Transition

The ISO 37001:2025 update evolves the original 2016 anti-bribery standard by adopting the latest Annex SL Harmonized Approach, enabling seamless integration with other ISO standards. Key deltas include a mandatory focus on digital due diligence, heightened governing body accountability, and ESG alignment. Unlike the 2016 version, the 2025 standard emphasizes a "leadership-driven culture" over mere procedural compliance. For Singapore organizations, this transition requires a shift toward proactive third-party risk management. Organizations typically have a three-year window to transition, starting with a comprehensive gap analysis of their current ABMS.

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Key Transition Highlights

  • Annex SL Alignment: Modernized structure for better "Plug-and-Play" integration with other ISO systems.

  • Board Oversight: Increased requirement for the "Governing Body" to demonstrate active anti-bribery leadership.

  • Digital Integrity: New focus on managing bribery risks within digital transactions and automated procurement.

  • Sustainability Link: Direct ties to the "Governance" pillar of ESG reporting frameworks.

Key Differences Between ISO 37001:2016 and ISO 37001:2025

The 2025 edition introduces significant updates across the structure, terminology, and requirements of the standard. These changes reinforce leadership responsibility, elevate the importance of culture, and align the standard with modern governance practices.

 

1. Culture and Leadership Enhancements (Clause 5)

A major revision in the 2025 edition is the new subclause 5.1.3, which mandates the promotion of an anti-bribery culture across all organizational levels.

  • What’s New: The governing body and management must demonstrate visible, consistent, and sustained commitment to ethical behavior and anti-bribery controls.

  • Why It Matters: The 2016 standard referenced culture contextually; the 2025 version makes this a concrete requirement—highlighting culture as a measurable element of ABMS maturity.

 

2. Role Clarity: ‘Anti-Bribery Function’

The terminology for the oversight role has been refined for simplicity and clarity:

  • 2025 Edition: Uses the term "Anti-bribery function".

  • 2016 Edition: Referred to this as the "Anti-bribery compliance function."

This aligns with broader governance standards and ensures clarity in implementation.

 

3. Integration of Climate Change Considerations (Clause 4)

ISO 37001:2025 introduces climate change as a potential external or internal risk factor:

  • Requirement: Organizations must determine whether climate change is relevant to the effectiveness of their ABMS (Clause 4.1).

  • Implication: Environmental risks tied to bribery (e.g., in procurement or permit acquisition) must be recognized and managed.

 

4. Explicit Emphasis on Conflicts of Interest (Clause 7)

While the 2016 edition provided guidance on conflicts of interest, the new version implements a structured requirement:

  • New Requirement (7.2.2.1 e)): Organizations must ensure all personnel are aware of the need to report actual or potential conflicts of interest.

  • Insight: This mandates procedures and training for conflict disclosure, an essential control for mitigating internal bribery risk.

 

5. Harmonized Structure and Standards References

The 2025 standard adopts the latest Annex SL harmonized structure, aligning with other recently updated ISO management system standards such as:

  • ISO 37000:2021 – Governance of Organizations

  • ISO 37301:2021 – Compliance Management Systems

  • ISO 37002:2021 – Whistleblowing Management Systems

Additionally, the sequence in Clause 10 (Improvement) has been reorganized for logical flow:

  • 2025: 10.1 Continual improvement → 10.2 Nonconformity and corrective action

  • 2016: 10.1 Nonconformity and corrective action → 10.2 Continual improvement

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  • Clause 5.1.3: Mandatory Anti-Bribery Culture.

  • Clause 4.1/4.2: Integration of Climate Action.

  • Annex SL: Shift to Harmonized Structure for easier integration with ISO 9001/45001.​​

What are the 3 Main Changes in  ISO 37001:2025 ?

Frequently Asked Questions: - ISO 37001:2025 Key Changes and Guide for Transition

1. What is the main difference between ISO 37001:2016 and 2025?

The 2025 version places a stronger emphasis on digital due diligence, the role of the 'Governing Body' in fostering an anti-bribery culture, and improved integration with ESG (Environmental, Social, and Governance) frameworks.

 

2. When should Singapore companies transition to ISO 37001:2025?

Companies typically have a 3-year transition period from the date of publication. It is recommended to begin a gap analysis within the first year to ensure compliance with new documentation requirements.

 

3. Does the 2025 update change the Anti-Bribery Management System (ABMS) structure?

Yes, it follows the updated Annex SL high-level structure, making it easier to integrate with other recent standards like ISO 9001 and ISO 45001 while adding specific controls for third-party risk management.

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Conclusion

The transition to ISO 37001:2025 is more than a technical update. It is a shift toward holistic leadership accountability, cultural maturity, and environmental awareness within anti-bribery systems.

Companies must take a strategic approach from compliance to resilience i.e. strengthening internal vigilance, fostering ethical culture, and aligning with global governance expectations.

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Analogy: Transitioning from ISO 37001:2016 to 2025 is like upgrading a security system. The foundation remains, but new threats and vulnerabilities require better tools, smarter controls, and shared responsibility across all levels of the organization.

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Learn how ISOGuruSG supports companies through ISO 37001 consultancy​​

 

For personalized guidance, feel free to contact us directly.

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