ISO 37001:2025

Overview

ISO 37001:2025 - Anti-bribery management systems - Requirements with guidance for use specifies requirements and guidance to establish, implement, maintain, review and continually improve an anti‑bribery management system (ABMS). The standard is applicable to all organizations - public, private or not‑for‑profit - and can be implemented as a stand‑alone system or integrated into an overall management system. ISO 37001:2025 is focused exclusively on bribery (direct and indirect) and helps organizations prevent, detect and respond to bribery while supporting compliance with applicable anti‑bribery laws and voluntary commitments.

Key topics and technical requirements

ISO 37001:2025 organizes requirements across the typical management system lifecycle and includes both mandatory requirements and guidance:

• Context, scope and bribery risk assessment (Clause 4) - understanding organizational context and determining scope based on risk factors.
• Leadership and commitment (Clause 5) - roles for governing bodies, top management and the defined anti‑bribery function, plus fostering an anti‑bribery culture.
• Planning and objectives (Clause 6) - actions to address risks and opportunities and setting measurable anti‑bribery objectives.
• Support (Clause 7) - resources, competence, awareness, communication and documented information controls.
• Operation (Clause 8) - due diligence, financial and non‑financial controls, controls for business associates and controlled organizations, gifts/hospitality/donations, raising concerns and investigations.
• Performance evaluation (Clause 9) - monitoring, internal audit, management review and reviews by the anti‑bribery function.
• Improvement (Clause 10) - continual improvement, nonconformity management and corrective action.
• Annex A provides informative guidance on applying requirements in practice.

Key technical elements include bribery risk assessment, due diligence, financial controls, non‑financial controls, internal audit, and investigative and corrective processes.

Practical applications - who uses it

ISO 37001:2025 is used by:

• Boards, CEOs and senior management to establish governance and tone‑from‑the‑top.
• Compliance, legal and risk teams to design anti‑bribery policies and controls.
• Internal audit and assurance teams for program evaluation.
• Procurement, sales and HR to operationalize due diligence and gifts/hospitality rules.
• Small and medium enterprises, multinational corporations, public agencies and NGOs seeking to demonstrate anti‑corruption commitment to regulators, partners and customers.

Practical uses include implementing an anti‑bribery policy, conducting risk assessments, performing third‑party due diligence, documenting controls, and integrating anti‑bribery measures with existing management systems.

Related standards and compatibility

Prepared by ISO/TC 309 (Governance of organizations), ISO 37001:2025 adopts a harmonized management‑system structure to facilitate integration with other ISO management system standards, enabling cohesive governance, risk and compliance programs.

Keywords: ISO 37001:2025, anti‑bribery management system, anti‑corruption, bribery risk assessment, due diligence, compliance, anti‑bribery policy.