ISO 37001 was revised in February 2025 and the 2016 edition, along with its 2024 amendment, was withdrawn. This ISO 37001 2025 ABMS pack is written to the second edition throughout. 55 editable Word documents, downloadable the moment you check out. On this page:
- What is in the ISO 37001 2025 ABMS pack
- The second edition replaced the 2016 original in February 2025
- Who needs ISO 37001 2025 ABMS
- How the documents map to the framework
- Frequently asked questions
- Related toolkits
What is in the ISO 37001 2025 ABMS pack
Documents carry GDL-ISO37K reference codes and follow the clause structure:
- Context – the ABMS scope and boundaries document, context analysis and interested parties register, internal and external issues procedure
- Bribery risk assessment – the methodology and procedure, and the bribery risk register, which is the document that justifies the proportionality of everything else
- Leadership – the anti-bribery policy, governing body and top management responsibilities, and the anti-bribery compliance function with its required independence and authority
- Planning – objectives, planning to achieve them and the treatment of identified bribery risks
- Support – competence, employment processes including screening, awareness and training, communication, and documented information control
- Operation – due diligence on transactions, projects, business associates and personnel; financial and non-financial controls; the gifts, hospitality, donations and similar benefits policy and register; and the control of business associates including the flow-down of anti-bribery requirements
- Raising concerns – the whistleblowing and concern-raising procedure and the protection from retaliation position
- Investigation – the investigating and dealing with bribery procedure
- Performance – monitoring, internal audit, management review by both top management and the governing body, and review by the compliance function
- Improvement – nonconformity and corrective action procedure and register, and continual improvement
The second edition replaced the 2016 original in February 2025
ISO 37001:2025 was published in February 2025 as the second edition. The 2016 first edition was withdrawn, as was Amendment 1:2024 which had added consideration of climate change to it.
Documentation written to the 2016 edition is therefore superseded. For a standard whose purpose is to demonstrate a good-faith anti-bribery programme to prosecutors, regulators and business partners, running on a withdrawn edition is a poor look – the whole value of certification here is the credibility it lends.
The core architecture is unchanged: a bribery risk assessment drives proportionate controls, an independent compliance function oversees them, and due diligence is applied to transactions, projects and business associates according to risk. An ISO 37001 2025 ABMS is a refinement of that model rather than a rebuild.
Who needs ISO 37001 2025 ABMS
Organisations operating in sectors or jurisdictions with elevated bribery risk – construction, extractives, defence, pharmaceuticals, infrastructure and anywhere involving public procurement or agents. Companies subject to the UK Bribery Act, the US Foreign Corrupt Practices Act or equivalent, where a certified programme evidences adequate procedures. Organisations required by a customer or a tender to hold certification. And those rebuilding after an incident.
How the ISO 37001 2025 ABMS maps to the framework
The bribery risk assessment is load-bearing in a way it is not in other management systems. ISO 37001 explicitly requires controls to be proportionate to assessed risk, which means an organisation that applies identical due diligence to every counterparty has not implemented the standard – it has bypassed it. The methodology here forces risk differentiation and records the reasoning.
Frequently asked questions
Which edition is this written to?
ISO 37001:2025, the second edition published in February 2025. The 2016 edition and its 2024 amendment were both withdrawn.
Does certification protect us legally?
No certification prevents prosecution. It can evidence that adequate procedures were in place, which is relevant under the UK Bribery Act and similar regimes, but it is evidence rather than a defence in itself.
Does the compliance function have to be independent?
The standard requires it to have appropriate authority and independence, with direct access to the governing body. How that is structured is proportionate to the organisation, and the role documents cover the options.
Is whistleblowing included?
Yes – concern raising, protection from retaliation, and the investigation procedure that follows a report.
How many documents are included?
55 editable Word documents, plus guidance and a licence file.
Related toolkits
Anti-bribery sits within a wider compliance and governance picture. See the ISO 37301 Toolkit for the compliance management system above it, the COSO Toolkit for internal control, the SOX Toolkit for financial reporting controls and the ISO 31000 Toolkit for enterprise risk.
Implementing for clients? The Consultant Package licenses all 86 toolkits and assessment tools on this site for unlimited client engagements, under one firm-wide licence. One payment of $1,399, no subscription and no per-client fee.
Delivery, format and licence
Your ISO 37001 2025 ABMS downloads immediately after checkout as native Microsoft Word and Excel files. Nothing is watermarked or locked, so you can rebrand the documents, bring them under your own document control and revise them for as long as you need them.
One-time purchase. No subscription and no annual renewal. Because the source files behind the ISO 37001 2025 ABMS are yours, revising a procedure after an audit finding or a change of scope is an internal edit rather than another purchase.
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