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ISO 14001Compliance evaluation

Compliance evaluation under ISO 14001

An up-to-date register of environmental obligations tells you which rules and agreements apply to you. A compliance evaluation answers the next question: do we do in practice what is asked of us? ISO 14001:2026 covers this evaluation under 9.1.2. The official ISO 14001:2026 page  describes the environmental management system, and legislation and compliance helps you determine your obligations. Also use the ISO 14001 audit page to organise your evidence for an audit.

So evaluating compliance does not mean writing a new legal register. For each relevant obligation, you check which standard, permit condition, contract term or voluntary commitment applies, what evidence goes with it, and what you do if the outcome is unclear or negative. An obligation can be legal, but it can also come from a client agreement or a voluntary commitment.

1. Define the scope of the evaluation

For each assessment round, make a short plan. Note the location, activities, obligations, the person responsible, the period and the assessment method. Use the information from the Rijksoverheid (Dutch central government) on environmental rules and permits  as a starting point for the Dutch context. Always check which rules apply to your activity and location.

Choose the frequency based on risk and change. A permit condition that requires monthly emission measurements needs a different rhythm from an annual check of training records. A change in an installation, raw material, permit or legislation can be a reason for an interim check.

ElementQuestion for the plan
ObligationWhat must the organisation do or demonstrate?
EvidenceWhich measurement, record, notification or inspection shows compliance?
MethodDocument review, interview, walk-through, measurement or a combination?
OwnerWho can explain the source and take action?
TimingWhich frequency fits the risk and validity?

2. Test practice against the obligation

A good evaluation combines sources of evidence. Read the permit condition, review the records and talk to the person who carries out the activity. Where relevant, check whether measuring equipment is suitable and maintained, whether waste streams are recorded correctly, and whether notifications or reports were submitted on time.

For each obligation, record what you assessed. Avoid a conclusion such as “compliant” without a reference to the source, period and sample. For a sample, note which files, measurement values or locations you reviewed and why that choice was appropriate.

Example (fictional): metal processor Metaalstroom links a permit condition for wastewater to monthly measurement data and a quarterly check of the records. In June, a signed inspection form is missing, although the measurement value is available. The evaluator marks the evidence as incomplete, asks for the cause and plans a follow-up check. The outcome is therefore more than a green tick.

3. Assess and record the outcome

Use a simple status with an explanation, for example “compliant”, “partially compliant”, “not demonstrated” or “not applicable with reason”. Separate a missing piece of evidence from a substantive breach. Both require follow-up, but the measure differs.

ObligationEvidence and periodOutcomeActionFollow-up check
Measuring wastewaterReport June, sampling point ACompliantNoneSeptember
Waste recordingQ2 records, form missingNot demonstratedRepair the recording processNext quarter
Disposal of hazardous wasteConsignment notes MayPartially compliantRequest the missing documentsWithin 30 days

If you find a deviation, first investigate the cause. Is the instruction unclear, is the task not assigned, is the source unreliable, or has the way the work is done changed? Then record the owner, deadline, interim control and effectiveness check. An incident or deviation can also affect your environmental aspects, objectives and emergency scenarios.

4. Use the outcome in the management review

Report trends and open actions to management. Not every small administrative error is a serious environmental problem. However, recurring missing records can show that your process is not under control. Therefore, link the evaluation to environmental objectives, the internal audit and improvement actions.

A compliance evaluation is not legal advice. If you are unsure about whether a rule applies or how to interpret it, ask a qualified environmental specialist or the competent authority (bevoegd gezag, the body that issues permits and enforces the rules) for advice.

Frequently asked questions

Do you have to read all environmental legislation every year?

No. You must control relevant changes and obligations, and check periodically whether you comply with them. Base the frequency and method on risk, activity and how often things change.

Is a compliance register the same as a compliance evaluation?

No. The register describes which obligations apply. The evaluation checks with evidence whether you comply, and records the follow-up.

What do you do if no evidence is available?

Record “not demonstrated”, investigate why, and decide whether the activity itself needs to be checked again. Then repair the record or control measure and plan an effectiveness check.

Sources