Planning of changes under ISO 9001:2026 (6.3): the seven considerations, with the transition itself as the worked example

Written from the ISO 9001:2026 standard (sixth edition, published 16 September 2026). Reviewed by Kaushal Sutaria, Lead Auditor, Sterling International Consulting.

Clause 6.3 of ISO 9001:2026 requires an organisation that decides its quality management system must change to plan the change against seven considerations, a) to g): purpose and consequences; integrity of the system; resources and information; responsibilities and authorities; communication; monitoring and evaluation of effectiveness; and review of results. Items e), f) and g) are new in the 2026 edition, and c) now includes information. No form or procedure is prescribed. The quickest way to learn the clause is to apply it to the change every certified Philippine company now faces: the transition itself.

What does clause 6.3 of ISO 9001:2026 require?

The trigger is unchanged from 2015: once the organisation determines that the QMS needs to change, the change is carried out in a planned way. The list of considerations has grown from four to seven. The clause does not demand a document; the auditor tests whether the considerations were made before the work started and whether what happened matches them.

Letter	What the plan must consider (paraphrased)	2026 status
a)	Why the change is made and what it could cause, intended or not	Carried over
b)	Keeping the QMS whole and working while the change is made	Carried over
c)	Whether resources are available, and now whether information is too	Strengthened: information added
d)	Who is responsible and who has authority, allocated or re-allocated	Carried over
e)	How the change is communicated	New
f)	How the effectiveness of the change is monitored and evaluated	New
g)	How the results of the change are reviewed	New

The three new items close the loop a 2015-era plan could leave open at “who does it”; the 2015 to 2026 change register places 6.3 among the other changes.

How do you work through 6.3 a) to g) without a template?

Answer each consideration in one to three sentences before the change starts, in whatever record you already use: a management review minute, a project brief, a change request in Effivity, an approved email. The auditor wants not a form but seven answers that exist, were made in advance and can be traced to what was done.

a) Purpose and consequences. State the purpose in one line, then what the change could break or provoke for customers, neighbouring processes, suppliers, people and records. A purpose with no consequences has not been thought through.

b) Integrity of the QMS. Name what must keep working while the change runs, and how old and new versions will be controlled side by side. Clause 5.3 already has top management assign responsibility for keeping the system intact through changes; 6.3 b) is where those arrangements appear.

c) Resources and information. People-hours, money, equipment, software and external help, and now the information the change depends on: data, documents and the organisational knowledge that 7.1.6 expects to be retained, applied and shared. Resources without the information is the most frequent gap we see.

d) Responsibilities and authorities. Who leads, who decides, who does the work and who verifies it, including any decision that moves from one role to another.

e) Communication. Who needs to know, what, when and through which channel, using the communication decisions already made under 7.4 and awareness under 7.3, including the new 7.3 e) on quality culture and ethical behaviour.

f) Monitoring and evaluation of effectiveness. Decide before the change what “it worked” will look like, how it will be measured and when. This is the item 2015-era change records most often lack.

g) Review of results. Decide who reviews the outcome, where (usually management review under 9.3) and what closes the change.

Why is the ISO 9001:2026 transition itself a change under 6.3?

Moving the system to the 2026 standard alters processes, registers, responsibilities and the audit criteria: exactly the clause’s trigger. The certification body’s transition audit looks at three things: which requirements of ISO 9001:2026 changed, how the organisation’s context has moved, and whether the system needs any further change as a result. A transition without a 6.3 plan is a nonconformity in the very clause meant to govern it.

The dates are fixed. Global ACI-TECH-3-TR 2029-09-30 (M), version 1.0, was issued on 4 September 2026; Global ACI released it on 16 September 2026, the same day ISO brought out the standard. The three-year transition ends on 30 September 2029; ISO 9001:2015 certificates are no longer valid after that date. Accreditation bodies are to be ready for assessing certification bodies against the 2026 edition by 31 March 2027, certification-body declarations are due by 30 June 2027, accreditation decisions are completed by 30 September 2027, and from 31 March 2028 new certifications are issued only to the 2026 edition. As for the audit itself: the certification body can fold it into a scheduled surveillance or recertification visit or run it as a special transition audit; ICT allows it to be conducted remotely; and any additional audit time must rest on a calculation justified under ISO/IEC 17021-1. Each point belongs in a), c), d) or e) of the plan.

Worked example: planning the transition against 6.3 a) to g)

The example is illustrative: a single-site packaging manufacturer in Laguna, 180 staff, certified to ISO 9001:2015, surveillance audit due in the third quarter of 2027, recertification in 2028. Its 6.3 record fits on two pages. Yours will differ in detail, not in structure; the free ISO 9001:2026 gap check shows where yours starts.

Consideration	What the plan records for this company
a) Purpose and consequences	Purpose: an accredited certificate valid after 30 September 2029, and three weaknesses closed that the 2026 standard tests directly: risks and opportunities in one list; changes never measured for effectiveness; no management review input on shifting interested-party expectations. If not done: the certificate lapses and customers that require one are lost. If done: about three days per process owner; one extra internal audit; awareness time for 180 staff; possibly more audit time at the transition audit.
b) Integrity of the QMS	The 2015-based system stays in force until the revised documentation is approved on one switch-over date; no floor-level process changes before then. The rebuilt risk and opportunity register is prepared in parallel and replaces the old one at switch-over. Operational controls continue unchanged; the planned 2015-based internal audit stays and one against the 2026 standard is added.
c) Resources and information	Resources: a licensed copy of ISO 9001:2026; the certification body’s transition instructions; about 40 person-days internally; the Sterling Revise™ engagement; Effivity for document control and the register. Information: the gap report; the 2015 to 2026 clause register; the last two audit reports; the complaint log; the context analysis, including the 4.1 determination of whether climate change is relevant.
d) Responsibilities and authorities	General manager: sponsor; approves the resources and the revised quality policy, which under 5.2.1 e) must take context into account and support strategic direction. Quality manager: project lead and certification-body liaison. Process owners: revise their process documentation and risk and opportunity entries. HR manager: awareness, including 7.3 e). Internal auditors: audit against the 2026 standard. Production manager: newly assigned under 5.3 e) to report on opportunities for improvement. Sterling (Mark Santos, Metro Manila): gap assessment, gap report, documentation updates, pre-assessment.
e) Communication	Week 1: management team briefed on purpose, dates and workload. Week 3: every shift told what changes and what does not (no new forms for operators). Monthly: progress on the notice board. Certification body: transition audit requested in writing for the Q3 2027 surveillance visit, with audit time and any remote element confirmed. Suppliers and customers: nothing needed, recorded as considered.
f) Monitoring and evaluation of effectiveness	Milestones: gap report; documentation approved; register rebuilt; awareness delivered; internal audit against the 2026 standard completed and findings closed; management review; transition audit. Measures: internal audit findings against the changed requirements; twenty staff sampled on three awareness questions; management review confirming separate evaluation of the effectiveness of actions on risks and on opportunities (9.1.3 e) and f)); the transition audit outcome.
g) Review of results	Management review after the internal audit and again after the transition audit, with inputs including changes in interested-party needs and expectations (9.3.2 c)) and the effectiveness of actions on risks (9.3.2 g)) and on opportunities (9.3.2 h)). Outputs: formal closure, residual actions with owners and dates, lessons for the ISO 14001:2026 transition, which ends on 30 April 2029.

What evidence does the auditor expect for 6.3?

Clause 6.3 names no mandatory record, and the 2026 edition adds no new documents or records: where the 2015 edition used “maintain” or “retain”, the 2026 edition says documented information shall be available, as Annex A.2 e) explains. Seven considerations cannot be verified from memory, so the auditor asks for the plan in whatever form it exists and tests it against events.

Consideration	Evidence that satisfies an auditor	Common finding
a)	A change record or minute stating purpose and expected consequences	Purpose stated; consequences blank
b)	A switch-over date, version control, interim controls	Two versions of a document in use at once
c)	A resource list that also names the information relied on	Information never identified
d)	Named roles in the plan, consistent with the 5.3 assignments	Everything assigned to the quality manager
e)	Briefing records, notices, correspondence with the certification body	Operators unaware a change is under way
f)	Measures defined before the change; monitoring results afterwards	No measure defined until the auditor asked
g)	Management review minutes recording a decision on the change	Change never formally closed

Have the documentation updated once, correctly

Sterling Revise™ packages the transition into four fixed-scope weeks: the documentation review and gap assessment against the ISO 9001:2026 standard in week 1; the gap report, with the number, in week 2, before you commit to anything; then, in weeks 3 and 4, the plan, the booking with your certification body and the first updates. The week 3 plan is written as a 6.3 record, and the documentation updates are made by local Filipino lead auditors inside your existing document control. Sterling does not certify. Start with the Sterling Revise™ transition service.

Frequently asked questions

Does ISO 9001:2026 require a documented change management procedure? No. Clause 6.3 requires changes to the QMS to be planned against seven considerations; it does not require a procedure, a form or a register, and the 2026 edition adds no mandatory documents. The auditor will still ask how the considerations were made, so most organisations keep a short change record.

What is new in 6.3 compared with ISO 9001:2015? Three considerations are added: e) how the change is communicated, f) how its effectiveness is monitored and evaluated, and g) how its results are reviewed. Item c) is strengthened to cover information as well as resources. Items a), b) and d) carry over; the list runs a) to g) instead of a) to d).

How does 6.3 relate to 6.1.2 and 6.1.3? Clause 6.1.2 has risks determined, analysed and evaluated, and expects the action on each to be proportionate to the impact it could have on the intended results of the QMS; 6.1.3 treats opportunities the same way but separately, with actions appropriate to the organisation’s context. The consequences considered under 6.3 a) usually create entries for both.

Can we keep using our existing change request form? Usually, with three fields added: the communication plan, the effectiveness measure and the review point. Check that it captures the information needed, not only people and money, because 6.3 c) now asks for both. In Effivity or similar software the additions are a configuration change.

When does the transition to ISO 9001:2026 have to be completed? By 30 September 2029, the end of the three-year transition period set in Global ACI-TECH-3-TR 2029-09-30 (M); ISO 9001:2015 certificates are no longer valid after that date. New certifications are issued only to the 2026 edition from 31 March 2028, and accredited 2026 certificates become available during 2027.

We changed our system last year without a written plan. Is that a nonconformity now? Not retrospectively, but the next change is audited against the 2026 standard once your transition audit is done, and an auditor may ask how last year’s change was reviewed. Record what was considered and measured, close the change through management review, and plan the next one against a) to g).

Read next

The ISO 9001:2026 migration plan puts the twelve steps in date order; the risk register page covers 6.1.2 and 6.1.3; the transition audit page covers what your certification body will review; the internal audit page covers auditing the change first; Sterling OS™ is the delivery method; and the clause-level detail is in the planning of changes guide.

Sources

• ISO 9001:2026, Quality management systems — Requirements, sixth edition, published 16 September 2026 (ISO/TC 176/SC 2 with CEN): 4.1, 5.1.1, 5.2.1 e), 5.3 e), 6.1.2, 6.1.3, 6.3 a) to g), 7.1.6, 7.3 e), 7.4, 9.1.3 e), f), 9.3, 9.3.2 c), g), h), Annex A.2 e). https://www.iso.org/standard/9001
• ISO 9001:2015, clause 6.3 a) to d) (comparison).
• Global ACI-TECH-3-TR 2029-09-30 (M), Transition Requirements for ISO 9001:2026, version 1.0, issued 4 September 2026, published 16 September 2026.
• Global ACI-TECH-3-TR 2029-04-30 (M), ISO 14001:2026 transition requirements (ends 30 April 2029).
• ISO/IEC 17021-1 (certification-body audit time).
• No Philippine regulatory fact is stated on this page.