TLDR
ISO 9001:2026 competence Clause 7.2 updates the requirements for ensuring that personnel are competent to perform quality-affecting work. ISO 9001 2026 training requirements now include awareness of quality culture and ethical behaviour. The ISO 9001 2026 competence framework requires organizations to determine competence needs, ensure competence through training or other means, and retain evidence.
ISO 9001:2026 Clause 7.2 on competence is unchanged in its wording but significantly expanded in its practical scope. The new quality culture requirement (Clause 5.1.1) means that competence now includes behavioural and cultural competencies — not just technical skills. The new climate change requirement (Clause 4.1) means that relevant staff may need awareness training on environmental risks. And the enhanced risk management requirement (Clause 6.1) means that risk assessment competence is now an explicit expectation for key roles. This article explains what Clause 7.2 requires, how it connects to the new requirements, and how to build a competence framework that will satisfy ISO 9001:2026 auditors.
What Clause 7.2 Actually Requires
Clause 7.2 of ISO 9001:2026 requires organizations to: determine the necessary competence of persons doing work that affects the performance and effectiveness of the QMS; ensure those persons are competent on the basis of appropriate education, training, or experience; where applicable, take actions to acquire the necessary competence and evaluate the effectiveness of those actions; and retain documented information as evidence of competence.
The clause is deceptively simple. In practice, it requires four things that many organizations do poorly:
A defined competence matrix. Organizations must be able to articulate what competencies are required for each role that affects QMS performance. This is not a job description — it is a specific list of knowledge, skills, and behaviours required to perform quality-related tasks effectively.
A gap assessment process. For each person in a relevant role, the organization must assess their current competence against the required competence and identify gaps. This assessment must be documented.
A training and development plan. Where gaps exist, the organization must take action to close them. This can include formal training, mentoring, job rotation, or other development activities.
Effectiveness evaluation. After training or development, the organization must verify that the person has achieved the required competence. A training attendance record is not evidence of competence — it is evidence of attendance.
Key Insight
The Most Common Clause 7.2 Nonconformity: Across thousands of ISO 9001 audits, the most frequently cited Clause 7.2 finding is the absence of effectiveness evaluation. Organizations maintain training records but cannot demonstrate that training resulted in competence. The standard is explicit: "evaluate the effectiveness of the actions taken." A post-training test, a supervised task observation, or a 90-day performance review are all acceptable methods. A signature on a training register is not.
ISO 9001:2026 Competence Clause 7.2: Training Requirements
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How the Three New Requirements Expand Clause 7.2
The three new requirements in ISO 9001:2026 expand the scope of competence in ways that organizations must address before their transition audit.
Climate Change Awareness (Clause 4.1 → Clause 7.2)
If an organization's Clause 4.1 analysis identifies climate change as a relevant external issue, then relevant personnel need to be aware of how climate-related risks affect the organization's operations and quality objectives. This does not require specialist environmental training — it requires that key staff understand the organization's climate risk assessment and their role in responding to it.
For example, a manufacturing organization that identifies supply chain disruption from extreme weather as a climate risk should ensure that procurement staff are aware of this risk and understand the organization's mitigation strategy (e.g., approved supplier lists, buffer stock policies, alternative sourcing procedures).
Quality Culture Competencies (Clause 5.1.1 → Clause 7.2)
The new Clause 5.1.1 requirement for top management to promote quality culture and ethical behaviour has a direct implication for Clause 7.2: behavioural competencies related to quality culture are now within scope. This includes:
- Understanding of the organization's quality policy and its personal relevance
- Commitment to reporting nonconformities and near-misses without fear of blame
- Awareness of ethical behaviour expectations in quality-related decisions
- Understanding of how individual work contributes to customer satisfaction
These competencies are harder to measure than technical skills, but they are measurable. Employee surveys, 360-degree feedback, and behavioural observation during audits are all valid assessment methods.
Risk Assessment Competence (Clause 6.1 → Clause 7.2)
The enhanced Clause 6.1 requirement for documented strategic risk management means that persons involved in risk assessment and risk register maintenance must be competent to perform these activities. Auditors will look for evidence that the people responsible for risk management have the knowledge and skills to identify, assess, and respond to quality-related risks at a strategic level.
This is a new expectation for many organizations that previously treated risk management as a compliance exercise rather than a strategic capability.
Building a Competence Framework for ISO 9001:2026
A competence framework that satisfies ISO 9001:2026 Clause 7.2 has four components:
1. Role-based competence profiles. For each role that affects QMS performance, define the required competencies. Include technical competencies (specific knowledge and skills), process competencies (ability to perform specific QMS processes), and behavioural competencies (quality culture, ethical behaviour, risk awareness).
2. Individual competence assessments. For each person in a relevant role, assess their current competence against the required profile. Document the assessment method (test, observation, portfolio review, supervisor assessment) and the result (competent / development needed / not yet assessed).
3. Development plans. For each identified gap, document the planned development action, the responsible person, the target date, and the expected outcome. Link development plans to the organization's training budget and resource plan.
4. Effectiveness records. After each development action, document the effectiveness evaluation method and result. Update the competence assessment to reflect the new competence level.
| Competence Component | ISO 9001:2026 Reference | Evidence Required |
|---|---|---|
| Technical skills | 7.2(a) | Job-specific training records, certifications |
| QMS process knowledge | 7.2(b) | Competence assessments, process audits |
| Quality culture behaviours | 5.1.1, 7.2 | Culture surveys, behavioural observations |
| Climate risk awareness | 4.1, 7.2 | Awareness training records, assessment results |
| Risk assessment competence | 6.1, 7.2 | Risk management training, risk register quality |
| Training effectiveness | 7.2(d) | Post-training assessments, performance observations |
Documented Information Requirements for Clause 7.2
Clause 7.2 explicitly requires documented information as evidence of competence. The minimum documentation set for a compliant Clause 7.2 implementation includes:
- Competence matrix — roles vs. required competencies, showing current status for each person
- Training records — for each training activity: who attended, what was covered, when, and who delivered it
- Effectiveness evaluations — for each training activity: the evaluation method, the result, and the conclusion (competence achieved / not yet achieved / further development needed)
- Development plans — for each identified competence gap: the planned action, owner, target date, and status
Organizations that maintain these four document types will have no difficulty demonstrating Clause 7.2 compliance in a transition audit.
Key Insight
Template: Competence Assessment Record: Role: _______________ | Person: _______________ | Date: _______________ | Competency | Required Level | Current Level | Gap | Development Action | Target Date | Effectiveness Verified | |---|---|---|---|---|---|---| | [Technical skill] | Expert | Intermediate | Yes | Mentoring | Q1 2027 | □ | | [QMS process] | Proficient | Proficient | No | — | — | N/A | | [Quality culture] | Demonstrated | Developing | Yes | Coaching | Q2 2027 | □ | Assessed by: _______________ | Next review date: _______________
Key Resources
- ISO 9001:2026 Transition GuideISO 9001:2026 Transition Guide/article/how-to-transition-iso-9001-2015-to-2026 — complete transition methodology
- ISO 9001:2026 Quality Culture Clause 5.1.1ISO 9001:2026 Quality Culture Clause 5.1.1/article/iso-9001-2026-quality-culture-ethical-behaviour-clause-5-1-1 — the new quality culture requirement and its implications
- ISO 9001:2026 Risk Management Clause 6.1ISO 9001:2026 Risk Management Clause 6.1/article/iso-9001-2026-risk-management-clause-6-1 — risk assessment competence requirements
- ISO 9001:2026 Internal Audit ProgrammeISO 9001:2026 Internal Audit Programme/article/iso-9001-2026-internal-audit-programme-changes — auditor competence requirements
- Free Gap Analysis TemplateFree Gap Analysis Template/resources/gap-analysis-template — includes Clause 7.2 compliance assessment
- Free Transition ChecklistFree Transition Checklist/resources/transition-checklist — covers all competence-related transition requirements
- ISO.org — ISO 9001:2026 StandardISO.org — ISO 9001:2026 Standardhttps://www.iso.org/standard/62085.html — official standard
- CQI/IRCA — Lead Auditor TrainingCQI/IRCA — Lead Auditor Traininghttps://www.quality.org/qualifications/irca — professional auditor competence certification
FAQ
Does ISO 9001:2026 change the wording of Clause 7.2?
No. The text of Clause 7.2 is identical to ISO 9001:2015. However, the scope of competence has expanded because of the three new requirements — climate change (4.1), quality culture (5.1.1), and strategic risk (6.1) — which create new competence requirements for relevant roles.
Do all employees need competence assessments under Clause 7.2?
No. Clause 7.2 applies to "persons doing work under the organization's control that affects the performance and effectiveness of the quality management system." This includes direct production and service delivery staff, quality management personnel, internal auditors, and management — but not necessarily all employees. The organization must determine which roles affect QMS performance.
What counts as evidence of competence under ISO 9001:2026?
Evidence of competence can include: educational qualifications and certificates, training records with effectiveness evaluations, professional certifications (e.g., CQI/IRCA Lead Auditor), supervisor competence assessments, portfolio of work demonstrating skills, and records of satisfactory performance in relevant tasks. Training attendance records alone are not sufficient — they demonstrate attendance, not competence.
How should organizations handle competence for the new climate change requirement?
Organizations should first complete their Clause 4.1 analysis to determine whether climate change is a relevant external issue. If it is, they should identify which roles need awareness of climate-related risks and document this in their competence matrix. Awareness training (not specialist environmental training) is typically sufficient for most roles.
What is the minimum documentation required for Clause 7.2 compliance?
The standard requires "documented information as evidence of competence." At minimum, this means: a record of what competencies are required for each relevant role, a record of each person's current competence level, records of training and development activities, and records of effectiveness evaluations. The format is not prescribed — a spreadsheet competence matrix with supporting training records is sufficient.