Framework overlap

Does ISO 37001 cover ISO 37001:2016?

You hold ISO 37001 and have been told to do ISO 37001:2016. Here is how much overlaps, control by control.

54% of ISO 37001:2016 you already have

ISO 37001 already covers about 54% of ISO 37001:2016, leaving 18 of 39 controls as genuinely new work.

Already covered 17 Likely covered 4 New work 18

What is genuinely new work

Nothing in ISO 37001 reaches these. This is the list to scope.

4.2
Understanding the needs and expectations of stakeholders
4.3
Determining the scope of the anti-bribery management system
4.4
Anti-bribery management system
5.1
Leadership and commitment
5.3.1
Roles and responsibilities
6.1
Actions to address risks and opportunities
6.2
Anti-bribery objectives andISO planning
7.2
Competence
7.2.2
Employment process
7.3
Awareness and training
7.4
Communication
7.5
Documented information
7.5.2
Creating and updating
7.5.3
Control of documented information
8.7
Gifts, hospitality, donations and similar benefits
8.8
Managing inadequacy of anti-bribery controls
9.2
Internal audit
9.3.1
Top management review
Show the 21 you already have
10.1
Nonconformity and corrective action
4.1
Understanding the organization and its context
4.5
Bribery risk assessment
5.1.1
Governing body
5.1.2
Top management
5.2
Anti-bribery policy
5.3
Organizational roles, responsibilities and authorities
5.3.2
Anti-bribery compliance function
8.1
Operational planning and control
8.10
Investigating and dealing with bribery
8.3
Financial controls
8.4
Non-financial controls
8.6
Anti-bribery commitments
8.9
Raising concerns
9.1
Monitoring, measurement, analysis and evaluation
9.3
Management review
9.4
Review by anti-bribery compliance function
10.2
Continual improvement
8.2
Due diligence
8.5
Implementation of anti-bribery controls by controlled organizations and by
9.3.2
Governing body review

How this is calculated

Already covered means a mapping runs from a control in ISO 37001 to that control. Likely covered means no direct mapping exists but both frameworks map to the same control in a third standard. New work means neither. We keep those separate rather than adding them into one friendlier number, because blending them would present a two-hop inference as a verified fact.

Coverage is not symmetric. Run it the other way and you will get a different number; both are correct.

From 332,959 cross-framework control mappings across 723 frameworks, 531 of them verified against their source documents. It does not tell you that you are compliant: a mapped control means the two standards ask for the same thing, not that you have done it.

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