Framework overlap

Does ISO 37301:2021 cover ISO 37001:2016?

You hold ISO 37301:2021 and have been told to do ISO 37001:2016. Here is how much overlaps, control by control.

90% of ISO 37001:2016 you already have

ISO 37301:2021 already covers about 90% of ISO 37001:2016, leaving 4 of 39 controls as genuinely new work.

Already covered 32 Likely covered 3 New work 4

What is genuinely new work

Nothing in ISO 37301:2021 reaches these. This is the list to scope.

8.5
Implementation of anti-bribery controls by controlled organizations and by
8.6
Anti-bribery commitments
8.7
Gifts, hospitality, donations and similar benefits
9.4
Review by anti-bribery compliance function
Show the 35 you already have
10.1
Nonconformity and corrective action
10.2
Continual improvement
4.1
Understanding the organization and its context
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
4.5
Bribery risk assessment
5.1
Leadership and commitment
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
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
8.1
Operational planning and control
8.2
Due diligence
8.3
Financial controls
8.4
Non-financial controls
8.9
Raising concerns
9.1
Monitoring, measurement, analysis and evaluation
9.2
Internal audit
9.3
Management review
9.3.1
Top management review
9.3.2
Governing body review
5.3.1
Roles and responsibilities
8.10
Investigating and dealing with bribery
8.8
Managing inadequacy of anti-bribery controls

How this is calculated

Already covered means a mapping runs from a control in ISO 37301:2021 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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