**1. Introduction: The New Paradigm of Integrated Compliance**

The publication of ISO 37001:2025 marks a crucial milestone in the landscape of anti-corruption prevention tools, signifying the emergence of an approach that transcends traditional procedural concepts. This new paradigm embraces a systemic and cultural outlook on corruption risk, emphasizing not only formal procedures but also the significance of organizational culture. In Italy, this evolution fits within a complex legal context, where the preventive system is structured around various regulations, including Legislative Decree 231/2001 and Law 190/2012 against corruption.

In the Italian legal system, the dialogue between soft law and hard law is enriched by the update of the ISO standard. This standard seeks to balance the need for legal certainty, stemming from formal requirements, with the necessity for an in-depth assessment of the effectiveness of preventive measures.

**2. Main Innovations of ISO 37001:2025**

**2.1 The Integration of the Climate-Environmental Dimension**

One of the standout innovations of ISO 37001:2025 is the incorporation of climate change as a relevant contextual factor in risk assessment within Section 4.1. This development stems from the increasing scientific recognition of the connection between corruption and environmental degradation. Particularly in the Italian context, referencing this dimension becomes crucial, particularly in sectors related to ecological transition and the procurement processes of the National Recovery and Resilience Plan (PNRR).

The integration of this new dimension into anti-corruption management systems necessitates a strengthening of interdisciplinary competencies and the adoption of advanced risk analysis methodologies capable of highlighting the interconnections between different risk areas.

**2.2 The Reconfiguration of Anti-Corruption Culture**

The revision of Section 5.1.3 signifies a significant evolution, with organizational culture transitioning from a peripheral role to one of centrality and strategy within the prevention system. This change coincides with the growing attention of Italian jurisprudence towards the value of corporate culture in evaluating the effectiveness of organizational models.

The shift from a traditional approach based on rigid regulations to value-centered models requires deep reflection on implementation strategies, emphasizing the importance of ethical leadership and an incentive system aligned with the values declared by the organization.

**2.3 The Dynamic Approach to Change Management**

The introduction of Section 6.3, dedicated to “Change Planning,” marks a step forward in the approach to prevention systems. These systems are transforming from static models into a dynamic system capable of adapting to developments and new challenges. This innovation addresses the heterogeneity of corruption risks and the obligation to update organizational models under Legislative Decree 231/2001.

Proactive change management requires the implementation of advanced analysis and planning techniques, moving beyond the traditional reactive logic that characterized past compliance systems.

**3. Systematic Implications for Legislative Decree 231/2001**

**3.1 The Issue of Presumptions of Adequacy**

The update of ISO 37001 reignites the debate on whether the adoption of certified systems can constitute a presumption of the adequacy of the organizational model concerning the defenses provided by Article 6 of Legislative Decree 231/2001. Jurisprudence has shown a range of positions, oscillating between recognizing the significant value of certification and the necessity for concrete analysis that goes beyond mere formal compliance.

The experience of the Environmental Consolidated Law, which introduces presumptions of compliance for models aligned with specific standards, suggests the opportunity to further develop…