Environmental compliance management system (ECMS)

Your expert for questions

Daniela Hanauer ist Ihre Expertin für ECMS bei PwC Deutschland

Daniela Hanauer
Partner, Risk Consulting at PwC Germany

A holistic approach to compliance and governance for sustainable corporate management

Environmental management has long been an integral part of sustainable corporate management. A good way to handle environmental issues effectively is to implement an Environmental Compliance Management System (ECMS).

An ECMS is one governance system combining requirements for an environmental management system (EMS) – for instance according to ISO 14001 or EU EMAS – with requirements for a compliance management system (CMS) – such as ISO 26000 or IDW PS 980. Thus, an ECMS enables companies to establish a holistic governance approach for sustainable corporate management.

PwC experts have been supporting companies on their journeys to environmental compliance for almost 30 years. They combine environmental expertise with the success factors of traditional compliance management.

Is environmental compliance under control in your company?

Do you want to know whether your organisation is legally robust and secure when it comes to the environment? The following questions will help:

  • Are environmental risks adequately and systematically accounted for in your corporate strategy?
  • Are environmental concerns part of your corporate values?
  • Have you formulated environmental goals and/or an environmental policy?
  • Are you familiar with the environmental obligations – both legal and voluntary – that your company has committed to?
  • Have you identified, recorded and analysed the main environmental risks for your business model and operations?
  • Do you develop environmental compliance measures based on risk profiles?
  • Does your definition of environmental compliance cover the full life cycle of your products and services?
  • Is your environmental compliance organisation set up in line with the Three Lines of Defence model?
  • Have you defined clear environmental compliance roles, responsibilities and authorities in a way that is legally robust and secure?
  • Do you have any target group-specific training courses on environmental compliance?
  • Do you have regular, independent audits of the effectiveness of your measures for compliance with environmental obligations?

Big differences in ECMS maturity levels

The maturity of Environmental Compliance Management Systems still varies widely between companies. Some companies are only just beginning to deal with the risks that corporate externalities can create in the environment. These companies may well be trying to protect the environment and implement legal requirements in their operations, but they don’t carry out risk-oriented and systematic monitoring of their compliance measures. They lack plans, guidelines, structures, solutions or processes to address risks efficiently and effectively. 

Other companies have met certain minimum standards and formulated guidelines together with an implementation plan. They systematically address environmental risks in their business models and operations through defined structures and processes. A company is considered mature if it has implemented and formalised risk minimization measures and established guidelines, concepts, structures and elementary standard processes.

Good practice in terms of ECMS do exist company-wide where guidelines, plans, structures and processes have been implemented throughout the organization, are regularly checked and are supported by technology.

True pioneers in environmental compliance management are companies which anticipate risks and manage them proactively. Best-in-class companies use their ECMS strategically to add value. They have drawn up guidelines, plans and standard processes and firmly anchored them throughout the company. To do this, they rely on supporting technologies and a high degree of automation.

The core elements of an effective and efficient ECMS


It is important to transparently communicate the basic position of management and the role of the supervisory board. This tone at the top must be rigorously reflected in all communications.


In an effective ECMS, legal representatives precisely define compliance goals for each sub-area. These compliance goals, in turn, are based on the corporate goals.


An effective ECMS is characterised by the fact that a procedure has been established to systematically identify compliance risks that could lead to rules being broken – and thus to compliance objectives being missed. Compliance risks are also evaluated in an effective ECMS.


A good ECMS programme is based on the establishment of compliance risk-based policies and measures that aim to limit compliance risks and thus ensure compliance.


In order to avoid corporate culpability, it is crucial that management defines roles and responsibilities and organises the structure and operations of the ECMS in a legally robust and secure manner. Providing sufficient resources for an effective ECMS is also essential.


Effective ECMSs clearly communicate the compliance programme and the defined roles and responsibilities. This is the only way that the programme can properly do its job. This also includes creating reporting channels for compliance risks and evidence of rule-breaking.

Monitoring and improvement

Effective ECMS are under constant scrutiny: suitability and effectiveness must be monitored at all times. Defined ECMS documentation helps with this process. It is also important to report, continuously improve and eliminate any weak points that have been identified.

We will guide you on your journey into the future

PwC’s environmental compliance services combine environmental expertise with the success factors of traditional compliance management. Our experts can support you in setting up an Environmental Compliance Management System – from strategy through execution.

Our interdisciplinary team of experts on the environment, business processes, sustainability and technology has in-depth knowledge and wide-ranging experience to provide the skilled support you need for sustainable and robust transformation of your environmental (compliance) management system. Alongside many years of insight into compliance management approaches, our specialists also have invaluable company- and industry-specific knowledge and experience with leading tools.

Your benefits

Anchoring environmental compliance concerns in your company

Agreement on a coordinated, holistic approach to action

Comprehensive assignment of roles and activities within the process chain

Clear commitment to lawful and responsible action on environmental issues

Regulatory framework
Embedding environmental compliance concerns and requirements 

“Implementing an Environmental Compliance Management System is an important pillar of governance for strengthening the integrity and sustainability of a company.”

Daniela Hanauer,Partner, Risk Consulting at PwC Germany
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Daniela Hanauer

Daniela Hanauer

Partner, Sustainability Services, PwC Germany

Tel: +49 151 11720054

Dieter W. Horst

Dieter W. Horst

Senior Manager, Risk Consulting, PwC Germany

Tel: +49 69 9585-1397

Hermann Gratzer

Hermann Gratzer

Manager, Risk Consulting, PwC Germany

Tel: +49 175 43 41 481