Environmental Performance Assessment Scheme (EPAS) - a fair way to report performance​ 

Closes 30 Jun 2025

Section 4: What will EPAS apply to?

The activities that we regulate are split into functional “regulatory regimes”, such as water or materials recovery. An operator may carry out activities across several regimes. For example, a waste transfer station that has a waste management licence, plus undertakes activities that fall within the scope of the transfrontier shipment regulations. We plan to apply EPAS to different regimes in phases. 

Section 4.1: Initial application of EPAS

Initially, EPAS will apply to regimes that were included in our 2009-2019 Compliance Assessment Scheme. This includes water, industrial activities, waste management and radioactive substances, see table A1, Annex 1. These are our four largest regulatory regimes. 

These include: 

  • Activities included in the Environmental Authorisations (Scotland) Regulations 2018 i.e. radioactive substances. 

  • Activities that are expected to be included in upcoming amendments to the Environmental Authorisations (Scotland) Regulations and the Integrated Authorisation Framework, planned for November 2025 i.e. water, industrial activities and waste management (those currently included in the Water Environment (Controlled Activities) (Scotland) Regulations 2011 as amended in 2013, 2017 and 2021, the Pollution Prevention and Control (Scotland) Regulations 2012 and Waste Management Licensing (Scotland) Regulations 2011). 

This will include compliance with authorisation conditions, compliance with payment of annual charges and undertaking activities without holding the appropriate authorisation (see section 5: Compliance, for more information). This includes activities authorised under permits, registrations, notifications and General Binding Rules. 

We intend to start publishing environmental performance ratings for these regimes in the 2026 to 2027 financial year, subject to delivery of our new digital systems. We will confirm how EPAS will operate and timescales for implementation by March 2026. 

Section 4.2: Potential future application

We plan to expand EPAS to include the other regimes that we regulate in phases. By assessing environmental performance across a range of activities we regulate, we can provide a more complete picture of an operator’s environmental performance. The regimes we are preparing to include in future phases of EPAS are set out in table table A2, Annex 2. This includes: 

  • Reservoirs. 

  • Materials recovery. 

  • Transfrontier shipment of waste. 

  • Emissions Trading Scheme. 

  • Fluorinated gases (F gases). 

  • Persistent organic pollutants. 

  • Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). 

  • Duty of Care. 

  • Special waste. 

  • Deposit Return Scheme (when this starts). 

  • Digital Waste Tracking (when this starts). 

  • Environmental Authorisations (Scotland) Regulations – new activities (when this starts). 

We will publish the major non-compliance criteria for future regimes at least three months in advance of including them in EPAS.