EPAS appeals process
The EPAS appeals process gives regulated operators a clear route to challenge decisions. If you disagree with a decision recorded in your Compliance Verification Report (CVR), you can ask SEPA to review it.
Before starting an appeal, we encourage informal discussion with the SEPA officer who made the decision, as many issues can be clarified and resolved quickly at this stage.
Please note: we will only start processing EPAS appeals from 2 February 2026. If you wish to initiate the Appeals Process before this date, please email EPAS@sepa.org.uk and it will be placed on hold until then.
Who can appeal
The appeals process must be initiated by the regulated operator named in the CVR. Appeals from third parties will not be accepted.
What can be appealed
You can seek review/appeal for any EPAS decision, except for decisions that could not cause you a disadvantage e.g. our decision that you are compliant.
EPAS will be introduced in phases. From 1 January 2026, the major non-compliance criteria and environmental events framework apply. This means that you can commence the appeals process for the following:
- decisions on whether something is non-compliant
- decisions on whether something is major non-compliant
- decisions that operator evidence does not demonstrate a return to compliance
Once EPAS is fully implemented, there will be other decisions which you will be able to appeal. All required information will be added to this page.
How the process works
The appeals process has three stages.
Stage 1 (In team review)
- This begins when we receive your Review Form.
- During this stage, the original decision-maker will review their decision and present their findings to a Senior Environmental Protection Officer (SEPO) or Line Manager in their team.
- The SEPO or manager will review this, consider whether any further information is needed and make the decision on the Stage 1 review.
- If you remain dissatisfied, then you can progress to stage 2.
Stage 2 (Management review)
- This involves a review of the decision by a manager or principal lead specialist regulator or advisor from a different team within the Regulation, Business and Environment portfolio.
- If you remain dissatisfied, then you can progress to stage 3.
Stage 3 (Formal appeal)
- This is the final step in the process.
- The person making the decision on the appeal is not just in a different line management chain but is also within a different portfolio (Governance, Performance and Engagement).
Timescales
If there are exceptional circumstances that mean you cannot make these deadlines you should let us know in advance. We will endeavour to meet the following timescales for decision-making. If for any reason we require additional time we will advise you and give a timeframe for our response. We propose to keep timescales under review and may amend based on our experience of operating the appeals process.
Stage 1: Your Review Form must be submitted within 28 calendar days (including public holidays) of the date on your Compliance Verification Report. We aim to respond within 7 calendar days of receiving your Review Form.
Stage 2: You have 14 calendar days (including public holidays) from being notified of the Stage 1 outcome to submit a request for a Stage 2 review. We aim to respond within 14 calendar days of receiving this request.
Stage 3: You have 14 calendar days (including public holidays) from being notified of the Stage 2 outcome to submit the Stage 3 appeal. We aim to respond within 28 calendar days of receiving this request.