EPAS review and appeals process
The EPAS review and appeals process gives operators a clear route to challenge decisions. If you disagree with certain decisions recorded in your Compliance Verification Report (CVR), you can ask SEPA to review it.
Before starting a review, we encourage informal discussion with the SEPA officer who made the decision, as many issues can be clarified and resolved quickly at this stage.
Who can initiate a review/appeal
The review and appeals process must be initiated by the authorised person named in the CVR. A third party cannot request a review.
Which decisions are in scope
You can seek review/appeal for any EPAS decision, except for decisions that could not cause you a disadvantage - for example, 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 review and 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, other decisions will come in scope. All required information will be added to this page.
How to initiate a review
To request a review, you must download and complete the EPAS Review Form .
Your completed Review Form must be received by SEPA within 28 calendar days (including public holidays) from the date of issue of your CVR.
If you require a paper copy of the EPAS Review Form, you can request one by emailing EPAS@sepa.org.uk or by calling 0300 099 6699.
Once completed, return your Review Form along with all relevant details and any supporting documentation to the email or postal address noted on the EPAS Review Form.
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 received by SEPA within 28 calendar days (including public holidays) of the date of issue of your Compliance Verification Report. We aim to respond within 7 calendar days of receiving your Review Form.
Stage 2: Your request for a Stage 2 review must be received by us within 14 calendar days (including public holidays) from the date the Stage 1 review outcome is issued to you. We aim to respond within 14 calendar days of receiving this request.
Stage 3: Your Stage 3 appeal must be received by us within 14 calendar days (including public holidays) from the date the Stage 2 review outcome is issued to you. We aim to respond within 28 calendar days of receiving this request.