Transformation. That is the one word that sums up 2025. Environmental regulatory shifts, court decisions, and new priorities challenged organizations to adapt quickly.
In this edition of Compliance News, we’ll look back at the key developments that shaped the past year and share what’s ahead in 2026. Our Compliance and Permitting team is ready to track these changes and partner with you to navigate what’s next.
Highlights from 2025
- PFAS Regulation Intensifies. Expanded monitoring requirements proposed in federal stormwater permits, revised drinking water MCLs, and the EPA’s intent to develop new effluent guidelines kept PFAS at the forefront of compliance planning.
- Clean Water Act and Permitting Clarity. A Supreme Court ruling moves away from narrative-based NPDES permit requirements, while NEPA decentralization shifted environmental review approach to individual agencies.
- Climate Risk and Cumulative Impacts. EPA’s proposal to reconsider the 2009 Endangerment Finding related to greenhouse gases (GHG) and repeal GHG emissions standards from some vehicles and engines.
- Digital Transformation in Permitting. CEQ’s Permitting Technology Action Plan and new GIS-based tools highlighted a move toward tech-enabled compliance processes.
- Infrastructure Priorities and Policy Shifts. Executive orders fast-tracked permitting for AI/data centers and critical minerals, while funding shifts reprioritized conventional infrastructure over climate and environmental justice projects.
A Look Ahead at 2026
- Permitting Streamlining Continues. Expect continued efforts to accelerate approvals through digital permitting platforms, expanded categorical exclusions, and coordinated interagency reviews for complex projects. These initiatives aim to reduce delays and improve predictability alongside legislative reforms like the SPEED Act.
- NEPA Reform Momentum. The White House Council on Environmental Quality (CEQ) formally repealed NEPA implementation rules, effective Jan. 8, 2026, replacing the February 2025 interim final rule (IFR). Some attorneys general have argued that environmental review policies and guidance prepared by individual federal agencies since the IFR took effect are unlawful, indicating litigation in 2026 is possible. Meanwhile, the CEQ says it is taking steps to “ensure consistency and efficiency across agency implantation of NEPA.”
- Clean Water Act Updates. The PERMIT Act, now in the Senate, would limit the scope of the Clean Water Act by redefining navigable waters to exclude (1) waste treatment systems, (2) ephemeral features that flow only in direct response to precipitation, (3) prior converted cropland, (4) groundwater, or (5) any other features determined to be excluded by the U.S. Army Corps of Engineers.
- WOTUS Redefinition. EPA and the Corps proposed a new rule narrowing federal jurisdiction to “relatively permanent” waters with continuous surface connections, fully implementing the Sackett Finalization (and continued litigation) is expected later in 2026.