AHJ Radar · Mason Mathews Facility Assurance, LLC
EPA enforcement, fiscal 2025: the cases that reach a building
EPA concluded 2,127 civil enforcement cases in fiscal 2025, the most in nine years, and charged 156 criminal defendants, the most since 2016. Most of the money came from one vehicle-emissions case. The lines that reach a building are smaller and specific: 127 lead-based paint case conclusions, seven settlements for illegal HFC refrigerant imports with a record $427,000 penalty, and 538 self-disclosures covering 957 facilities.
The year in numbers
| Measure | FY2025 |
|---|---|
| Civil enforcement cases concluded | 2,127 (971 administrative compliance orders; 1,107 final administrative penalty orders; 49 civil judicial conclusions) |
| Civil penalties | "over $652 million"; one vehicle-emissions case accounts for 69% of the total |
| Criminal defendants charged | 156 |
| Compliance monitoring activities | 14,020 (8,296 inspections; 5,724 off-site) |
| Self-disclosures and new-owner audit agreements | 538, covering violations at 957 facilities |
The lines that reach a building
| Program | What the report says | Who it reaches |
|---|---|---|
| Lead-based paint (TSCA) | "127 Toxic Substances Control Act (TSCA) lead-based paint case conclusions"; 29 compliance monitoring activities at privatized military housing; a settlement with a housing authority described as first of its kind | Any pre-1978 residential building: the disclosure at lease or sale and the Renovation, Repair and Painting rule for work that disturbs paint |
| HFC refrigerants (AIM Act) | "seven settlements for illegal hydrofluorocarbon (HFC) imports"; the largest, $427,000, "the highest HFC penalty settlement to date"; six defendants charged criminally | Enforcement in FY2025 was aimed at importers, not building owners; a building's own obligations under 40 CFR 84 (leak repair, automatic leak detection from January 1, 2027 for larger systems) are the next layer |
| Self-disclosure | 538 disclosures, 957 facilities | An owner who finds a violation during an audit can disclose it under EPA's audit policy for penalty mitigation; the count shows the route is used |
40 CFR part 84 (eCFR)40 CFR 745 (lead) in the Citation Decoder
What this means for a hotel or a condominium
The report names no asbestos, oil-spill (SPCC) or Section 608 refrigerant case, which does not mean those programs went quiet; EPA's report highlights national initiatives, and most asbestos and tank enforcement in Florida runs through the state and the counties. The two federal lines a property should read as live are lead paint in pre-1978 residential buildings, where EPA counted 127 case conclusions in one year, and refrigerants, where the import crackdown precedes the equipment-owner obligations that start in 2027.
What is not on this page, and why
Penalty amounts for the lead-paint cases are not itemized in the report. The report's civil-penalty total and its narrative for the largest case give different figures ($449 million in the chart, $525 million in the narrative); the total is quoted as the report states it, "over $652 million." Regional and state-level figures are not in the document.
Get the free digest
AHJ Radar™ is a trademark of Mason Mathews Facility Assurance, LLC. Official sources read daily since September 2026; every entry names its source. Content and compilations © 2026 Mason Mathews Facility Assurance, LLC, for personal and internal use under the Terms of Use; no redistribution or resale.
Reference only. This page restates a published official document; it is not legal advice and not an assessment of any property. Confirm requirements with the official text linked above, your authority having jurisdiction and your own counsel. Mason Mathews Facility Assurance, LLC · all reference pages · how our monitor reads sources.