"Compliance First": What Does EPA's New Policy Mean For My Business?

On December 5, 2025, the U.S. Environmental Protection Agency (EPA) Office of Enforcement and Compliance Assurance (OECA) issued an internal policy memorandum¹that sets a "compliance first" directive for EPA's enforcement programs. The policy memorandum became effective immediately and applies to all EPA civil judicial and administrative enforcement staff and both pending and future cases. We provide a summary of the "Compliance First" policy and what regulated parties should expect in interactions with EPA moving forward.

Overview

Acting Assistant Administrator of OECA Craig Pritzlaff opens the policy memorandum by stating that the primary focus of EPA inspections, investigations, enforcement, and compliance assistance activities "must be on achieving and ensuring timely compliance." The memorandum goes on to explain that EPA's priority will be achieving compliance in "the most efficient, most economical, and [by the] swiftest means possible" while still