05 Feb 2026
By Jennifer Davidson, Associate, Real Estate, Gilson Gray
From 1 November 2025, the Environmental Authorisations (Scotland) Regulations 2018 (EASR) became the principal framework through which SEPA authorises and regulates environmental activities in Scotland. The purpose of the EASR is to consolidate them into a single, integrated system.
For businesses, the key takeaway is that environmental permissions that were once dealt with separately for waste, water and industrial activities are now managed under one regulatory structure.
Environmental Authorisations (Scotland) Regulations 2018
EASR is essentially a common set of authorisation types and compliance tools. Depending on the risk and complexity of your operations. The activities will now be categorised as follows:
Many existing consents transitioned into EASR authorisations on commencement, but businesses must check whether conditions, category, or authorisation type have altered, and whether a fresh application is required in your specific circumstances. If fresh applications are required, then you must be mindful of the deadlines imposed here to avoid falling foul of the regulations. It should also be noted that in some cases activities that previously operated under exemptions now require a registration or licences, as some of the previous exemptions no longer exist.
What to do as a business
As a business and from a risk management and compliance perspective it is important to:
1. Audit your activities – identify all waste, water and industrial operations at each site.
2. Confirm your current authorisation status – ensure you understand what EASR authorisations now apply and on what conditions.
3. Check transitional deadlines – some activities have grace periods to convert or reapply; these should be diarised and actively managed.
4. Plan ahead for variations or applications – SEPA will expect early engagement where permissions need to change.
Failure to comply with the regulations could result in enforcement action, operational delays or reputational risk.
The onus is on the individuals/businesses to understand their current compliance position and take all necessary steps to ensure compliance.
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