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When is an environmental audit study due, and what does NCEC check?

When Category 2 and 3 facilities must submit an environmental audit study, what the study must contain, how NCEC reviews it, and the penalties linked to it.

NCEC rules. 6 min read.

Short answer

Category 2 and 3 activities must submit an environmental audit study with each renewal of the Permit to Operate, and the Permits regulation describes this as every 3 years. The study must be prepared by a service provider licensed by NCEC on the Appendix 1 template of the Audit regulation, and NCEC decides within 30 days. The Financial Dues regulation lists no dues for reviewing audit studies. Not developing the audit carries a fine of 20,000 riyals and not implementing its results carries 30,000 riyals.

Key terms used in this guide 17 terms
Category 1 activities
Activities expected to produce low environmental impact that does not exceed the perimeter of the activity's site. Arabic: أنشطة الفئة الأولى (meaning “activities of the first category”) Permits reg. Art. 4(4), First
Category 2 activities
Activities expected to produce moderate environmental impact throughout the different stages of the activity. The impact may be alleviated and controlled, and does not largely exceed the perimeter of the activity's site. Arabic: أنشطة الفئة الثانية (meaning “activities of the second category”) Permits reg. Art. 4(4), Second
Closure of an activity
Complete closure or removal of an activity (translated from the Arabic guide). Arabic: إغلاق نشاط (meaning “closure of an activity”) Permit guide, definitions
Competent authority
The Ministry, any of the national centres for the environment sector, or the Public Foundation for the Conservation of Coral Reefs and Turtles in the Red Sea, each within its mandate and as the regulations set. Council of Ministers Decision 406 added the Foundation to the Environmental Law definition. The Audit regulation (1446H) uses the same definition. Arabic: الجهة المختصة (meaning “the competent (specialised) authority”) Env Law Art. 1 as amended by Council of Ministers Decision 406 (1445H), Third, Audit reg. (1446H) Art. 1
Environmental audit study
The study that Category 2 and 3 activities, and any activity NCEC names in a reasoned decision, submit with the renewal of the permit to operate. It is prepared by an NCEC licensed provider using the structure in Appendix 1 of the Audit regulation. The 1446H regulation no longer defines the term. Arabic: دراسة التدقيق البيئي (meaning “environmental audit study”) Audit reg. (1446H) Art. 5 and Appendix 1
Environmental compliance certificate (ECC)
Document NCEC grants as proof that the permittee complies with the Law, the executive regulations and the requirements of the environmental permits. Arabic: شهادة الالتزام البيئي (meaning “environmental compliance certificate”) Audit reg. (1446H) Art. 1
Environmental impact assessment (EIA) study
Study aimed at determining, estimating and evaluating the environmental impact of any activity classified by the Center as category 2 or 3, with the objective of incorporating environmental considerations into the final design of the activity, along with economic, social and security considerations, and identifying the necessary alternatives and measures to protect the environment. Arabic: دراسة تقييم الأثر البيئي (meaning “study of the assessment of the environmental impact”) Permits reg. Art. 1
Environmental management plan (EMP)
Measures taken by the person to ensure and sustain environmental compliance. It is submitted as part of the procedures to obtain the environmental permit. Arabic: خطة الإدارة البيئية (meaning “the environmental management plan”) Permits reg. Art. 1
Environmental permit (general)
Document issued by the Center to a person before undertaking an activity. Arabic: التصريح (meaning “the permit (authorisation)”) Permits reg. Art. 1
Environmental permit to operate
A document issued by the Center to a person granting him the permission to operate the activity. Arabic: التصريح البيئي للتشغيل (meaning “the environmental permit for operation”) Permits reg. Art. 1
Environmental rehabilitation
Any procedure conducted on an environmentally degraded site or one that is affected by environmental damage or pollution, to restore its natural state of environmental balance, in accordance with the standards set by the competent authority. Arabic: إعادة التأهيل البيئي (meaning “environmental re-qualification (restoring to a fit state)”) Rehab reg. Art. 1
Financial dues
An amount of money collected by the competent center from a person for the purpose of issuing or renewing licenses or permits or for providing environmental services. Arabic: المقابل المالي (meaning “the financial consideration”) Fees reg. Art. 1
Rehabilitation plan
Plan that must be submitted to NCEC for certain Category 1 activities designated at classification, as part of a Category 2 or 3 EIA, whenever an incident requires rehabilitation of the damaged site, or on NCEC request after inspections or audits. Arabic: خطة إعادة التأهيل البيئي للمواقع المتدهورة (meaning “plan for the environmental rehabilitation of degraded sites”) Rehab reg. Art. 5, First (1)
Self plan (emergency preparedness and response)
Measures to manage an activity's or facility's internal environmental emergencies. They cover preparedness for the environmental risks that threaten it and the steps after an emergency or disaster, including rehabilitation of the affected areas. Arabic: الخطط الذاتية (meaning “the self plans (own plans)”) Emergency reg. Art. 1
Self-inspection
An internal inspection within the activity to ensure compliance with the Law, the executive regulations and environmental requirements. Arabic: التفتيش الذاتي (meaning “self-inspection”) Audit reg. (1446H) Art. 1
Service provider
A person licensed by the competent authority to provide environmental services. The Audit regulation uses the singular مقدم الخدمة (meaning the service provider) for a person licensed by the Center. Arabic: مقدمو الخدمات (meaning “the service providers (those who provide the services)”) SP reg. (1446H) Art. 1 and Audit reg. (1446H) Art. 1
Wastewater
Water whose use has changed its color, taste, odor, or level of health or environmental security. This includes water used for health, industrial or agricultural purposes, including cooling water and water from desalination plants (brine). Arabic: مياه الصرف (meaning “drainage water”) Aqueous reg. Art. 1

All 49 terms in the NCEC glossary

On this page
  1. When is an audit study required?
  2. How does the audit fit into the renewal application?
  3. What must the audit study contain?
  4. What does NCEC look for in the detail?
  5. How long does NCEC take to review it, and what does it cost?
  6. How does the audit link to the compliance certificate?
  7. What can go wrong?

When is an audit study required?

The Audit regulation requires an environmental audit study for Category 2 and 3 activities at each renewal of the Permit to Operate. NCEC can also require one for any category if it justifies the request.Audit reg. (1446H) Art. 5, First (a) and (b)

The Permits regulation says that renewal of the Permit to Operate requires an audit study every 3 years for Category 2 and 3 activities.Permits reg. Art. 6, Third (6)

NCEC sets the validity of each Permit to Operate at between 3 and 6 years.Permits reg. Art. 6, Third (7)

The sources do not say how the 3-year audit cycle applies to a permit issued for longer than 3 years. Check the conditions of your own permit.Permits reg. Art. 6, Third (6) and (7)

Existing Category 2 and 3 activities that never held an environmental permit submit an audit study, with an undertaking to implement its results, to obtain a Permit to Operate.Permit guide, section 7.2.2

The Environmental Law itself requires permit holders to provide the competent authority with the environmental audit, as the regulations specify.Env Law Art. 8(5)

How does the audit fit into the renewal application?

The audit study is submitted to NCEC together with the renewal application for the Permit to Operate.Audit reg. (1446H) Art. 5, Second (1)

The NCEC permit guide asks permittees to apply for renewal of the Permit to Operate 30 days before it expires.Permit guide, section 5(h)

For Category 2 and 3 renewals, the permit guide lists:Permit guide, section 8.2.2

  • The environmental audit study.Permit guide, section 8.2.2
  • An updated rehabilitation plan, included in the audit study.Permit guide, section 8.2.2
  • Any other requirement NCEC considers necessary.Permit guide, section 8.2.2

The Rehabilitation regulation also requires the rehabilitation plan to be updated when an audit study is carried out and submitted.Rehab reg. Art. 5, First (2)(a)

NCEC reviews a rehabilitation plan submitted with an audit within the period set for reviewing the audit.Rehab reg. Appendix 1

An Environmental Management Plan or rehabilitation plan submitted inside an EIA or audit study needs no additional review fee.Permit guide, section 1(c)

The Permit to Operate cannot be renewed until the annual financial dues for the operating permit are fully paid.Fees reg. Art. 4(7)

What must the audit study contain?

The study follows the template in Appendix 1 of the Audit regulation, and NCEC may amend the template as it sees fit.Audit reg. (1446H) Art. 5, Second (1)

The template chapters are:Audit reg. (1446H) Appendix 1

  • Introduction, including the service provider, the activity description and an overview of previous audit studies.Audit reg. (1446H) Appendix 1, chapter 1
  • Related environmental laws and executive regulations.Audit reg. (1446H) Appendix 1, chapter 2
  • The surrounding environment: site and topography, geology, hydrology and hydrogeology, and the surrounding area.Audit reg. (1446H) Appendix 1, chapter 3
  • Activities and production: process description, inputs and outputs, energy use, water consumption and a schematic.Audit reg. (1446H) Appendix 1, chapter 4
  • Environmental performance: management system, air emissions, wastewater, solid and hazardous waste, biodiversity and land use, noise, HSE incidents and complaints, and the contingency plan.Audit reg. (1446H) Appendix 1, chapter 5
  • An outcomes summary and a compliance executive plan with corrective measures, enhancement opportunities and a self-inspection plan.Audit reg. (1446H) Appendix 1, chapters 6 and 7
  • Appendices such as references, CVs of the study team, permits and licences.Audit reg. (1446H) Appendix 1, chapter 8

The template also lists these items:Audit reg. (1446H) Appendix 1

  • Front matter with a table of contents, a list of figures and numbers, definitions of terms and a non-technical summary of the report.Audit reg. (1446H) Appendix 1, front matter
  • Other indicators, as the last item of the environmental performance chapter after the activity's emergency plan.Audit reg. (1446H) Appendix 1, items 5-9 and 5-10
  • In the appendices, the audit methodology and sampling protocol, test results where available, and safety data sheets (MSDS) for chemicals used in the activity.Audit reg. (1446H) Appendix 1, chapter 8

The Emergency regulation requires a self plan for emergency preparedness and response to be prepared, updated and submitted to NCEC for approval when an audit study is prepared and submitted. The plan forms part of the audit study.Emergency reg. Art. 4, First (1)(b)

For marine and coastal activities, the permit application must fully disclose any potential risks or impacts on wildlife and their habitats, including during breeding, migration or rearing seasons. This disclosure goes in the EIA, the environmental management plan and the audit study.Marine reg. (1448H) Art. 7, Third (1)

What does NCEC look for in the detail?

The NCEC audit guide adds detail that reviewers expect to see:Audit guide, p. 13

  • Results of previous audits and the actions taken on their recommendations, plus earlier EIAs, rehabilitation plans and certifications.Audit guide, p. 13
  • The environmental permits held, with their expiry dates, and copies in the appendices.Audit guide, p. 14
  • Climate data with highs, lows and averages for the last five years.Audit guide, p. 15
  • For air emissions, wastewater and solid waste: sources, test points, methods, results and compliance status.Audit guide, p. 18
  • A reference number for each non-conformity, and a compliance action plan showing corrective action, cost, responsibility, status and planned closure date.Audit guide, p. 20
  • A self-inspection plan with monitoring indicator, location, method, responsible staff and cost.Audit guide, p. 21
  • A copy of the service provider's licence and a disclaimer statement from the provider.Audit guide, p. 11

The guide describes the audit study as a binding document for facility operators.Audit guide, p. 7

Once NCEC approves the study, you commit to implementing its outcomes and recommendations, and NCEC follows them up.Audit reg. (1446H) Art. 5, Second (5) and (6)

Measure, do not just review documents

The guide asks for test points, methods and results for each environmental medium. Plan field sampling into the audit programme rather than relying on a desk review of permits and records.

How long does NCEC take to review it, and what does it cost?

NCEC decides within 30 days of receiving the study. It either approves the study and renews the permit after the dues are collected, or rejects it or asks for corrections or missing items.Audit reg. (1446H) Art. 5, Second (2)

After a revised study is received, NCEC makes its final decision within 30 days.Audit reg. (1446H) Art. 5, Second (2)(b)

NCEC may extend the review period when needed, after notifying you, by no more than 15 days. It may also visit the site to check the study details against reality.Audit reg. (1446H) Art. 5, Second (3) and (4)

The NCEC audit guide states the review period as 30 days, which matches the 1446H Audit regulation. The older 1442H regulation said 30 working days, so older advice may quote the wrong period.Audit guide, p. 8

The Financial Dues regulation lists no financial dues for reviewing environmental audit studies.Fees reg. Appendix 1, item 7

The study must be prepared through a service provider authorised by NCEC.Audit reg. (1446H) Art. 5, Second (1)

How does the audit link to the compliance certificate?

NCEC issues an Environmental Compliance Certificate on request when its own inspection and the audit study both show at least compliance. Certificate holders may use the Environmental Compliance Badge.Audit reg. (1446H) Art. 6(1) and (2)

The NCEC compliance certificate guide also requires a compliance plan and ISO 14001 certification, and makes the certificate valid for the same period as the permit.Compliance certificate guide, section 11

An operating permit longer than 3 years is possible for activities that hold NCEC compliance certificates, or that had no exceedances and complied with their management and emergency plans and previous permit conditions.Permit guide, section 10

A request for an operating permit term longer than 3 years must be accompanied by an audit study.Permit guide, section 10.1

What can go wrong?

Common audit problems and their consequences:

What can go wrong
  • Not developing the audit study carries a fine of 20,000 riyals.Audit reg. (1446H) Art. 8, Table 1, item 9
  • Not implementing the approved audit outcomes and recommendations carries 30,000 riyals.Audit reg. (1446H) Art. 8, Table 1, item 10
  • Under the Audit regulation, inaccurate or incorrect information in reports to NCEC carries 1,000 to 50,000 riyals and referral to the Public Prosecution.Audit reg. (1446H) Art. 8, Table 1, item 1
  • The Permits regulation sets 1,000 to 100,000 riyals and referral to the Public Prosecution for incorrect information in any study, plan or report. The sources do not say which range applies to an audit study.Permits reg. Art. 11, Table 2 (2024), item 1
  • Submitting an audit study prepared by an unauthorised service provider is prohibited, although Table 1 of the Audit regulation has no specific fine line for it.Audit reg. (1446H) Art. 7(7)
  • Operating without an effective Permit to Operate carries 10,000, 20,000 or 50,000 riyals for Category 1, 2 or 3 activities.Permits reg. Art. 11, Table 2 (2024), item 4
  • Unpaid annual operating permit dues block the renewal.Fees reg. Art. 4(7)
  • Not preparing and submitting the emergency self plan carries 5,000 to 10,000 riyals. If the plan is still not submitted after the penalty, the committee of specialists formed by the NCEC CEO may ask the Violations Review Committee to order temporary closure of the activity.Emergency reg. Table 1, row 1
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References

Each small number in this guide shows the article or section that point comes from. Hover over or tap a number to see it, or open the full list below.

Show all 50 references and the 8 regulation texts
  1. Audit reg. (1446H) Art. 5, First (a) and (b)
  2. Permits reg. Art. 6, Third (6)
  3. Permits reg. Art. 6, Third (7)
  4. Permits reg. Art. 6, Third (6) and (7)
  5. Permit guide, section 7.2.2
  6. Env Law Art. 8(5)
  7. Audit reg. (1446H) Art. 5, Second (1)
  8. Permit guide, section 5(h)
  9. Permit guide, section 8.2.2
  10. Rehab reg. Art. 5, First (2)(a)
  11. Rehab reg. Appendix 1
  12. Permit guide, section 1(c)
  13. Fees reg. Art. 4(7)
  14. Audit reg. (1446H) Appendix 1
  15. Audit reg. (1446H) Appendix 1, chapter 1
  16. Audit reg. (1446H) Appendix 1, chapter 2
  17. Audit reg. (1446H) Appendix 1, chapter 3
  18. Audit reg. (1446H) Appendix 1, chapter 4
  19. Audit reg. (1446H) Appendix 1, chapter 5
  20. Audit reg. (1446H) Appendix 1, chapters 6 and 7
  21. Audit reg. (1446H) Appendix 1, chapter 8
  22. Audit reg. (1446H) Appendix 1, front matter
  23. Audit reg. (1446H) Appendix 1, items 5-9 and 5-10
  24. Emergency reg. Art. 4, First (1)(b)
  25. Marine reg. (1448H) Art. 7, Third (1)
  26. Audit guide, p. 13
  27. Audit guide, p. 14
  28. Audit guide, p. 15
  29. Audit guide, p. 18
  30. Audit guide, p. 20
  31. Audit guide, p. 21
  32. Audit guide, p. 11
  33. Audit guide, p. 7
  34. Audit reg. (1446H) Art. 5, Second (5) and (6)
  35. Audit reg. (1446H) Art. 5, Second (2)
  36. Audit reg. (1446H) Art. 5, Second (2)(b)
  37. Audit reg. (1446H) Art. 5, Second (3) and (4)
  38. Audit guide, p. 8
  39. Fees reg. Appendix 1, item 7
  40. Audit reg. (1446H) Art. 6(1) and (2)
  41. Compliance certificate guide, section 11
  42. Permit guide, section 10
  43. Permit guide, section 10.1
  44. Audit reg. (1446H) Art. 8, Table 1, item 9
  45. Audit reg. (1446H) Art. 8, Table 1, item 10
  46. Audit reg. (1446H) Art. 8, Table 1, item 1
  47. Permits reg. Art. 11, Table 2 (2024), item 1
  48. Audit reg. (1446H) Art. 7(7)
  49. Permits reg. Art. 11, Table 2 (2024), item 4
  50. Emergency reg. Table 1, row 1
How to read these references 10 texts cited
  • Art. 7(4)(b) means Article 7, paragraph 4, item (b).
  • First, Second and Third are the numbered parts some articles are divided into. The Arabic texts write them أولاً، ثانياً، ثالثاً (meaning first, second, third).
  • H after a year marks the Hijri (Islamic calendar) year. 1446H ran from July 2024 to June 2025.

Every text we cite is listed on our regulations page.

Regulation texts this guide is written from

  • Executive Regulations for Environmental Permits to Establish and Operate Activities
  • Executive Regulation for Environmental Inspections and Audits
  • NCEC Environmental Guidelines for Inspection and Environmental Audit Studies (EP-M-44-V01)
  • NCEC guide to issuing and renewing environmental permits for the construction and operation of activities (LO-1-M-005)
  • Executive Regulation for Controls and Procedures Pertaining to Financial Dues for Environmental Licenses, Permits and Services
  • Executive Regulations for the Environmental Rehabilitation of Degraded Sites and Remediation of Polluted Sites
  • NCEC guide to standards and regulations for issuing an environmental compliance certificate (CP-02-M-02-V01)
  • Environmental Law (Royal Decree M/165)

This guide is general information written from the regulation texts listed above. It is not legal advice. Regulations change, and the official text always prevails. Spotted something out of date? Request a change.