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How do I object to an NCEC decision or fine?

The separate objection routes and deadlines for NCEC permit decisions, rehabilitation and remediation plan decisions, audit-related decisions and penalties.

NCEC rules. 4 min read.

Short answer

Decisions on environmental permits can be objected to in writing to NCEC within 15 working days of notification, and NCEC decides within 30 working days. Late objections are not accepted. Objections to penalty decisions follow the rules and procedures of the committees that review Environmental Law violations, which the 1446H Violations regulation now refers to instead of setting its own deadline. Committee decisions can be challenged before the administrative court.

Key terms used in this guide 11 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
Compensation
Monetary amount paid by the person who causes the damage, pollution or environmental degradation, to compensate for or eliminate the resulting deterioration. It includes rehabilitation expenses if the person causing the damage did not carry out the rehabilitation. Arabic: التعويضات (meaning “the compensations”) Aqueous reg. Art. 1
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 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 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 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
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)
Remediation of polluted sites
Any procedure conducted on a polluted site to restore it to its natural state of environmental balance in accordance with the requirements of the competent authority. Arabic: معالجة المواقع الملوثة (meaning “treatment of polluted sites”) Rehab reg. Art. 1
Remediation plan
Plan that must be developed and submitted to NCEC when any environmental pollution incident occurs while the activity is being set up, operated or closed, or on NCEC request after inspections or audits. Arabic: خطة معالجة المواقع الملوثة (meaning “plan for treating polluted sites”) Rehab reg. Art. 5, Second (1)

All 49 terms in the NCEC glossary

On this page
  1. Which route applies to my decision?
  2. How do I object to a permit decision?
  3. How do I object to a rehabilitation or remediation plan decision?
  4. What about audit and inspection decisions?
  5. How do I object to a fine?
  6. What should an objection include?
  7. What can go wrong?
  8. Checklist when you receive a decision

Which route applies to my decision?

The route and deadline depend on the type of decision.

Permit decisionWritten objection to NCEC within 15 working days
Rehabilitation plan after an incident or NCEC requestObjection within 10 working days
Remediation planObjection within 10 working days
Penalty decisionObjection under the Committee rules. No period in the 1446H regulation
Committee decisionAdministrative court

Table sourcePermits reg. Art. 10(1), Rehab reg. Appendix 1, Violations reg. (1446H) Art. 6, Env Law Art. 39(4)

How do I object to a permit decision?

You may object in writing to NCEC's decisions on environmental permits within 15 working days of notification. Objections received after that period are not accepted.Permits reg. Art. 10(1)

NCEC decides on the objection within 30 working days of receiving it.Permits reg. Art. 10(2)

Objections to decisions on rehabilitation plans for designated Category 1 activities, or on plans inside a Category 2 or 3 EIA, follow the permits regulation route.Rehab reg. Appendix 1

The permits regulation does not describe a further appeal after NCEC's decision on the objection.

How do I object to a rehabilitation or remediation plan decision?

For rehabilitation plans required after an incident or at NCEC's request, and for remediation plans, the objection window is 10 working days from notification.Rehab reg. Appendix 1

Objections received after that period are not accepted. NCEC decides within 10 working days of receipt.Rehab reg. Appendix 1

For plans submitted with an environmental audit study, the rehabilitation regulation points to the inspections and audits regulation. That regulation does not contain its own objection article.Rehab reg. Appendix 1

What about audit and inspection decisions?

NCEC reviews an audit study within 30 days of receiving it and may approve it, reject it or ask for corrections or missing items. A revised study gets a final decision within 30 days of receipt.Audit reg. (1446H) Art. 5, Second (2)

Approval of the audit study comes with renewal of the operating permit. In practice, a refusal is therefore a decision on an environmental permit, which the permits regulation objection article covers, although the sources do not state this link expressly.Audit reg. (1446H) Art. 5, Second (2)(a)

After an inspection, NCEC reviews your corrective action plan within 15 working days and either approves it or suggests amendments.Audit reg. (1446H) Art. 4, Third (2)

How do I object to a fine?

The competent authority, which is NCEC for matters in its remit, imposes fines of up to 100,000 riyals. Fines above 100,000 riyals are imposed by the Violations Review Committee.Violations reg. (1446H) Art. 4, First (3)

You may object to a fine imposed by the competent authority. The committees review such objections under the rules and procedures for the work of the committees that review Environmental Law violations. The 1446H regulation sets no objection period of its own.Violations reg. (1446H) Art. 6, Env Law Art. 39(2)

The 1446H Violations regulation no longer says what happens if the Committee does not reply. The older 60 day rule came from the 1442H text, which was replaced on 8 Nov 2024.Violations reg. (1446H) Art. 6

Committee decisions can be challenged before the administrative court.Env Law Art. 39(4)

The Environmental Law also provides that Committee decisions may be appealed before the administrative court.Env Law Art. 39(4)

What should an objection include?

The permits regulation requires the objection to be in writing. It does not prescribe a form or content.Permits reg. Art. 10(1)

Committee decisions must be reasoned and passed by majority. The penalty tables issued by the Minister take into account these factors:Env Law Art. 39(2), Violations reg. (1446H) Art. 4, First (2)

  • The nature of the violation.Violations reg. (1446H) Art. 4, First (2)
  • Its gravity.Violations reg. (1446H) Art. 4, First (2)
  • Aggravating circumstances.Violations reg. (1446H) Art. 4, First (2)
  • Mitigating circumstances.Violations reg. (1446H) Art. 4, First (2)

Your statements and arguments can also be recorded in the violation report itself. The inspector may comment on them with reference to supporting documents.Violations reg. (1446H) Art. 3(3)

Build the technical record

Support each point with monitoring data, photos, permit conditions and dates, and keep proof of the date you were notified.

What can go wrong?

Many objections can be lost on timing alone, so check the deadline first.

What can go wrong
  • A permit objection filed more than 15 working days after notification is not accepted.Permits reg. Art. 10(1)
  • A rehabilitation or remediation plan objection has a shorter window of 10 working days.Rehab reg. Appendix 1
  • Relying on the old 60 day silence and court periods. They came from the 1442H Violations regulation, which was replaced on 8 Nov 2024, so confirm the current periods in the Committee rules.Violations reg. (1446H) Art. 6
  • Refusing to sign the violation report does not stop the process. The refusal is noted and the procedure continues.Violations reg. (1446H) Art. 3(4)
  • Compensation is payable within 90 days of notice. The sources do not say whether an objection suspends this.Violations reg. (1446H) Art. 5(2)
  • The violation report template commits the violator to appear at the Ministry branch within 15 days to complete the procedures.Violations reg. (1446H) Appendix 1
  • Referral of a serious act to court does not prevent administrative penalties being imposed as well.Violations reg. (1446H) Art. 4, Third

Checklist when you receive a decision

Act on these points straight away:

  • Record the date you were notified.
  • Identify which regulation the decision falls under.
  • Calendar the objection deadline in working days.
  • Gather the technical evidence before drafting.
Received an NCEC decision or fine you disagree with?

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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 18 references and the 5 regulation texts
  1. Permits reg. Art. 10(1), Rehab reg. Appendix 1, Violations reg. (1446H) Art. 6, Env Law Art. 39(4)
  2. Permits reg. Art. 10(1)
  3. Permits reg. Art. 10(2)
  4. Rehab reg. Appendix 1
  5. Audit reg. (1446H) Art. 5, Second (2)
  6. Audit reg. (1446H) Art. 5, Second (2)(a)
  7. Audit reg. (1446H) Art. 4, Third (2)
  8. Violations reg. (1446H) Art. 4, First (3)
  9. Violations reg. (1446H) Art. 6, Env Law Art. 39(2)
  10. Violations reg. (1446H) Art. 6
  11. Env Law Art. 39(4)
  12. Env Law Art. 39(2), Violations reg. (1446H) Art. 4, First (2)
  13. Violations reg. (1446H) Art. 4, First (2)
  14. Violations reg. (1446H) Art. 3(3)
  15. Violations reg. (1446H) Art. 3(4)
  16. Violations reg. (1446H) Art. 5(2)
  17. Violations reg. (1446H) Appendix 1
  18. Violations reg. (1446H) Art. 4, Third
How to read these references 5 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 Apprehension of Violations and Imposition of Penalties
  • Executive Regulations for the Environmental Rehabilitation of Degraded Sites and Remediation of Polluted Sites
  • Executive Regulation for Environmental Inspections and Audits
  • 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.