Search the site

Press Esc to close

  1. Home
  2. Royal Commission library
  3. Guides

How does the Royal Commission calculate an environmental fine?

Violation classes, the repeat factor, the self-reporting discount, what comes on top of a fine, and what to do when a notice arrives.

Royal Commission rules. 4 min read.

Short answer

Each clause of Volume I has a penalty range in Table 3.1 of Volume III. The Royal Commission assesses the fine from that range and the violation class it decides, on a scale of six classes from minor to catastrophic. A repeat within two years can raise the fine by a factor that grows with each repeat, and a fourth violation in one class moves it to the next class. Self-reporting and cooperating multiplies the total by 0.75. After a notice, the operator explains within 10 days, submits a compliance plan within 20 days, and pays or appeals within 30 days.

Key terms used in this guide 4 terms
Day
Refers to a working day. RCER-2025 Vol. I, Glossary, page ix
Environmental Permit to Construct (EPC)
The Royal Commission permit an operator must obtain before starting any construction activity related to the process of a new facility. An existing facility also needs an EPC, decided case by case, for reconstruction, modification or expansion. RCER-2025 Vol. I, 1.2.1 and 1.2.2, page 5
Environmental Permit to Operate (EPO)
The Royal Commission permit without which a facility may not operate or carry out process commissioning. It is valid for five years from the date of issue. RCER-2025 Vol. I, 1.3.1 and 1.3.6, pages 5 and 6
Severe damage
Damage with significant impacts on the environment of the RC industrial city. RCER-2025 Vol. I, Glossary, page xi

All 50 terms in the Royal Commission glossary

On this page
  1. What does the Royal Commission take into account?
  2. How are violations classed?
  3. How do repeat violations raise the fine?
  4. What reduces or caps the fine?
  5. What comes on top of the fine?
  6. What do you do when a notice arrives?
  7. How do appeals work?

What does the Royal Commission take into account?

The nature, circumstances and gravity of the violation, the cost of compliance measures, any history of prior offences, actions taken to minimise or mitigate the effects, and good faith efforts toward earlier compliance.RCER-2025 Vol. III, 3, page 3

Every clause of Volume I has a penalty range in Table 3.1.RCER-2025 Vol. III, 3, page 3

Table 3.1 gives the figures without a currency. Volume III’s penalty notice form states the fine in Saudi riyals (SR).RCER-2025 Vol. III, Appendix D, Penalty Notice of Non-Compliance, page 16

How are violations classed?

Penalties are assessed from the range for the clause and the violation class the Royal Commission decides:RCER-2025 Vol. III, 3.1 and 3.1.1, page 3

Class 1, minorLimited effects, fully contained and no lasting damage
Class 2, moderateLocalised effects which may require mitigation
Class 3, majorNoticeable localised effects which require active mitigation
Class 4, severeBroader effects which require a comprehensive plan or mitigation
Class 5, highly severeSevere effects with potentially long-term environmental impacts
Class 6, catastrophicWidespread, potentially irreversible damage to the environment

Table sourceRCER-2025 Vol. III, 3.1.1, page 3

How do repeat violations raise the fine?

The fine for a repeat of an offence committed within the previous two years may be increased by a multiplication factor m:RCER-2025 Vol. III, 3.1.2, page 3

  • Total penalty = first penalty + (m × first penalty)RCER-2025 Vol. III, 3.1.2, page 3
  • m = 1.1 to the power (n − 1), where n is the number of violation incidents for that regulationRCER-2025 Vol. III, 3.1.2, page 3

Worked from the formula: on a second incident n is 2 and m is 1.1, so the total is 2.1 times the first penalty. On a third incident m is 1.21 and the total is 2.21 times.

If a compliance plan is agreed, repeat fines may be suspended until the agreed period ends. They may be waived if the plan succeeds, and are reinstated if it does not.RCER-2025 Vol. III, 3.1.2, page 3

  • A fourth violation in one class moves it to the next class. In the highest class, the fine is doubled after the third repetition.RCER-2025 Vol. III, 3.6, page 4
  • Repeated violations may lead to revocation of the EPO or EPC.RCER-2025 Vol. III, 3.6, page 4
  • Where operations repeatedly cause severe damage, the Royal Commission may hand the case to the competent authorities.RCER-2025 Vol. III, 3.7, page 4

What reduces or caps the fine?

  • Self-reporting the violation and responding proactively and cooperatively to mitigate it multiplies the total penalty by 0.75.RCER-2025 Vol. III, 3.2, page 4
  • Total fines, including repeats, may not exceed the maximum fines in MEWA’s environmental law.RCER-2025 Vol. III, 3.3, page 4
  • Violations caused by extraordinary interruptions from natural causes, failure of utilities outside the operator’s responsibility, or hostilities fall outside the penalty system.RCER-2025 Vol. III, 2.3.4, page 2
  • The Royal Commission may reduce a fine so that the money needed for an agreed compliance plan is not taken away.RCER-2025 Vol. III, 4.2.1(a), page 11
  • Fines that continue to accrue are suspended during an agreed compliance plan, as long as its milestones are met.RCER-2025 Vol. III, 4.2.1(b), page 11

What comes on top of the fine?

  • The costs of all necessary remedial measures.RCER-2025 Vol. III, 3.4, page 4
  • Refusing to pay may lead to revocation of the EPO.RCER-2025 Vol. III, 3.5, page 4
  • The facility is responsible for violations by its contractors and other third parties in their contracted work.RCER-2025 Vol. III, 2.3.2, page 2
  • On a sale, change of name or joint venture, the penalty obligations pass to the operators of the new entity.RCER-2025 Vol. III, 2.3.3, page 2

What do you do when a notice arrives?

The notice of non-compliance names each regulation violated, the basis of the penalty and the amount owed.RCER-2025 Vol. III, 4.1.2, page 10

  • Immediately: take all reasonable measures to minimise the impact.RCER-2025 Vol. III, 4.1.3, page 10
  • Within 10 days: give the reasons for each violation and the immediate measures taken.RCER-2025 Vol. III, 4.1.3, page 10
  • Within 20 days: submit a compliance plan and schedule to prevent recurrence, for RC approval.RCER-2025 Vol. III, 4.1.3, page 10
  • Within 30 days: pay the fine in full, or appeal for a reduction, suspension or waiver with a detailed justification. Paying does not remove the compliance requirements.RCER-2025 Vol. III, 4.1.3, page 10
  • RCER-2025 defines a day as a working day.RCER-2025 Vol. III, Glossary, Day, page viii

Not knowing the cause or existence of a violation is not accepted as a reason to waive or reduce a fine.RCER-2025 Vol. III, 4.1.3, page 10

Section 4.1.3 counts from receipt of the notice. The penalty notice form in Appendix D gives the 10, 20 and 30 working days “from date above”, and the form shows both a notice date and a date of violation above that line.RCER-2025 Vol. III, Appendix D, Penalty Notice of Non-Compliance, page 16

To be safe, count from the earliest date shown on the notice. The deadline calculator in this library counts from the date you enter.

How do appeals work?

Appeals go to the CEO of the Royal Commission in the industrial city concerned. The Environmental Penalty Appeal Committee (E-PAC) investigates and recommends, and the CEO approves the decision. Once approved it cannot be appealed again, and the fines due are paid within 30 days of the decision.RCER-2025 Vol. III, 4.2, page 11

Section 4.2 also gives 60 days from receipt of the notice to appeal to the CEO, and allows an appeal to the courts.RCER-2025 Vol. III, 4.2, page 11

Because section 4.1.3 asks for payment or an appeal within 30 days, appealing within 30 days is the safer course.

Within 30 days of receiving the payment and the compliance plan, the Royal Commission issues a Violation Closure Certificate. It becomes an addendum to the facility’s permit to operate.RCER-2025 Vol. III, 4.3, page 12

Received a Royal Commission notice of non-compliance?

We prepare the 10 day response, the compliance plan and the technical case for an appeal.

Our service: Royal Commission EPC and EPO

Talk to our team

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 21 references and the 3 regulation texts
  1. RCER-2025 Vol. III, 3, page 3
  2. RCER-2025 Vol. III, Appendix D, Penalty Notice of Non-Compliance, page 16
  3. RCER-2025 Vol. III, 3.1 and 3.1.1, page 3
  4. RCER-2025 Vol. III, 3.1.1, page 3
  5. RCER-2025 Vol. III, 3.1.2, page 3
  6. RCER-2025 Vol. III, 3.6, page 4
  7. RCER-2025 Vol. III, 3.7, page 4
  8. RCER-2025 Vol. III, 3.2, page 4
  9. RCER-2025 Vol. III, 3.3, page 4
  10. RCER-2025 Vol. III, 2.3.4, page 2
  11. RCER-2025 Vol. III, 4.2.1(a), page 11
  12. RCER-2025 Vol. III, 4.2.1(b), page 11
  13. RCER-2025 Vol. III, 3.4, page 4
  14. RCER-2025 Vol. III, 3.5, page 4
  15. RCER-2025 Vol. III, 2.3.2, page 2
  16. RCER-2025 Vol. III, 2.3.3, page 2
  17. RCER-2025 Vol. III, 4.1.2, page 10
  18. RCER-2025 Vol. III, 4.1.3, page 10
  19. RCER-2025 Vol. III, Glossary, Day, page viii
  20. RCER-2025 Vol. III, 4.2, page 11
  21. RCER-2025 Vol. III, 4.3, page 12
How to read these references 1 text cited
  • RCER-2025 Vol. I, 1.3.6, page 6 means Volume I, clause 1.3.6, on printed page 6. All three volumes define a day as a working day.

The three RCER-2025 volumes are listed in the Royal Commission library.

Regulation texts this guide is written from

  • Royal Commission Environmental Regulations 2025, Volume I, Regulations and Standards
  • Royal Commission Environmental Regulations 2025, Volume II, Environmental Permits and Licenses Program
  • Royal Commission Environmental Regulations 2025, Volume III, Penalty System and Service Charges

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.