Analysis of the regulator’s public enforcement actions shows how President Trump’s staffing cuts and strategy changes led to far fewer companies facing enforcement action in 2025 compared to the previous year.
Key takeaways
- The EPA announced 120 enforcement actions in March to August 2024, but just 43 in the same period this year.
- Both the number and value of penalties handed to businesses fell sharply.
- The Trump administration pledged to cut environmental regulations, and slashed agency staff numbers.
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Enforcement activity by the US Environmental Protection Agency (EPA) under the Trump administration has fallen dramatically compared to its work under Joe Biden, Lexology PRO analysis of regulatory data reveals.
In March to August 2025 the EPA announced 43 enforcement actions, whereas in the same six-month period of 2024 that figure was 120 – a decline of 64%. Penalties issued to companies for breaching pollution and other environmental regulations fell sharply in both number and value, as did administrative orders, such as orders to prevent the sale of dangerous pesticides.
Lee Zeldin was sworn in as the director of the EPA on 29 January 2025, and announced his agency’s priorities on 4 February. It is possible that the lack of enforcement in 2025 relative to 2024 is linked to a new team finding its feet – but the Trump administration also pledged to gut the agency, and by 18 July had cut 23% of its staff.
In an enforcement memo published on 12 March, Zeldin committed to rolling back any EPA activity related to “environmental justice” and “DEI”, although such issues do not appear to have influenced the data to any meaningful degree.
For US companies, the data paints a picture of a regulator that may be focusing less on on-the-ground enforcement, but one still prepared to hand down penalties for some environmental offences.
Companies face fewer penalties, of lower value
In terms of penalties handed directly to companies, and out-of-court settlements, the EPA handed businesses far fewer fines, and fines of lower value, compared to the same period a year prior.
The figures are influenced by outliers in both years. In 2024, the EPA agreed a $310 million settlement with Norfolk Southern over cleanup costs for a 2023 train derailment. In 2025, a court approved a $1.6 billion fine to Hino Motors for fraudulently downplaying its vehicles’ emissions.
| Time period | Number of penalties | Cumulative value | Highest penalty |
| March – August 2024 | 46 | $389.3 million | $310 million (Norfolk Southern) |
| March – August 2025 | 27 | $1.61 billion | $1.6 billion (Hino Motors) |
These actions were initiated years earlier. Without these outliers, the figures are more illustrative of contemporary trends.
| Time period | Number of penalties | Cumulative value | Average |
| March – August 2024 | 45 | $79.3 million | $1.76 million |
| March – August 2025 | 26 | $10.3 million | $396,000 |
The EPA announced far fewer enforcement actions across the board in 2025, but the number of penalties issued fell less than other enforcement types. While penalties fell in 2025 compared to 2024, as a share of the EPA’s overall enforcement, they actually rose from around 40% to over 65% of announced actions. This indicates that while its activity fell, the agency was still much more focused on handing out financial punishments to companies than other types of enforcement.
Overall EPA enforcement activity
In addition to penalties and settlements, the EPA announced dozens of administrative orders, cleanup operations and reviews. All of these fell sharply in 2025 compared to 2024.
In March to August 2024, the agency announced 30 administrative orders, 10 reviews, and the initiation of two lawsuits.
In the same period in 2025, the EPA announced nine administrative orders and two reviews.
The issues the agency focused on did not change dramatically, as shown in part by the laws and regulations cited in the announcements. Analysis showed that in 2024 the EPA announced 36 enforcement actions related to the Clean Air Act, 26 related to the Clean Water Act and related statutes, 11 regarding pesticide control, and seven on lead-based paint and other occupational safety and chemical regulations.
In 2025, there were 14 announcements related to the Clean Air Act, eight related paint and chemicals, seven under the Clean Water Act and four related to pesticides. Proportionately, the agency focused on these issues to a similar degree despite overall enforcement falling across the board, with only its focus on occupational hazards and chemicals rising as a proportion of its overall focus.
The Trump administration has been open about its intention to draw a line under its predecessor’s climate ambitions and cut red tape for businesses. While the data is based on public announcements, which may not include all EPA actions, it suggests the new EPA wasted no time in changing course, and that staffing cuts and regulatory priorities have resulted in far less regulatory interference for companies.
A spokesperson for the EPA said: "This Administration is focused on efficiently resolving violations and achieving compliance as quickly as possible rather than pushing for broad injunctive relief that goes beyond what the law requires and unfairly and unlawfully burdens industry and energy."
"The Trump EPA will continue to ensure environmental laws are followed and keep Americans safe as we carry out our core mission of providing clean air, land, and water for every American and protecting human health and the environment," they added.