LEGAL COUNSELNEAR ME
Environmental Law

What should you do when a regulator issues an order or lays charges?

Two very different things arrive from environmental regulators and they demand different responses. An **order** is administrative - it requires action, usually within a short period, and is appealable to an environmental tribunal. A **charge** is quasi-criminal, often a strict liability offence where the prosecution need not prove intent, and the principal defence is due diligence. Confusing the two wastes the deadline for both.

What to do next

  1. Establish which you have received, and the deadline

    Orders carry compliance deadlines and separate, usually short, appeal periods. Charges carry a first appearance date. Both run whatever you do next, and both are strict.

  2. Do not make admissions to inspectors

    Statements to investigators can be used in a prosecution. Cooperate with the process and your legal obligations, but take advice before providing explanations or written responses about how the incident occurred.

  3. Comply while appealing, unless the order is stayed

    An appeal does not automatically suspend an order in most jurisdictions - a stay usually has to be requested. Non-compliance during an appeal can itself be an offence, compounding the problem.

  4. Build the due diligence record

    For strict liability offences the central defence is that you took all reasonable care. Environmental management systems, training records, maintenance and inspection logs, incident response records and prior audits are what establish it - and they must pre-date the incident.

  5. Consider director and officer exposure

    Environmental legislation frequently imposes personal liability on directors and officers who failed to take reasonable care. Where charges name individuals, separate representation may be necessary because interests can diverge.

Frequently asked questions

Is an order the same as a charge?

No. An order is administrative and appealable to a tribunal; a charge is quasi-criminal and proceeds in court. The responses and the deadlines are different.

What is due diligence?

The defence to a strict liability offence: that you took all reasonable care to prevent the event. It rests on records created before the incident, not after.

Can directors be charged personally?

In many jurisdictions yes, where they failed to take reasonable care to prevent the offence. Separate representation is often appropriate.

Should I comply while appealing?

Generally yes unless a stay is granted, because non-compliance can be a separate offence. Ask about a stay immediately.

Which tribunal hears appeals?

The provincial environmental appeal tribunal, with prosecutions in the provincial court. Federal matters go to the Federal Court.

This is general information, not legal advice. Laws vary by location and every situation is different — speak with a qualified lawyer about your specific circumstances.

Dealing with this situation?

Tell us what happened and we will help you identify the type of lawyer who handles it.

By submitting, you agree to be contacted about your inquiry. This is not legal advice and does not create a lawyer–client relationship.

Top rated

Environmental Law Firms Ready to Help

Independently verified — featured placements appear first.

Civil, commercial and estate litigation in Vancouver

Vancouver, British Columbia
  • Appeals
  • Arbitration & Dispute Resolution
  • Boundary Disputes
  • Business Formation
  • Business Law
  • Business Torts
  • Capital Markets & Securities
  • Civil Litigation
  • Commercial Leasing
  • Commercial Litigation
  • Commercial Real Estate
  • Competition & Antitrust
  • Construction Law
  • Contract Disputes
  • Corporate Governance
  • Corporate Law
  • Data Privacy & Cybersecurity
  • Debt Collection
  • Director & Officer Liability
  • Employment Law
  • Environmental Law
  • Estate Litigation
  • Estate Planning
  • Franchise Law
  • Guardianship
  • Insolvency & Restructuring
  • Insurance Law
  • Intellectual Property
  • Joint Ventures
  • Mediation
  • Mergers & Acquisitions
  • Partnership Disputes
  • Partnerships
  • Power of Attorney
  • Professional Negligence
  • Property Development
  • Real Estate
  • Regulatory Compliance
  • Residential Real Estate
  • Securities Litigation
  • Shareholder Agreements
  • Shareholder Disputes
  • Tax Planning
  • Title Disputes
  • Trusts
  • Wills

Civil, commercial and estate litigation in Toronto

Toronto, Ontario
  • Appeals
  • Arbitration & Dispute Resolution
  • Boundary Disputes
  • Business Formation
  • Business Torts
  • Capital Markets & Securities
  • Civil Litigation
  • Commercial Leasing
  • Commercial Litigation
  • Commercial Real Estate
  • Competition & Antitrust
  • Construction Law
  • Contract Disputes
  • Corporate Governance
  • Corporate Law
  • Data Privacy & Cybersecurity
  • Debt Collection
  • Director & Officer Liability
  • Employment Law
  • Environmental Law
  • Estate Litigation
  • Estate Planning
  • Franchise Law
  • Guardianship
  • Insolvency & Restructuring
  • Insurance Law
  • Intellectual Property
  • Joint Ventures
  • Mediation
  • Mergers & Acquisitions
  • Partnership Disputes
  • Partnerships
  • Power of Attorney
  • Professional Negligence
  • Property Development
  • Regulatory Compliance
  • Residential Real Estate
  • Securities Litigation
  • Shareholder Agreements
  • Shareholder Disputes
  • Tax Planning
  • Title Disputes
  • Trusts
  • Wills

Go deeper

Guides, Forums & Where This Is Decided

Background reading and the bodies that hear environmental law matters.

Related guides

Where this is decided

All courts & tribunals