An environmental compliance manager at a large manufacturing company faces a familiar decision: Whether to move forward with a multimillion-dollar investment in emissions-control equipment.

Under last year’s regulatory framework, this would have been a routine investment. At that time, federal greenhouse gas (GHG) regulations made the long-term compliance trajectory relatively clear.

However, today’s regulatory climate is far less predictable.

For environment, health, and safety (EHS) professionals in many industries, the sweeping deregulatory agenda the EPA launched last year has introduced a new challenge: Planning for regulations that disappear and then return.

In March 2025, EPA Administrator Lee Zeldin announced a sweeping initiative to reconsider or roll back more than 30 environmental regulations affecting air pollution, water protections, and climate policy. The Agency described the effort as the most significant deregulatory agenda in EPA history.

The listed items up for reconsideration included the EPA’s 2009 Endangerment Finding, the scientific determination that GHGs pose a threat to public health and welfare under the Clean Air Act (CAA).

In February 2026, the Agency finalized the rescission of the Endangerment Finding, which eliminated GHG emissions standards for vehicles and engines impacted by the determination.

For risk managers and environmental compliance professionals, the significance of these actions lies not only in the rollback itself but also in the uncertainty they introduce into the future of environmental regulations.

“In this undulating landscape, only this message is reliable: environmental compliance is an unyielding obligation that persists until all applicable requirements (in federal rule, state law, and permits) are nullified. That means businesses and industries are wise to stay the course of environmental stewardship and invest in compliance and communities, until further notice,” advises law firm Stoel Rives LLP.

What risk managers should watch next

For companies responsible for environmental compliance, the evolving regulatory landscape raises several strategic questions:

Federal litigation outcomes: Legal challenges to the repeal of the Endangerment Finding could determine whether federal GHG regulations remain dismantled or are eventually reinstated.

Expansion of state climate regulations: Even as federal environmental policies change, The New York Times notes that many states continue pursuing independent emissions-reduction initiatives that may affect companies operating nationally.

Regulatory reversals under future administrations: Environmental policy historically shifts between presidential administrations, creating the possibility that regulations rescinded today could return in future rulemakings.

Corporate environmental, social, and governance (ESG) and investor expectations: Even in the absence of federal mandates, companies may face continued pressure from investors, lenders, and customers to maintain environmental performance commitments. For many risk managers, these overlapping pressures make environmental compliance planning more complex.

A broad deregulatory agenda

The repeal of the Endangerment Finding represents only one piece of a much broader deregulatory effort across EPA programs.

Beginning in 2025, the administration identified dozens of environmental rules for revision or repeal across air quality, water protection, and climate policy.

Media reports have described the initiative as a sweeping rollback agenda affecting environmental protections across multiple regulatory programs.

The deregulatory effort spans several major environmental policy areas, including:

Air pollution standards

GHG regulation

Water protection policies

Environmental enforcement priorities

Supporters argue that many environmental regulations adopted during previous administrations imposed excessive compliance costs on industries and consumers.

EPA officials say reducing regulatory burdens could lower energy prices, reduce vehicle costs, and improve economic competitiveness.

Critics warn the rollback could weaken environmental protections and reduce oversight of pollution sources.

For corporate environmental managers, however, the central question isn’t whether the policy debate continues but rather how companies should plan for environmental compliance in a regulatory landscape that may shift repeatedly over time.

Why the Endangerment Finding matters

The 2009 Endangerment Finding has served as the legal cornerstone of federal climate regulation for more than a decade.

“The decision [to rescind the Endangerment Finding] is a blow to decades of environmental progress in the U.S.,” asserts TIME magazine. “‘It’s the foundation on which all of the other regulations rest,’ Chris Field, director of the Stanford Woods Institute for the Environment, says of the endangerment finding. ‘It is the authorization to regulate [GHGs], and without that authorization the legal basis for regulating emissions from automobiles and power plants, is fuzzy at best and potentially nonexistent.’”

The finding followed the Supreme Court’s decision in Massachusetts v. EPA, which held that GHGs qualify as air pollutants under the CAA, meaning they fall within the EPA’s regulatory authority.

Following that ruling, the Agency concluded that several GHGs, including carbon dioxide, methane, and nitrous oxide, pose a threat to public health and welfare.

That determination provided the statutory basis for regulating GHG emissions.

Over the past decade, the finding has supported regulatory programs like:

Vehicle GHG emissions standards

Carbon rules for power plants

Climate-related regulatory initiatives across multiple sectors

Because the Endangerment Finding provided the legal foundation for these programs, rescinding it has implications that extend far beyond a single regulation.

What the deregulation changes

The EPA’s 2026 action rescinds both the Endangerment Finding and the GHG emissions standards tied to it.

EPA officials state the change will reduce regulatory burdens, lower vehicle prices, and generate substantial economic savings.

However, the rollback doesn’t eliminate environmental obligations for businesses entirely.

Many environmental monitoring and reporting programs remain in place, and state governments may continue implementing climate-related regulations.

For companies operating nationally and internationally, the practical result may be a more fragmented regulatory environment rather than the disappearance of environmental compliance requirements.

Regulatory volatility: The risk behind the rollback

For corporate risk managers, the most significant consequence of the EPA’s deregulatory agenda may be regulatory volatility.

Environmental compliance investments typically involve long-lived infrastructure.  Companies often make capital decisions based on regulatory expectations that extend 10 to 20 years into the future.

When regulatory frameworks shift rapidly, those assumptions become harder to evaluate.

Legal and regulatory analysts note that companies must continue planning for environmental compliance even when regulatory requirements appear to be changing.

Insurance and liability risk

Another factor complicating corporate planning is environmental liability risk.

Even when regulatory requirements change, environmental liabilities related to contamination, emissions, or compliance failures can persist for decades.

Insurance providers and risk consultants often advise companies to maintain robust environmental risk management practices regardless of short-term regulatory changes.

Environmental liabilities frequently arise through litigation, cleanup obligations, or legacy contamination issues that remain subject to federal and state environmental laws.

As a result, the financial exposure associated with environmental risk may continue even if certain regulatory requirements are reduced.

Supply chain and market pressure

It’s also important to consider pressures beyond federal environmental regulation.

Many multinational corporations operate within supply chains that increasingly include climate-related reporting and emissions-reduction commitments.

Large retailers, manufacturers, and financial institutions often require suppliers to disclose environmental performance data or meet sustainability targets.

As a result, companies may face continued incentives to manage emissions and environmental impacts even in the absence of federal regulatory requirements.

For organizations participating in global supply chains, environmental performance expectations may increasingly be shaped by market forces rather than regulatory mandates.

Will courts reinstate climate regulation?

The repeal of the Endangerment Finding is expected to face extensive litigation.

Environmental organizations and several states have already indicated plans to challenge the decision in federal court.

Legal challenges will likely focus on whether the EPA has the authority to reverse its scientific determination that GHGs endanger public health.

Analysts also believe “the policy reversal could, for example, lead to a surge in lawsuits known as ‘public nuisance’ actions, a pathway that had been blocked following a 2011 Supreme Court ruling that GHG regulation should be left in the hands of the [EPA] instead of the courts,” Reuters explains.

“This may be another classic case where overreach by the Trump administration comes back to bite it,” said University of Maryland environmental law professor Robert Percival.

“Environmental groups have slammed the proposed repeal as a danger to the climate. Future U.S. administrations seeking to regulate [GHG] emissions likely would need to reinstate the endangerment finding, a task that could be politically and legally complex,” Reuters continues.

If courts determine the Agency lacks authority to rescind the finding, federal GHG regulations could eventually be reinstated.

For environmental compliance managers, this possibility introduces significant uncertainty into long-term planning.

Will states fill the federal gap?

Even as federal climate regulations are rolled back, many states continue pursuing independent environmental policies.

Coalitions like the U.S. Climate Alliance have committed to maintaining emissions-reduction initiatives regardless of federal policy changes.

Several states already maintain environmental regulations covering:

Vehicle emissions

Renewable energy standards

GHG reporting requirements

For companies operating nationally, this creates a compliance landscape defined by a patchwork of state regulations.

Organizations may face limited federal requirements while still complying with stringent environmental rules in multiple states.

Conclusion: Environmental risk is shifting, not disappearing

The EPA’s deregulatory agenda represents one of the most significant environmental policy shifts in decades.

Yet the rollback of federal regulations doesn’t necessarily eliminate environmental risk for businesses.

Instead, it may change the nature of that risk.

Legal challenges, state-level environmental policies, and potential future regulatory reversals could leave companies navigating a more complex and uncertain compliance landscape.

For environmental professionals, the key challenge may not be adapting to the rules that exist today but preparing for the possibility that the rules of tomorrow may look very different.

In an era of regulatory volatility, the greatest risk may not be the regulations that disappear but the ones that return.