Compliance with Environmental Operating Regulations in the Czech Republic

Operating regulations are not just administrative paperwork, but a key legal obligation monitored by the Czech Environmental Inspectorate (ČIŽP). Violating these rules can lead to fines of up to 10 million CZK or the suspension of business operations. In this article, you will learn about the most common mistakes companies make and how to effectively avoid them. Read our practical guide to understand what inspectors in the Czech Republic focus on.

Quick Summary

• Operating rules are a binding legal document: Companies operating listed sources of pollution in the Czech Republic must have up-to-date, approved operating rules. Without them, or in case of non-compliance, they risk fines of up to CZK 10 million and, in extreme cases, suspension of operations.
• Emphasis on updates and digitalization (2026): Air protection legislation in the Czech Republic is constantly evolving. Operating rules must reflect the current version of Act No. 201/2012 Coll. and Implementing Decree No. 415/2012 Coll., including requirements for the electronic reporting system (ISPOP).
• Inspectors focus on compliance with reality: The Czech Environmental Inspectorate (CEI) most frequently identifies discrepancies between documentation and reality, errors in operating records, non-compliance with technical conditions, and missing employee training records.
• Time and complexity: Reviewing and updating operating rules is a specialized task with significant potential for legal errors. Our Czech legal team can save you time and eliminate the risk of sanctions.

What are operating rules and why they matter

Operating rules are a technical-legal document that may initially seem like mere paperwork involving a set of procedures and rules. In practice, however, it is the legal foundation upon which the Czech Environmental Inspectorate (CEI) builds its inspections and sanctions. If approached lightly, it can cost a company millions of crowns.

Specifically, the operating rules define how you operate a stationary source, the operational parameters, and how you monitor emissions. It is the manual of your legal liability. Under Czech Act No. 201/2012 Coll., on Air Protection, operators of so-called listed sources of pollution (specified in Annex 2 of the Act) must maintain these rules. This typically includes paint shops, foundries, incinerators, large boiler rooms, or gas stations.

The attorneys at ARROWS law firm in Prague have extensive experience with permitting processes and know exactly what the CEI focuses on during inspections in 2026. This is why you need their services, as the practical application involves a complex combination of technical standards and Czech administrative law.

Legal foundations and what your operating rules must contain

The obligation to prepare operating rules arises from Section 12(4)(d) of Act No. 201/2012 Coll., on Air Protection. The requirements for operating rules are set out in Annex 12 of Implementing Decree No. 415/2012 Coll., on the permissible level of pollution. The content is not discretionary, as Czech legislation precisely defines what the document must include.

Operating rules must include source identification, a detailed technical description, a description of emission reduction technology, and a list of pollutants and their parameters. Furthermore, it is mandatory to state binding operating conditions, such as temperature regimes, pressure drops on filters, or reagent dosing. You must also precisely describe the method of emission monitoring, the maintenance of operating records, and the maintenance system.

Current legal practice in the Czech Republic in 2026 emphasizes compliance with integrated permit conditions (for IPPC facilities) and precise fulfillment of reporting obligations. If your operating rules were approved many years ago and do not reflect changes in technology or legislation, it is highly likely they will be deemed insufficient by the Czech authorities.

Main sources of risk: common errors identified by the CEI

When CEI inspectors visit a company, they follow a clear procedure and know where businesses most often fail. Deficiencies fall into three main categories: formal content of the rules, their currency, and factual compliance during operation.

We encounter cases where companies operate sources according to rules approved ten years ago, even though the technology has changed. If burners have been replaced or the types of paint used in a paint shop have changed and this change is not reflected in the operating rules, it constitutes a violation of Czech law.

The second typical problem is incorrect operating records, which must be kept in accordance with Decree No. 415/2012 Coll. A common mistake is that companies record data retrospectively, by estimation, or lack data on operating hours and raw material consumption. During an inspection, the CEI easily detects discrepancies between warehouse records, purchase invoices, and operating logs.

The CEI qualifies this as operating a source in violation of the operating rules, which is an administrative offense under Section 25 of the Air Protection Act. For example, if the operating rules require a daily check of the differential pressure on a filter, but records are missing from the logbook. The third major risk is thus the discrepancy between "paper" and reality.

Most common errors leading to fines

Based on the decision-making practice of the CEI and the experience of our Prague-based attorneys at ARROWS, we have identified specific failures that lead to significant sanctions.

Operation without a permit or approved operating rules

This is the most serious scenario. If you operate a listed source in the Czech Republic without a valid operating permit, you face a fine of up to CZK 10,000,000. The CEI acts uncompromisingly in these cases. In addition to the financial penalty, the authority may order the suspension of the source's operation, which often has fatal economic consequences for the company.

Discrepancy between operating rules and actual state

Inspectors conduct physical inspections of equipment. If they find, for example, that filtration equipment listed in the rules has been removed, is non-functional, or has been replaced by another type without a permit for change, it is a serious offense. Sanctions depend on the severity of the environmental impact.

Deficiencies in operating records

Errors in records are a frequent reason for fines. For example, a paint shop may fail to record the daily consumption of volatile organic compounds (VOCs) and thus cannot prove compliance with emission limits. Incorrect maintenance of operating records carries a fine, but primarily, it prevents inspectors from verifying compliance with limits under Czech regulations.

Non-compliance with mandatory inspections and training

Czech law and decrees require regular technical inspections and revisions. If a company fails to present valid protocols on emission measurements or technical condition inspections, it is a direct ground for a fine. The same applies to operator training, where verifiable records of personnel training must exist.

Exceeding emission limits

If a one-off emission measurement or continuous monitoring proves that the established limits have been exceeded, it constitutes an administrative offense under Czech law. In such a case, the operator is obliged to immediately take remedial measures and inform the Czech Environmental Inspectorate (ČIŽP). Concealing this fact leads to the maximum fine rates.

Risks and Sanctions	How ARROWS Assists (office@arws.cz)
Absence of operating permit or operating rules: Fine up to CZK 10,000,000 (in practice often hundreds of thousands depending on the source size), risk of operation shutdown.	Comprehensive legal service for obtaining permits: The ARROWS law firm in Prague will manage the complete process for obtaining or amending operating permits.
Operation in violation of operating rules (outdated rules): Fine up to CZK 10,000,000. This includes non-compliance with technical operating conditions.	Ensuring operational compliance with valid legislation: Our Czech legal team will perform a compliance audit of your operating rules against the actual state of operations.
Incorrect or missing operational records: Fine up to CZK 500,000 (or up to millions within a broader legal context), risk of incorrect fee calculation.	Methodological support: We will help set up a record-keeping system that complies with the relevant Czech decree.
Failure to meet training and inspection obligations: Fine in the range of tens to hundreds of thousands of crowns, depending on the severity.	Setting up internal mechanisms for training and revisions: We will prepare template documentation for training and schedules for mandatory revisions under Czech law.
Exceeding emission limits: Fine up to CZK 10,000,000, obligation to implement remedial measures.	Expert representation in sanction proceedings: Our Prague-based attorneys will defend you in dealings with the ČIŽP and challenge incorrect measurements.

What to prepare for during a ČIŽP inspection

When you know what the inspectors are looking for, you can be prepared. Inspections in 2026 focus on the following points in the Czech Republic:

Identification and valid permits

Inspectors always begin by checking the valid operating permit and approved operating rules. You must have a version available that includes the clause confirming the legal force of the decision issued by the Regional Office.

Operational records and ISPOP reporting

A key point is the inspection of operational records (logbooks). Inspectors compare the data in the records with the data submitted in the Summary Operational Records via the ISPOP system (Integrated System for Fulfilling Reporting Obligations). Any discrepancy is a signal for an in-depth audit.

Emission measurement reports

You must present valid reports of authorized emission measurements (one-off) or records from continuous monitoring. Compliance with measurement intervals, which are typically once every 3 calendar years under Czech legislation, is crucial.

Technical condition of equipment

A physical inspection of the source reveals leaks, corrosion, clogged filters, or unauthorized technological modifications. Inspectors verify whether the condition matches the description in the operating rules.

Operator knowledge

Inspectors may ask questions directly to the equipment operators to verify if they know the procedures specified in the operating rules. A discrepancy between an employee's answer and the text of the rules is evidence of a dysfunctional training system. Our attorneys in Prague will prepare you for this process.

Related questions regarding preparation for a ČIŽP inspection

1. What to do if inspectors arrive unannounced?
Inspectors have the right to enter the premises. Your obligation is to provide cooperation. However, contact your legal representative immediately. You have the right to request that the inspectors wait for the arrival of a responsible representative or lawyer, provided this does not defeat the purpose of the inspection.

2. Can I be present during the inspection?
Yes, the operator (or their representative) has the right to be present during all inspection activities, including sampling or reviewing documentation. According to the Czech Inspection Code (Act No. 255/2012 Coll.), you must prove that you are an authorized person.

3. What if the inspectors find a deficiency?
The result is an inspection report. You can file objections against the inspection findings stated in the report within the deadline set by the inspector (by law, this is usually 15 days unless specified otherwise). Well-drafted objections are crucial for the further development of any potential sanction proceedings in the Czech Republic.

How to prepare and minimize risks

Prevention is always cheaper than fines. Here are the steps you should take.

Step 1: Legal and technical audit of documentation

Verify whether your operating rules correspond to the current state of the equipment and the legislation in force in 2026. If you have made any technical changes, it is likely that the rules are outdated. The ARROWS law firm in Prague will conduct an audit of your permits and identify discrepancies.

Step 2: Review of operational record keeping

Check whether the records are kept properly, legibly, and to the extent required by Czech Decree No. 415/2012 Coll. Focus on the verifiability of data regarding raw material and fuel consumption.

Step 3: Employee training

Ensure demonstrable training of operators. Have employees sign an attendance sheet with a clearly defined training content, which must include specific familiarization with the operating rules.

Step 4: Verification of emission measurements

Check the dates of the last emission measurements and verify if the deadline is approaching. Late measurement is a common administrative offense in the Czech Republic, so book a measurement group in advance.

Legislative environment in 2026 and impact on operating rules

Environmental legislation is constantly tightening in accordance with EU directives (e.g., the Industrial Emissions Directive IED). In 2026, emphasis is placed on the following areas in the Czech Republic.

Tightening of emission limits and BAT

For large sources (IPPC), Best Available Techniques (BAT) Conclusions are continuously applied, which may tighten emission limits or introduce new monitoring requirements. Operating rules must reflect these changes.

Digitalization and ISPOP

Reporting obligations via the Integrated System for Fulfilling Reporting Obligations (ISPOP) are strictly enforced. Data in the operating rules must correspond with the data in the system.

Categorization of sources

It is necessary to monitor whether an amendment to Annex No. 2 of the Czech Air Protection Act has changed the categorization of your source. A change in category may mean new obligations, such as the requirement to have operating rules even for a source that did not previously require them.

Errors in updating rules and how to avoid them

Errors in documentation preparation often lead to the rejection of applications or heavy fines for operations that conflict with approved conditions under Czech law.

Error No. 1: Universal Templates

Using a template downloaded from the internet is risky. Operating rules must be "tailor-made" to the specific technology and local conditions in the Czech Republic. Regional authorities typically return generic texts for revision.

Error No. 2: Ignoring Conditions of Binding Opinions

When permitting a construction or a change in use, the Czech air protection authority issues a binding opinion with specific conditions. These conditions must be incorporated into the operating rules. Overlooking them is a frequent mistake.

Error No. 3: Insufficient Description of Emergency Situations

In practice, specific procedures for emergencies are often missing. It is not enough to state "we will call the fire department." It is necessary to describe steps to minimize the leakage of emissions into the surroundings under Czech environmental standards.

Practical Steps: How to Proceed with Updating Operating Rules

Updating operating rules is a complex process that must reflect not only technical changes at the source but also the current methodological requirements of Czech air protection authorities. 

Phase 1: Legal and Technical Analysis

The first step is the collection of data regarding the technology, safety data sheets for raw materials, project documentation, and existing permits issued in the Czech Republic.

Phase 2: Drafting the Proposal

This is followed by drafting the operating rules in accordance with Annex No. 12 of Decree No. 415/2012 Coll. Collaboration between a technologist and our Czech legal team is crucial here.

Phase 3: Approval Proceedings

An application for the issuance or amendment of an operating permit is submitted to the locally competent Regional Authority, or the Prague City Hall. Other documents, such as a dispersion study or an expert opinion, if required under Czech legislation, are attached to the application.

Phase 4: Implementation

Once the decision becomes legally binding, it is necessary to familiarize the operators with the rules and implement new operational records.

Situation / Risk	How ARROWS (office@arws.cz) Assists
Integrated Permit (IPPC) and BAT: Non-compliance of technology with Best Available Techniques requirements. Risk of permit revision and necessary investments.	Expert Assistance during Integrated Permit Revisions: Our Prague-based attorneys provide legal support during the revision of integrated permits.
Accidents with Substance Leakage: Risk of high fines, damages, and criminal liability for management.	Crisis Legal Representation during Accidents and Failures: We provide legal representation during accident investigations and communication with the Czech Police.
Change of Owner/Operator: Operating permits are non-transferable (for standard sources); the new operator must re-apply (transfer of rights is only possible in specific cases under Czech commercial law).	We ensure the correct legal procedure during plant transfers or mergers.

How to Defend Your Business During Inspections and After Deficiencies are Identified

A proper strategy when dealing with Czech supervisory authorities and the timely application of your arguments can fundamentally influence the final outcome of an investigation.

During the Inspection: An Active Approach

Ensure that inspectors record facts in your favor in the protocol. An example could be a record stating that a defect was immediately rectified or that no emissions leaked. Do not sign anything you do not understand without consulting our Prague-based attorneys.

After the Inspection: Objections to the Protocol

The inspection protocol is a key piece of evidence. If you disagree with it, you must file written and reasoned objections within the set deadline, which is usually 15 days in the Czech Republic. Successful objections can lead to a change in the inspection findings and avert a fine.

Administrative Proceedings Regarding Fines

If proceedings regarding an administrative offense are initiated, it is necessary to choose an appropriate procedural strategy. Arguments can be made regarding the failure to meet the material aspect of the offense, mitigating circumstances, or procedural flaws in the inspection. The attorneys at ARROWS law firm in Prague are specialists in Czech administrative criminal law.

Conclusion

Operating rules are a living document that must reflect the reality of your operations and the current Czech legislation of 2026. Neglecting them is a gamble with the company's existence. The risk of fines in the millions of CZK is real but preventable.

A preventive legal audit and update of operating rules is an investment that pays off, as the attorneys at ARROWS law firm in Prague ensure bulletproof documentation. Our legal team has experience with dozens of proceedings before Czech regional authorities and the Czech Environmental Inspectorate (ČIŽP).

If you are unsure whether your rules are in order, contact office@arws.cz for a non-binding consultation.

FAQ – Most Frequent Legal Questions Regarding Operating Rules

1. Do I need operating rules even for a small source?
It depends on the classification of the source according to Annex No. 2 of Act No. 201/2012 Coll. Even smaller sources, such as gas boiler rooms over 300 kW or certain paint shops and carpentry workshops, may be listed sources with the obligation to have operating rules. Contact us for an assessment.

2. How long does the approval of operating rules take?
The administrative deadline is 30 days, or 60 days in more complex cases. In practice, proceedings in the Czech Republic can take 2–3 months if the authority requires additional documentation.

3. Am I at risk of a fine if I lost the rules?
Yes, the operator is obliged to present the operating rules during an inspection. If you do not have them, it is an administrative offense. We recommend immediately requesting a copy from the file at the regional authority or starting the process of creating new rules.

4. Who can prepare operating rules?
Czech law does not require special authorization for the drafter (unlike for expert opinions or measurements), but it does require professional knowledge of technology and legislation. Legal-technical quality is key for smooth approval.

5. Is it possible to appeal against a fine from the ČIŽP?
Yes, an appeal can be filed against a decision to impose a fine with the Czech Ministry of the Environment. The appeal has a suspensive effect, so you do not pay the fine yet. The success of the appeal depends on the quality of the legal argumentation.

6. Do you also cooperate with in-house legal counsel?
Yes, ARROWS law firm in Prague commonly provides specialized support to in-house counsel in the field of Czech environmental law (EIA, IPPC, waste, air), where deep expertise is required. Write to us at office@arws.cz.

Disclaimer: The information contained in this article is for general informational purposes only and serves as a basic guide to the subject matter. While we strive for maximum accuracy, Czech legislation and its interpretation evolve over time. To verify the current wording of regulations and their application to your specific situation, it is essential to contact ARROWS law firm in Prague directly (office@arws.cz). We accept no liability for any damages or complications arising from the independent use of information in this article without our prior individual legal consultation and professional assessment. Every case requires a tailored solution under the Czech legal system; therefore, please do not hesitate to contact us.

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