“Outdated permits complicate enforcement – updating them provides control and clarity.”
Discharge permits are often outdated or incomplete
August 24, 2025
8 min
Introduction
Discharge permits form the legal basis for regulating the release of substances into water.
They determine which substances may be discharged, in what quantities, and under which conditions.
As such, they are an essential instrument for governments to protect water quality and provide clarity to businesses.
Yet many permits no longer fully align with today’s reality. Some are outdated and insufficiently account for new substances or processes,
while others are incomplete and lack provisions needed for effective oversight.
The result: businesses operate within the rules, but harmful substances still enter the water system via legal routes.
Source: Union of Water Boards – “Water boards raise questions about strengthening the permit system.”
Caption: Permitting is a key instrument for protecting water quality – updating and strengthening are needed to keep up with new challenges.
Permits that lag behind
Many discharge permits date back to a time when knowledge of certain substances or attention to diffuse discharges was more limited than today.
New substances out of scope – Substances such as PFAS or other Zeer Zorgwekkende Stoffen (ZZS, “very concerning substances”) are often not included in older permits, as they were not yet recognized.
General conditions – Some permits contain generic norms that don’t specifically match the type of company or substances released.
Little dynamism – Permits are not always revised when processes or substances change, which can cause them to no longer reflect the current situation.
This creates a gap between the paper reality and ecological reality.
Incompleteness: not everything is included
Limited lists of substances – Many permits still focus on classic pollutants such as nutrients or heavy metals, while countless other compounds are barely covered.
Indirect routes underexposed – Permits often focus mainly on direct discharges. Indirect emissions via sewers and WWTPs (wastewater treatment plants) are less explicitly included, even though they represent a major part of the load.
Missing basic data – Information about quantities or concentrations is not always fully available, making oversight more difficult.
This means inspectors don’t always have the full toolkit to steer effectively.
Consequences for water quality and policy
Discharges within the rules – Companies discharge legally under their permits, but harmful substances still end up in the environment.
Gaps in enforcement – Without a complete picture, inspectors lack the levers to identify risks in time.
Missed opportunities for WFD goals – If permits are not up to date, meeting the 2027 chemical and ecological water quality targets of the Water Framework Directive becomes more difficult.
Trust and transparency – Clear and current permits strengthen trust among companies and citizens that discharges are managed responsibly.
Source: Het Kontakt – “Water quality in the region under pressure due to non-natural substances.”
Caption: Water quality in many regions is under pressure from non-natural substances – a growing challenge for management and oversight.
Conclusion
Discharge permits are a powerful instrument, but only when they are current and complete.
In practice, many permits are outdated or incomplete, making oversight and water protection more complex than necessary.
The urgency is clear: by updating permits to reflect today’s knowledge and substances, governments gain more control over discharges and businesses can operate with clearer rules.
This provides a solid foundation for future-proof water management and increases the chances of meeting WFD goals on time.
