PFAS in water
England now has a PFAS Plan, proposed water thresholds and more monitoring data. What it still lacks is a single PFAS limit in an effluent permit – while the EU has turned its own commitments into law.
A year ago, operators with PFAS in their discharges were watching for signs that restrictions were coming for their effluent permits.
Twelve months on, the direction of travel is clearer. The legal position in England has barely moved.
Under the Environmental Permitting Regulations 2016, there are still no specific permit conditions targeting PFAS. Law firms Fieldfisher and Pinsent Masons have both noted this in recent regulatory summaries.
PFOS remains the only PFAS with a statutory environmental quality standard (EQS) in English rivers.
No PFAS-specific limits in water company trade effluent consents have been identified [unverified – absence of public evidence, not confirmation].
What has changed is the policy framework, the evidence base and the gap between England and the EU.
Defra published the UK’s first PFAS Plan on Tuesday, 3 February 2026. For permitted operators, the relevant commitments sit in its second chapter.
The government will issue cross-sector guidance to regulators and operators on reducing PFAS emissions. It expects operators to be transparent with regulators about PFAS use and releases.
That guidance will then inform control measures, which the plan says “may include reviews of relevant environmental permits.”
Further actions commit to developing thresholds and standards for PFAS emissions to air, land and water, and to identifying best available techniques (BAT) for PFAS.
None of these actions carries a deadline.
The plan also commits to maintaining around 2,400 freshwater PFAS samples a year in England, with increases in Wales and Scotland.
The Environment Agency’s (EA) PFAS prioritisation map is due to reach the public sector by the end of 2026.
For operators, the practical message is that permit reviews are coming, but not on a timetable anyone can plan against.
The more technically significant publication came a week earlier. On Monday, 26 January 2026, the EA proposed thresholds for four PFAS in surface water.
They are 0.4 ng/L for PFOA, 0.3 ng/L for PFNA, 0.2 ng/L for PFHxS and 0.015 ng/L for PFOS. They are to be applied together, accounting for the combined effect of the four substances.
A combined threshold of 77 ng/kg applies to fish.
The EA is clear that the PFOS value does not replace the existing statutory EQS.
The thresholds are intended to inform how it understands and manages PFAS risk in surface waters, including when assessing monitoring data from regulated sites.
For laboratories, the numbers pose an obvious problem. EU guidance on the Drinking Water Directive sets a maximum limit of quantification (LOQ) of 1.5 ng/L for individual PFAS.
For PFOA, PFOS, PFHxS and PFNA, it asks for values “well below” that. A survey cited in the guidance found laboratories achieving mean LOQs of around 1.3–1.4 ng/L.
A PFOS threshold of 0.015 ng/L is roughly two orders of magnitude below that. Even the statutory PFOS EQS of 0.65 ng/L sits below routine quantification limits.
[Human review: technical inference drawn from the published figures rather than a sourced statement – confirm with a UKAS-accredited PFAS laboratory.]
Any permit condition built on these thresholds will depend on analytical capability that most commercial laboratories do not yet routinely offer.
That makes the EA’s Monitoring Certification Scheme (MCERTS) relevant. Its current standard for water sampling and chemical testing contains no PFAS-specific performance requirements [unverified – confirm with the EA].
The Drinking Water Inspectorate’s (DWI) report for 2025, published on Monday, 6 July 2026, gives the clearest picture of how PFAS data is changing.
Water companies carried out more than 666,000 individual PFAS analyses in 2025. Tier 2 concentrations were found in treated water at 82 of 989 water treatment works.
Two treated-water results exceeded the Tier 3 value of 0.1 µg/L for an individual PFAS, both at a single Southern Water works. There were none in 2024. [Human review: named company and regulatory finding.]
England and Wales still have no statutory drinking water standard for PFAS. The government has committed to consulting on one in 2026.
As of late September, no such consultation had been identified as launched [unverified – check Defra consultation pages].
Across the Channel, the past year has produced binding law. PFAS limits under the recast Drinking Water Directive have applied since Monday, 12 January 2026.
They set 0.1 µg/L for the sum of 20 PFAS and 0.5 µg/L for total PFAS.
Directive (EU) 2026/805, which entered into force on Sunday, 10 May 2026, adds a sum-of-PFAS surface water standard covering 24 PFAS plus TFA, alongside new groundwater standards.
The recast Urban Wastewater Treatment Directive requires PFAS monitoring of influent and effluent at treatment plants of 10,000 population equivalent and above. This applies where they discharge into catchments used for drinking water abstraction.
The EU also restricted PFAS in firefighting foams in October 2025.
In March 2026, the European Chemicals Agency’s (ECHA) Committee for Risk Assessment adopted its opinion on the universal PFAS restriction.
Its Committee for Socio-economic Analysis consulted on a draft opinion until Monday, 25 May 2026, and is expected to finalise it by the end of 2026.
The UK’s equivalents are mostly at the stage of consulting, considering or deciding in 2027. Its restriction on PFAS in firefighting foams under UK REACH is one example, with a government decision expected in 2027.
The absence of permit limits is not the same as the absence of risk. The EA has already used information-gathering powers on PFAS.
In 2024 it issued Regulation 61 notices to permitted airport sites. These required source surveys, a 12-month monitoring programme and surface water risk assessments.
No outcome from that exercise has been published [unverified – check with the EA].
The PFAS Plan signals that the same approach will extend to other sectors.
Operators that already hold PFAS monitoring data from their discharges, obtained with methods capable of low quantification limits, will be better placed when permit reviews arrive.
Twelve months ago, the question was whether PFAS restrictions were coming for effluent permits. The answer is still yes. What has not changed is the uncertainty over when.
IET 36.5 Sept/Oct 2026
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