How to Get an Environmental Permit in Saudi Arabia

Under Saudi Arabia's Environmental Law, an activity that has an environmental impact needs an environmental permit before it starts. For most facilities, that permit is issued by the National Center for Environmental Compliance (NCEC) through its online Permits and Licenses Platform. This article walks through how the process works, based on the executive regulations and NCEC's published service pages, and where applications commonly slow down.

Requirements are updated from time to time, so always check the current service page on ncec.gov.sa before you file.

Two permits, not one

The executive regulations distinguish between two stages:

• Permit to establish (often called the construction permit): needed before a new activity is built or an existing one is expanded or modified.
• Permit to operate: needed for the activity to run once it is built.

Holding a permit to establish does not replace the permit to operate. Plan for both from the start.

Step 1: Environmental classification

Everything depends on classification. The executive regulations for permits to establish and operate activities divide activities into three categories according to their environmental impact:

• Category 1: low environmental impact.
• Category 2: medium environmental impact.
• Category 3: high environmental impact.

According to MEWA's announcement of the regulation, NCEC classifies activities (or reviews their classification) based on factors including the type and size of the activity, the energy it uses, its consumption of natural resources, land use, sensitive receptors around the site, and the characteristics of its environmental impacts.

The applicant completes an environmental classification form describing the activity. A vague or incomplete description is one of the main reasons a file ends up in the wrong category, which then means the wrong study.

Step 2: Prepare the technical document for your category

The category decides which technical document NCEC expects. Based on NCEC's service pages for the permit to establish:

• Category 1: an environmental management plan prepared by a service provider licensed by NCEC, an environmental rehabilitation plan where the regulations require one for that activity, and an undertaking to implement the plan's findings and recommendations.
• Category 2: an environmental impact assessment (EIA) study for Category 2 activities, prepared by an NCEC-licensed service provider, plus the undertaking.
• Category 3: a scoping report for the EIA first; then, after NCEC approves the scope, a full Category 3 EIA study prepared by a licensed service provider, plus the undertaking.

For the permit to operate, NCEC's service pages list:

• Category 1: an updated operational environmental management plan and an undertaking to implement it.
• Categories 2 and 3: an environmental audit study prepared by a licensed service provider and an undertaking to implement its findings.

In every case NCEC may ask for any further requirements it considers necessary, and fees apply according to the executive regulation on fees.

Step 3: Gather the general documents

NCEC's service pages list general requirements such as:

• the completed environmental classification form;
• an official identification document: the investor's ID, the commercial registration, or the unified number for government entities without a commercial registration;
• the address of the activity's site;
• for an expansion, modification or added activity, the currently valid environmental permit.

Step 4: Submit on the platform

The steps on NCEC's service pages are the same for each permit type: log in to the Permits and Licenses Platform, choose the service, complete the form, attach the documents and submit the application. NCEC publishes a user guide for the platform.

Step 5: Review and decision

NCEC reviews the file and may come back with questions or requests for more information. Its service directory publishes an expected service duration for each service. At the time of writing, for permits to establish, these were 10 working days for Category 1, 30 working days for Category 2 and 60 working days for Category 3. Those figures run from a complete application; the time spent preparing studies and answering questions comes on top.

Published fees also vary by category, and for Category 3 they scale with the project's capital. Check the current service page for the figure that applies to you.

Where applications commonly slow down

Delays usually come from a handful of avoidable issues:

• The activity description does not match reality. The commercial registration activity name alone is not enough. The file should describe the actual processes, capacity, materials, emissions, waste and water use.
• The wrong category is assumed. Starting a Category 1 plan for an activity that NCEC places in Category 2 means redoing the work.
• The study is not prepared by a licensed provider. NCEC requires the plan or study to come from a service provider it has licensed.
• The project is split into pieces. MEWA has noted that NCEC may refuse an EIA, or cancel an earlier approval, if an applicant fragments an activity into phases in a way that prevents correct classification.
• The environmental work starts too late. The regulation expects environmental impact to be considered at the feasibility and preliminary design stage, not after the design is fixed.
• Questions go unanswered. A request for clarification that sits in someone's inbox stops the clock on your side.

After the permit

The permit comes with conditions, and the Environmental Law requires the holder to comply with them. Expect monitoring, periodic reporting and, at renewal, an updated plan or audit study. Any expansion, modification or additional activity needs its own application through the platform.

The bottom line

Getting an environmental permit is a sequence: classify correctly, prepare the right document through a licensed provider, submit a complete file and respond quickly. Most of the time lost in practice is lost before submission, in getting the classification and the technical document right.

Sources: NCEC: Construction permit, Category 1 (service page) · NCEC: Construction permit, Category 3 (service page) · NCEC: Add an activity (service page) · MEWA: Implementation of the Executive Regulations for Environmental Permits to Establish and Operate Activities