Executive summary
This report provides a comprehensive overview of enforcement actions, compliance issues, and regulatory developments in the drinking water industry during Q3 and Q4 of 2024, with a forward look into AMP8 obligations.
The Inspectorate issued a range of legal instruments to address potential risks to drinking water quality and security. In total, 26 regulation 28(4) notices were served to mitigate potential risks identified in water safety plans, alongside five final enforcement orders under section 18 of the Water Industry Act 1991 (the Act), and five undertakings under section 19(1) of the Act. Notably, Southern Water now holds seven live final enforcement orders which is a first for any water company and reflecting its systemic delivery challenges. Thames Water also received two final enforcement orders for failing to formalise supported schemes under the Security and Emergency Measures Direction 2022. Additional notices targeted issues such as elevated lead levels, iron failures, Cryptosporidium risks, and structural integrity concerns at service reservoirs, with completion dates extending into AMP9 for some schemes.
Late PR24 submissions were accepted by exception, resulting in new regulation 28(4) notices for emerging risks. AMP8 priorities include PFAS mitigation strategies across multiple companies, nitrate risk management, and catchment-based approaches. For example, Anglian Water and United Utilities will install granular activated carbon treatment to address emerging PFAS contamination, while Wessex Water is implementing a hydrogeological modelling program to inform PFAS catchment management. Completion timelines for these schemes range from 2030 to 2036, reflecting the complexity and scale of interventions.
AMP8 introduces stringent targets: a maximum of 0.94 contacts per 1,000 population per water quality zone and an industry average of 0.3 by 2030. Outlier companies such as Dŵr Cymru Welsh Water and South West Water have been assigned stretching targets, while Wessex Water has aligned with industry expectations. These measures aim to drive sustained improvements and reduce variability between water company areas.
In collaboration with Ofwat, the Inspectorate formalised “Acknowledged Actions” for schemes outside its regulatory remit but deemed beneficial for public health. These include catchment investigations, disinfection resilience upgrades, and emerging contaminant studies. While not legally binding, these actions are monitored closely and may escalate to formalised delivery in response to findings or if risks change.
Technical audits revealed recurring deficiencies in filter performance, maintenance, and risk assessment practices across multiple companies. Specific issues included inadequate Powder Activated Carbon (PAC) dosing, delayed refurbishment of critical assets, and poor sampling arrangements. Enforcement was initiated where necessary to secure compliance with regulation 4. Events such as the ‘Lightshaw source change’ and ‘Oughtershaw service reservoir contamination’ highlighted gaps in risk assessment, consumer communication, and operational response, underscoring the need for timely investigations and robust asset management.
Key updates include the publication of PFAS guidance, mandating risk reduction strategies and enhanced monitoring requirements by January 2025. The Inspectorate also advanced work on Drinking Water Safety Plan guidance, emphasizing World Health Organization (WHO)-aligned approaches and improved reporting consistency under regulation 28.