19 Stars Out of 36: Water Companies' Worst Environmental Score Since 2011

The Worst Scorecard Since 2011

The Environment Agency's Environmental Performance Assessment (EPA) is the closest thing the sector has to an annual report card — and the 2024 results, published this month, make uncomfortable reading for every water company in England. Collectively, the nine companies scored just 19 stars out of a possible 36, down from 25 stars in 2023. It is the lowest combined score since the EPA framework began tracking performance in 2011.

The Environment Agency has responded with a call for "urgent improvement" — language it has not used this pointedly in previous years. For a sector already under intense scrutiny from Ofwat's separate wastewater enforcement programme (which has now levied more than £300 million in penalties since 2023), a second regulator publicly flagging deteriorating performance adds a further layer of pressure that is difficult for boards to ignore.

The Other Side of the Story: A Record WINEP Commitment

Here is the detail that matters for suppliers and contractors: at the same time as performance has fallen, the Water Industry National Environment Programme (WINEP) has secured a record £22.1bn environmental investment commitment from water companies for the current price review period — four times the amount committed at the previous review. WINEP is the mechanism through which environmental improvement obligations (storm overflow reduction, habitat restoration, phosphorus removal, biodiversity net gain and more) are translated into funded, deliverable capital schemes.

Put those two facts together and the picture is clear: the sector is under-performing against its environmental obligations right now, while simultaneously holding the largest ever committed budget to fix exactly that problem. That gap — between poor current performance and locked-in future spend — is where the near-term supply chain opportunity sits.

Which Companies Are Under the Most Pressure

The EA does not publish a single company-by-company star rating in the same headline format each year, but historical EPA data and the current enforcement landscape point consistently to the same operators: Thames Water, Southern Water and Yorkshire Water have the highest incident counts on record, and all three are already under separate Ofwat enforcement or heightened scrutiny. Companies facing simultaneous pressure from the EA's performance data and Ofwat's enforcement track record have the least room to defer environmental capex — for suppliers, these are the accounts where WINEP-linked procurement is most likely to accelerate rather than slip.

What It Means for the Supply Chain

A falling EPA score combined with a record WINEP settlement is a specific and unusually clear signal. The categories most likely to see accelerated procurement over the next 12–18 months include:

• Storm overflow monitoring and reduction: event duration monitors, continuous water quality monitoring (CWQM) and the civil engineering works — storm tanks, screening, network attenuation — that reduce spill frequency.
• Habitat restoration and biodiversity net gain: already a live AMP8 procurement category (see Northumbrian Water's £6.84m BNG award and Southern Water's Andover Link Main BNG contract), and one of the more direct routes to improving a company's environmental standing quickly.
• Permit compliance and self-reporting assurance: independent verification of incident data and reporting processes, as companies work to demonstrate genuine improvement to the EA rather than simply meet minimum obligations.
• Nature-based and catchment-scale solutions: the EA published a policy paper in May 2026 formalising support for these approaches, with a practical design handbook due this summer — a strong signal that catchment-scale environmental contracts will be a growing WINEP category.

The Bigger Regulatory Picture

This story lands against the backdrop of the biggest regulatory shake-up since privatisation. Ofwat is being abolished, with its functions — alongside the EA's water responsibilities, Natural England and the Drinking Water Inspectorate — set to merge into a single regulator. In that transition, the EA's own performance data becomes an important part of the evidence base the new regulator inherits. A poor EPA scorecard published now is not just this year's problem for water companies; it is part of the baseline the incoming regulator will use to judge whether the sector's environmental investment is actually working.

Source: Environment Agency Environmental Performance Assessment 2024; WINEP price review settlement data. Independent analysis by Water Industry Hub. This article is for information purposes only and does not constitute legal or investment advice.