2027 CCR Rule Changes
Three federal deadlines land within a ten-month window starting January 2027: the revised Consumer Confidence Report rule takes effect January 1, 2027; PFAS initial monitoring must be completed by April 26, 2027; and Lead and Copper Rule Improvements (LCRI) compliance begins November 1, 2027. This page covers what changed in the May 2024 CCR Rule Revisions (89 FR 46013, May 24, 2024), what the adjacent PFAS and LCRI deadlines require from your CCR specifically, and what to do before your first 2027 report is due.
What changed in the 2024 CCR Rule Revisions
EPA published the final Consumer Confidence Report Rule Revisions on May 24, 2024 (document ID 2024-10919, 89 FR 46013). The statutory authority runs from the Safe Drinking Water Act of 1996 (Pub. L. 104-182, codified at 42 U.S.C. § 300g-3(c)(4)) through the America's Water Infrastructure Act of 2018 (AWIA, Pub. L. 115-270, § 2008), which directed EPA to revise the rule.
The rule amends 40 CFR Part 141 Subpart O, which now spans §§ 141.151 through 141.156. The addition of § 141.156 — the mandatory summary section — is new in the 2024 revisions and was not in the prior Subpart O range of §§ 141.151–141.155.
The seven substantive changes utilities need to plan for:
1. Mandatory summary at the start of every CCR. Every report must now open with a summary, displayed prominently, that covers violations, compliance status, contact information, and any public notification language. The summary must be written in plain language and may use infographics. This requirement lives at 40 CFR § 141.156, effective January 1, 2027. See the mandatory summary section page for content requirements.
2. Twice-yearly delivery for systems serving 10,000 or more persons. Systems at or above 10,000 connections must now distribute the CCR twice per calendar year. The second report is due by December 31. Per 40 CFR § 141.155(j)(2), the threshold is inclusive — if your system serves exactly 10,000 persons, you are subject to this requirement. See twice-yearly delivery for the full delivery calendar.
3. Electronic delivery methods codified. The rule formalizes the delivery options at 40 CFR § 141.155(a): mail or hand-delivery of a paper copy, mailing a notification with a direct URL to the report, emailing the report or a direct URL, and any other delivery method approved in writing by the primacy agency. Electronic delivery is not a default — it is an option, and systems using electronic methods must provide a paper copy on request.
4. Accelerated certification deadline. Once you deliver your CCR, you must certify delivery to your primacy agency within 10 days. The prior rule allowed three months. This change takes effect January 1, 2027 and applies to all CCRs covering 2026 data.
5. Two distinct translation triggers. The prior rule had a single, loosely stated translation requirement. The 2024 revisions create two separate obligations:
- Any system whose primacy agency determines that a "large proportion" of consumers have limited English proficiency must include translated content in the report. The threshold is set by the primacy agency, not by federal rule. California uses ≥ 1,000 residents or ≥ 10% of the community served. Authority: 40 CFR § 141.153(h)(3).
- Systems serving 100,000 or more persons must separately develop and annually update a written Limited English Proficiency assistance plan. The first plan is due with the first 2027 report. Authority: 40 CFR § 141.155(i).
See translation requirements for both triggers in full.
6. Lead service line inventory disclosure. Every CCR must include a statement that a service line inventory has been prepared and instructions telling consumers how to access it. If your system has a service line replacement plan, the report must reference that plan as well. Authority: 40 CFR § 141.153(h)(8)(ii)–(iii). This connects directly to the LCRI compliance requirements in 2027.
7. State compliance data reporting to EPA. Primacy agencies must now submit system-level CCR compliance monitoring data to EPA annually. This does not change what utilities put in their reports but may affect how your state primacy agency collects and tracks your submissions.
Before and after at a glance
The table below compares the pre-2027 CCR rule against obligations that apply beginning January 1, 2027, using the current 40 CFR Subpart O language (§§ 141.151–141.156).
| Requirement | Before Jan 1, 2027 | Starting Jan 1, 2027 | |---|---|---| | Delivery cadence | Once per year by July 1 (or Oct 1 for systems relying on 2nd-tier wholesale data) | Once per year by July 1 plus a second report by December 31 for systems serving ≥ 10,000 persons (§ 141.155(j)(2)) | | Electronic delivery | Permitted under some state primacy guidance; federal codification inconsistent | Codified options: mail/hand-deliver, mail-with-URL notification, email-with-link-or-attachment, plus any primacy-approved alternative method (§ 141.155(a)) | | Mandatory summary section | Not required; opening section was at utility discretion | Required at start of every CCR; plain language; may use infographics; must cover violations, contact info, and public notification triggers (§ 141.156) | | Translation | Single primacy-determined trigger for non-English content | Two triggers: (1) primacy-determined "large proportion" of LEP consumers → translated content; (2) systems serving ≥ 100,000 → annual LEP assistance plan (§§ 141.153(h)(3), 141.155(i)) | | Certification timeline | 3 months after delivery | 10 days after delivery (all system sizes) | | Lead service line disclosure | Required to report lead violations; inventory disclosure requirement not federally codified | Explicit statement that service line inventory has been prepared; consumer instructions to access it; reference to replacement plan if applicable (§ 141.153(h)(8)) | | PFAS reporting | Not required (no federal MCL pre-2024 NPDWR) | Initial monitoring data must be reported starting with CCRs covering 2027 monitoring results; MCLs enforceable April 26, 2029 (89 FR 32532) |
January 1, 2027: the new mandatory summary section
Starting with CCRs covering 2026 data (reports due by July 1, 2027), every community water system must include a summary at the beginning of the report. The requirement is at 40 CFR § 141.156, added by the May 2024 revisions.
What the summary must include:
- A brief description of what the report is
- Violations and compliance information (cross-referencing the violations table required under § 141.153(d)(6), (8), (f), and (h)(6)–(7))
- Contact information for the system's owner, operator, or designee
- If using alternative delivery: directions for consumers to request a paper copy
- If the community has LEP consumers: how to obtain translated materials
- If the report also serves as a public notification: a statement to that effect and where consumers can find the full violation details
The regulation specifies the summary "should be written in plain language and may use infographics." This is not license to skip required content — it is permission to present that content clearly.
Systems doing mid-year updates (biannual filers) must note in the mid-year report that current-year information is available.
The mandatory summary section page has a full content checklist and draft language for each required element.
Twice-yearly delivery for systems serving 10,000 or more
The AWIA of 2018 (Pub. L. 115-270, § 2008) directed EPA to require biannual delivery for large systems. The 2024 rule codified that mandate at 40 CFR § 141.155(j)(2).
The exact threshold: 10,000 or more persons served. If your system is at 10,000, you are subject to the requirement — the threshold is inclusive.
The delivery schedule:
- First report: by July 1, covering the prior calendar year's data (unchanged from the existing annual rule)
- Second report: by December 31 of the same year
The December 31 report covers the same reporting period as the July 1 report — it is not a second annual report with new data. It is a re-distribution or updated distribution of the same compliance year's report, ensuring that consumers who did not receive or engage with the July 1 report have a second opportunity to access it.
For the compliance calendar and what to include in the second distribution, see twice-yearly delivery.
10-day certification timeline
Before the 2024 revisions, utilities had three months after delivering their CCR to certify delivery to their primacy agency. Starting January 1, 2027, that window is 10 days.
The certification must confirm that the report was distributed per the requirements of 40 CFR § 141.155 and must be submitted to your primacy agency. The form and method of certification vary by state.
This change affects operational workflow, not report content. It means you need a delivery verification step — confirmation that reports went out by mail, email, posting, or other approved method — ready to submit within 10 days, not 90.
Practical implication: if your current process involves manually confirming delivery two or three months after the July 1 deadline, that process needs to move to immediately after distribution.
Translation: two distinct triggers
The pre-2024 rule had a single, state-implemented translation requirement. The 2024 revisions split this into two obligations with different thresholds and different deliverables.
Trigger 1 — Translated content in the report: If your primacy agency has determined that a "large proportion" of your consumers have limited English proficiency (LEP), your CCR must include information in the appropriate language(s). The threshold for "large proportion" is set by your primacy agency, not by federal rule. States apply this differently: California uses ≥ 1,000 residents or ≥ 10% of the community served (Cal. Health & Safety Code § 116470). Authority: 40 CFR § 141.153(h)(3).
Trigger 2 — LEP assistance plan: Systems serving 100,000 or more persons must develop a written plan describing how they provide assistance to LEP consumers. The plan must be submitted with the first 2027 report and updated annually. It does not require translated content in the report itself — it is a plan for how to respond when a consumer needs language assistance. Authority: 40 CFR § 141.155(i).
These two requirements are independent. A system serving 150,000 could trigger Trigger 2 without triggering Trigger 1, if the primacy agency has not determined that a large proportion of that population has LEP needs. Conversely, a smaller system could trigger Trigger 1 based on its community demographics.
For the primacy-agency thresholds in your state and a checklist for both triggers, see translation requirements.
Adjacent 2027 deadlines: PFAS and LCRI
Two other federal rules reach 2027 compliance milestones within months of the CCR rule effective date. Both will generate new reporting obligations in your CCR.
PFAS reporting begins in 2027
EPA finalized the PFAS National Primary Drinking Water Regulation (NPDWR) on April 26, 2024 (document ID 2024-07773, 89 FR 32532). The rule establishes:
- Individual MCLs for five PFAS compounds: PFOA at 4.0 ng/L (ppt), PFOS at 4.0 ng/L, PFNA at 10 ng/L, PFHxS at 10 ng/L, and HFPO-DA (GenX Chemicals) at 10 ng/L
- A Hazard Index of 1 (unitless) as the MCL for any mixture containing two or more of {PFHxS, PFNA, HFPO-DA, PFBS} — PFBS is regulated only through this Hazard Index and has no individual MCL
Initial monitoring must be completed by April 26, 2027 (three years after publication). Large systems must collect four quarterly samples; smaller systems collect two semi-annual samples.
MCLs become enforceable on April 26, 2029. However, monitoring results collected before 2029 must be reported in CCRs starting with the year the data is collected. If your system detects PFAS at or above a reporting threshold during 2027 monitoring, that result appears in the CCR covering the 2027 monitoring period.
For the full PFAS MCL table, Hazard Index calculation, and what to include in your CCR if results exceed thresholds, see PFAS and your CCR.
LCRI compliance begins November 1, 2027
EPA finalized the Lead and Copper Rule Improvements (LCRI) on October 8, 2024, published October 30, 2024 (document ID 2024-23549, 89 FR 86416). Compliance begins November 1, 2027 — not October 16, which was the LCRR initial inventory deadline from 2024, not the LCRI compliance date.
LCRI changes that directly affect your CCR:
- Lead action level drops from 15 µg/L to 10 µg/L. Beginning November 1, 2027, the trigger for mandatory action changes. Authority: 40 CFR § 141.80 as amended by the LCRI.
- Paired 1st-and-5th-liter sampling. Systems sampling at lead service line sites must collect both a first-liter and a fifth-liter sample. The higher of the two values determines compliance.
- Lead service line inventory must be disclosed in the CCR. As noted above, 40 CFR § 141.153(h)(8) requires your CCR to tell consumers that a service line inventory exists and how to find it.
- LSL replacement progress. LCRI requires replacing all lead and galvanized-requiring-replacement (GRR) service lines under the system's control within 10 years of the November 1, 2027 compliance date, at an average replacement rate of 10% per year.
For the full LCRI compliance calendar, sampling protocol, and CCR disclosure language, see LCRI and your 2027 CCR.
What utilities should do now
Working backward from the July 1, 2027 deadline for CCRs covering 2026 data:
By December 31, 2026:
- Confirm your system's population count. Whether you serve ≥ 10,000 persons determines biannual delivery obligations. If your count is near the threshold, use your most recent SDWA population service area figure and document it.
- Confirm whether your primacy agency has determined your community has a large proportion of LEP consumers. If you are near or above your state's threshold, contact your primacy agency before the reporting period begins.
- If you serve ≥ 100,000 persons, draft your LEP assistance plan. The first plan is due with your first 2027 report.
By January 1, 2027:
- Update your CCR template to include a mandatory summary section as required by 40 CFR § 141.156. This section must appear at the beginning of the report.
- Update your delivery tracking to support 10-day certification. Whatever log or record you use to verify that reports were distributed needs to be completed and signed within 10 days of distribution, not three months later.
- Confirm the electronic delivery method(s) your system uses match one of the codified options at 40 CFR § 141.155(a) or have been approved in writing by your primacy agency.
By April 26, 2027:
- Complete initial PFAS monitoring. If your system has not already begun planning the sample collection schedule, contact your state primacy agency for monitoring schedules and approved lab certifications.
By July 1, 2027 (first compliant CCR due):
- Include the mandatory summary section (§ 141.156)
- Include the service line inventory disclosure and access instructions (§ 141.153(h)(8))
- Apply the 10 µg/L lead action level language if LCRI has triggered any exceedances in your 2026 monitoring data
- Include any PFAS monitoring results collected in 2026 if applicable
- Certify delivery to your primacy agency within 10 days of distribution
By November 1, 2027:
- LCRI full compliance required. Lead action level at 10 µg/L becomes the standard; paired 1st-and-5th-liter sampling protocol in effect; LSL replacement obligations begin.
If you are a CA CWS, the CCR resource index includes California-specific requirements from SWRCB/DDW that run in parallel with the federal framework described here.
Last reviewed: 2026-05-03. Next scheduled review: every 3 months until Jan 1, 2027 effective date.