Delivering Your CCR Electronically

You no longer have to mail a paper Consumer Confidence Report to every customer. Under 40 CFR § 141.155(a), as revised by the 2024 CCR Rule Revisions (89 FR 46013, May 24, 2024), electronic delivery is a codified option — but the rule is specific about which methods qualify and what "delivery" actually means.

This page covers the four primary delivery methods, the additional channels for reaching non-bill-paying customers, the direct-URL requirement, how to handle a system that mixes paper and electronic delivery, and the record-keeping and certification timelines that attach to every distribution.

What counts as electronic delivery

Electronic delivery means using a digital channel to put the report — or a direct path to it — in front of each customer on your billing list. The 2024 revisions to 40 CFR § 141.155(a) codified electronic options that were previously addressed only in EPA's January 2013 CCR Delivery Options Memorandum. The key word throughout the rule is "directly deliver" — passive availability on a website does not satisfy the delivery requirement on its own.

Three conditions apply to every electronic method:

  1. The report must be available at the time you send the notification (§ 141.155(a)(3)).
  2. If you use any electronic method, you must provide a paper copy on request, with prominent instructions for requesting it (§ 141.155(a)(2)).
  3. You must keep the report publicly accessible online for no less than 3 years (§ 141.155(a)(4)).

If your system serves 50,000 or more persons, posting the current year's report on a publicly accessible website is also a separate, affirmative obligation under § 141.155(f) — it runs alongside, not instead of, the direct-delivery requirement.

The four primary delivery methods (with examples)

40 CFR § 141.155(a)(1) lists the approved delivery options. Any community water system must use at least one:

Method 1 — Mail or hand-deliver a paper copy The traditional route: a printed CCR sent to each customer's billing address, or hand-delivered. This satisfies "direct delivery" without any further steps. Systems with a Governor's mailing waiver (available for systems serving fewer than 10,000 persons under § 141.155(g)) may substitute notice-posting if the waiver is in place.

Method 2 — Mail a notification with a direct link to the report on a website Send a physical postcard or bill insert that contains a direct URL — a link that goes straight to the CCR document, not to your utility's homepage or a general documents page. The report must be live at that URL when the postcard is mailed (§ 141.155(a)(3)). Example: a postcard mailed with the URL yourwater.gov/ccr/2025-annual-report.pdf.

Method 3 — Email a direct link or an electronic version of the report Send each billing-list customer either a PDF of the report attached to the email, or a direct URL in the body of the email that links straight to the CCR document. The email must be sent to each customer individually — a mass-CC or BCC blast does not establish individual delivery. As with Method 2, the report must already be accessible at any linked URL at the time of sending.

Method 4 — Another direct delivery method approved in writing by your primacy agency Your state primacy agency can authorize additional methods beyond the three above. Common examples approved by various state agencies include delivery via a utility billing portal where customers log in, SMS notifications with a direct link, or distribution through community organizations or social media channels with a direct link. The key requirements remain the same: the delivery must be direct, the report must be immediately accessible, and the method must be approved in writing before you use it.

Additional channels for non-bill-paying customers

Your billing list does not cover everyone who receives water from your system. § 141.155(b) requires a good-faith effort to reach customers who do not pay bills — apartment tenants, renters, businesses served by a landlord account. The rule identifies these channels as appropriate for that effort:

These channels do not replace the direct-delivery obligation to bill-paying customers — they supplement it for the portion of your service area not captured on billing records.

What "direct URL" means and why a homepage link is not enough

Both Method 2 (mailed notification) and Method 3 (email) depend on a "direct link." The rule uses this phrase deliberately. A direct link — sometimes called a direct URL — goes directly to the CCR document itself, not to a general page where a user would then need to navigate to find the report.

Why the distinction matters: if your notification points customers to www.yourwater.gov/reports/, where they must then scroll or search to find the current year's CCR, that is not direct delivery. You have pointed them toward the report, but you have not delivered it. The regulation's requirement is direct delivery, and a homepage or document-index link introduces intermediate steps that break that chain.

In practice, a direct URL looks like one of these:

A link to your utility's homepage, your "documents" index page, or your primacy agency's general CCR-search portal does not qualify. The report must be the landing destination, not a navigation waypoint.

This same logic applies to the website-posting requirement for ≥ 50,000 systems under § 141.155(f): the posted URL must resolve to the report itself, not to a search form or index page.

Hybrid delivery: paper and electronic for the same system

Many systems mix delivery methods within a single distribution cycle — for example, mailing paper copies to customers who have not provided an email address while emailing a direct link to customers who have opted in digitally. Nothing in § 141.155(a) prohibits this, and it is common practice.

If you use a hybrid approach, keep these points in mind:

For systems with a significant non-English-speaking customer base, electronic delivery does not remove the obligation to provide translated content. Translation requirements continue to apply to the report itself regardless of delivery channel.

The mandatory summary section added by § 141.156 must appear in all distributed versions of the report — paper and electronic alike. A short-form email notice that links to the full CCR satisfies the delivery requirement only if the full CCR contains the required summary.

Record-keeping and certification timeline

Certification: 10 days after distribution

Once your system has distributed the CCR, you have 10 days to certify delivery to your primacy agency. This replaces the previous 3-month certification window and is now codified at § 141.155(c) as part of the 2024 CCR Rule Revisions (89 FR 46013). The certification must include copies of the report and a statement that distribution has occurred.

For most systems, the annual distribution deadline is July 1. That puts the certification due date at July 11 under normal circumstances. Systems using a phased or hybrid distribution that completes after July 1 should track the actual final distribution date — the 10-day clock runs from that date.

The connection between delivery method and certification matters: if your primacy agency requires proof of delivery (such as postal tracking records, email send logs, or platform delivery receipts), gather those at distribution time. Reconstructing them after the fact is harder than collecting them in the moment.

Record retention

Systems must retain copies of each annual CCR for no less than 3 years under § 141.155(a)(4), which requires the website posting to remain accessible for at least that period. (Note: verify with your primacy agency whether state rules impose a longer retention period — some states require 5 years.)

For electronic delivery, "retaining a copy" means keeping the report accessible at its original URL or in your records system in its distributed form. If you update your website and move files, the old URL should either redirect to the retained copy or the report should remain accessible through a documented path.

The certification itself — the submission to your primacy agency under § 141.155(c) — is a separate record that most primacy agencies retain on their end. Keep your own copy as well.

For a full picture of what the 2024 revisions changed, including the new mandatory summary section and the twice-yearly delivery timeline, see the 2027 rule changes overview.

Step-by-step: how to deliver your CCR electronically

These steps apply to a system using Method 3 (email with direct link) as its primary delivery method. Adjust as needed for other approved methods.

Step 1: Confirm your delivery method is on the approved list Review 40 CFR § 141.155(a)(1) and confirm your intended method is one of the four primary options, or obtain written approval from your primacy agency if you are using a Method 4 alternative. Check your state's primacy agency guidance — some states have additional requirements or restrict certain methods.

Step 2: Finalize and post the report before sending any notification Upload the finalized CCR to a stable, direct URL before you send a single notification or email. The report must be live at the time of delivery (§ 141.155(a)(3)). Test the URL from an external network to confirm it resolves to the document without requiring login.

Step 3: Verify the URL is direct, not navigational Confirm the link resolves directly to the CCR document — not to your homepage, a documents index, or a search form. Share the URL with a colleague and ask them to confirm they land on the CCR without any additional navigation steps.

Step 4: Include a paper-on-request statement in your notification Your email must prominently include instructions for how customers can request a paper copy (§ 141.155(a)(2)). This is a mandatory disclosure, not optional. A single clear sentence is enough: "To request a free paper copy of this report, contact us at [phone/email/address]."

Step 5: Send to every customer on your billing list Deliver the report individually to each billing-list customer. If your list includes customers without an email address, send those customers a paper copy or mailed notification under Method 1 or Method 2.

Step 6: Execute your good-faith effort for non-bill-paying customers Carry out at least one action from the channels listed in § 141.155(b) to reach tenants and residents not on billing records. Document what you did and when.

Step 7: Record the final distribution date and gather delivery receipts Note the date on which the last customer was reached (the later of any staggered send dates). Save email delivery logs, mail receipts, or platform send-confirmation records.

Step 8: Certify delivery to your primacy agency within 10 days Submit your certification and report copies to your primacy agency no later than 10 days after your final distribution date (§ 141.155(c)). Confirm the submission method your primacy agency requires — some use online portals, others accept email.

Step 9: Retain the report at its posted URL for at least 3 years Keep the CCR accessible at its original URL for the minimum 3-year period (§ 141.155(a)(4)). If your web infrastructure changes, ensure the file is migrated and the URL remains functional or properly redirected.

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Last reviewed: 2026-05-03. Next scheduled review: every 6 months or after EPA guidance updates.