2026 HVAC Compliance Checklist: 23 Things to Verify Before Your Next EPA Audit
An EPA inspection does not announce itself weeks in advance. When an inspector arrives — often triggered by a whistleblower report or a routine compliance review — they expect organized, complete documentation covering every regulated system your business services.
This checklist covers every obligation under the AIM Act’s Subpart C (40 CFR Part 84) and the ongoing Section 608 requirements that still apply to ozone-depleting substances. Work through it systematically. Any item you cannot check off represents a gap in your compliance posture — and potential violation exposure during an inspection.
The full checklist is also available as a downloadable PDF you can print and keep in your office or share with your team.
Equipment inventory (Items 1–5)
1. Every system with 15+ pounds of HFC refrigerant is documented. Your equipment inventory must include every appliance you service that contains 15 pounds or more of a regulated HFC refrigerant with a GWP above 53. This is the foundational document — if a system is missing from your inventory, every service event on that system is undocumented. Walk your customer locations and verify your inventory against physical equipment.
2. Each system record includes refrigerant type and full charge weight. The leak rate calculation requires the full charge as the denominator. If your records show a system exists but do not specify whether it contains R-410A or R-404A, or whether the full charge is 18 pounds or 45 pounds, your leak rate calculations are unreliable and potentially indefensible during an audit.
3. Each system is categorized correctly. Systems must be classified as comfort cooling (10% threshold), commercial refrigeration (20% threshold), or industrial process refrigeration (30% threshold). The category determines which leak rate threshold applies. A system misclassified as industrial (30%) when it should be commercial refrigeration (20%) could exceed its actual threshold without triggering required repairs.
4. Installation dates are recorded for systems with 1,500+ lb charges. The ALD requirement’s compliance deadline depends on when the system was installed. Systems installed between 2017 and 2025 must have ALD by January 2027. Systems installed before 2017 are exempt from ALD. Without recorded installation dates, you cannot demonstrate which deadline applies.
5. ODS systems are identified separately. Systems using ozone-depleting substances (R-22, R-502, R-12) are regulated under Section 608, not the AIM Act. Your inventory should clearly distinguish ODS systems from HFC systems, as different thresholds and requirements apply. If a system has been converted from ODS to HFC, the record should reflect the current refrigerant type.
Service documentation (Items 6–11)
6. Every refrigerant addition is logged with date and amount. There should be no refrigerant additions to regulated systems that are not documented. Every addition, regardless of how small, must be recorded with the date and the amount in pounds. Cross-reference your service logs against refrigerant purchase records and technician schedules to identify potential gaps.
7. Each service entry identifies the technician. The AIM Act requires technician identification (name and contact information) on every service record. This is not optional and is not satisfied by entries that say “service performed” without identifying who performed it.
8. Leak rate is calculated for every refrigerant addition. It is not enough to record that refrigerant was added. Each entry must include the calculated leak rate using either the annualizing method or rolling average method, the applicable threshold for the system type, and a determination of whether the threshold was exceeded. See our leak rate calculation guide for the formulas and worked examples.
9. The calculation method is documented. Your records should indicate which method (annualizing or rolling average) was used for each calculation. If you switch methods between calculations for the same system, document the reason. Consistency strengthens audit credibility.
10. Refrigerant source is tracked. The AIM Act includes provisions for tracking where refrigerant comes from. Document whether the refrigerant came from company stock, a supply house, was customer-provided, or was recovered on-site. This data becomes increasingly important as reclamation requirements phase in.
11. Records are retained for at least 3 years. Verify that service records from 3 years ago are still accessible and organized. If you switched service management systems, changed tracking methods, or had a data loss event, records from the transition period may be incomplete. Address gaps proactively rather than discovering them during an inspection.
Leak repair compliance (Items 12–16)
12. Every threshold exceedance has a documented repair. Search your records for every instance where a leak rate calculation exceeded the applicable threshold (10%, 20%, or 30%). Each one should have a corresponding repair record. Missing repair documentation for a threshold exceedance is a clear violation.
13. Repairs were completed within 30 days. For each threshold exceedance, verify that the repair was completed and documented within 30 calendar days of the triggering calculation. The repair date, method, and technician should be documented.
14. Verification tests are documented. After each repair, a verification test must confirm that the leak rate dropped below the applicable threshold. The verification test date, method, and results must be recorded. A repair without a documented verification test is an incomplete compliance record.
15. Failed repairs have retrofit/retirement plans. If a verification test showed the repair was unsuccessful (leak rate still exceeds threshold), a retrofit or retirement plan must have been developed within 6 months. The plan should include a timeline for completion and be available for EPA review.
16. Chronic leakers are identified. Review each system’s total refrigerant additions for the current calendar year. Any system where additions exceed 125% of the full charge must be flagged for reporting to EPA by March 1 of the following year. If you are reading this mid-year, you should have a process in place to continuously monitor this metric — it cannot be reliably calculated only at year-end if service records are incomplete.
ALD compliance (Items 17–19)
17. All qualifying systems have ALD installed or scheduled. Identify every commercial or industrial refrigeration system in your service portfolio with a charge of 1,500+ pounds. For systems installed after January 1, 2026, verify ALD was installed within 30 days of commissioning. For systems installed between 2017 and 2025, confirm ALD installation is planned before the January 1, 2027 deadline. For more details, see our ALD requirements guide.
18. ALD calibration is current. For every system with ALD installed, verify that calibration was performed within the last 12 months. Calibration records must include the date, method, person performing calibration, and confirmation that detection thresholds were met.
19. ALD calibration due dates are tracked. Verify that you have a system — automated alerts, calendar reminders, or a tracking tool — to ensure ALD calibrations are not missed. A lapsed calibration creates a violation even if the ALD system is physically operational.
Technician and administrative compliance (Items 20–23)
20. All technicians hold current EPA Section 608 certification. Every technician who services regulated refrigerant systems must hold a valid Section 608 certification (Type I, II, III, or Universal depending on the equipment serviced). Maintain copies of current certifications in your compliance files. An uncertified technician servicing a regulated system creates violations for both the contractor and the technician.
21. Refrigerant purchase and recovery records are maintained. Track refrigerant purchased, refrigerant recovered, and refrigerant sent for reclamation or destruction. These records provide a cross-check against service logs — significant discrepancies between refrigerant purchased and refrigerant documented as added to systems can trigger investigation.
22. Records are organized and accessible within 5 business days. The EPA can request records and expects production within 5 business days. If your records are scattered across multiple systems, filing cabinets, or employees’ personal devices, consolidating them during a 5-day window is stressful and error-prone. Test your ability to produce a complete record set for any customer or system on demand.
23. State-specific requirements are identified and addressed. If you operate in California, New York, New Jersey, Washington, Colorado, or other states with HFC regulations that exceed federal requirements, verify that your compliance program addresses those additional obligations. State requirements may include lower GWP limits for new equipment, refrigerant sales reporting, or additional registration requirements.
The 60-second compliance check
If you cannot work through the full 23-point checklist right now, here is the minimum you should verify immediately.
Pick any single regulated system you service. Can you produce, right now, a complete record showing every refrigerant addition to that system for the past 12 months, with calculated leak rates for each addition, and documentation of any threshold exceedances and corresponding repairs? If you can produce that record in under 5 minutes for any system an inspector might ask about, your documentation is in reasonable shape. If pulling that record takes an hour of searching through files and spreadsheets, your compliance posture needs work.
RefriComply generates that record in one click. Every service event, every leak rate calculation, every alert, every repair — organized into an audit-ready PDF indexed by customer, location, and system. For an inspector or for your own peace of mind.
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