The NRC’s Office of Enforcement (OE) recently published its 2025 Enforcement Program Annual Report. During 2025, the NRC issued 71 escalated enforcement actions to licensees, nonlicensees, and individuals, which is a slight decrease from the 73 escalated enforcement actions in 2024, but slightly higher than the five-year average from 2021 to 2025.
NRC Enforcement Process
The NRC enforces regulatory compliance as a means of deterrence, as well as to encourage licensee violation identification and corrective actions. Notices of violations (NOVs) and civil penalties are the NRC’s primary enforcement tools. The NRC can also issue orders to modify, suspend, or revoke a license and to bar individuals from the industry—either for a fixed period or permanently.
Under “traditional enforcement,” violations of NRC regulations are assigned a severity level (SL) ranging from SL IV for minor violations to SL I for the most significant ones. Generally, SL IV violations are dispositioned as noncited violations, but under certain circumstances can result in an NOV. Violations that are SL I, II, or III are entered into the NRC’s escalated enforcement process, resulting in NOVs and potential civil penalties. Willful violations of NRC regulations are always subject to traditional enforcement.
For operating reactors, the Reactor Oversight Process (ROP) supplements the NRC’s enforcement process. Under the ROP, violations and inspection findings are assessed at a significance level and assigned a color—green, white, yellow, or red. Violations and findings assessed as white, yellow, or red are considered escalated enforcement actions and will result in an NOV and, under certain circumstances, a civil penalty.
2025 Enforcement Summary
Nuclear material licensees continued to receive the highest number of escalated enforcement actions, totaling 46 and accounting for 63% of all actions issued. Operating reactors received the second largest number of escalated enforcement actions with 23 actions, or 34% of all actions. The remaining two actions were related to fuel facilities.
The majority of escalated actions occurred in Region III (31 actions). Region I had 18, Region II had two, and Region IV had 16. The remaining four actions were issued by the NRC Office of International Programs (three actions) and Office of Nuclear Reactor Regulation (one action).
The most common outcome from escalated enforcement in 2025 was for the NRC to issue an NOV without civil penalties, occurring in 56 of the escalated enforcement actions, or 79%. The NRC provided in its report that it considers a large percentage of NOVs without civil penalties to be a positive outcome, as it demonstrates that most licensees identify and correct violations themselves—a goal of the Enforcement Program.
Similar to the slight decrease in the total number of enforcement actions from 2024, the number of NOVs with civil penalties slightly decreased from 14 to 12. Of these 12 enforcement actions, two involved “willfulness,” meaning deliberate misconduct or careless disregard. In total, the OE proposed $203,400 in civil penalties, which is slightly higher than the amount issued in 2024 but significantly lower than the five-year average of $311,400. According to the NRC, this is because in calendar year 2021, operating reactors (which have higher civil penalty amounts) accounted for a substantial portion of the proposed civil penalties. In contrast, no reactor licensees had a civil penalty proposed in 2025.
Morgan Lewis routinely assists licensees in connection with NRC allegations, investigations, and enforcement. We will continue closely following and reporting on these topics.