The social welfare implications of industry self-auditing

The Environmental Protection Agency's (EPA's) audit policy authorizes reduced penalties for firms that voluntarily undertake compliance audits and then correct and report any discovered violations to the agency. While the EPA claims the policy is a success, this paper joins a growing literature in questioning that claim. A game-theoretic model of the audit policy is developed where the goal of enforcement is remediation and the agency is unable to commit to a pre-announced inspection policy. Self-auditing is beneficial because it permits both self-reporting and self-policing to occur; however additional costs are imposed on firms. Self-auditing is more likely to be socially beneficial when the damages caused by violations are large. The current audit policy explicitly excludes violations that result in serious actual or potential harm. When violations are small, as most current disclosures under the audit policy are, firm self-auditing is likely to increase social costs.