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Environmental Due Diligence Checklist for Commercial Property Buyers (Phase I, Phase II & More)

Environmental Due Diligence Checklist

Buying commercial property in 2026 is about more than price, location, or future tenants. An Environmental Due Diligence Checklist for Commercial Property Buyers is essential, as one overlooked environmental issue can delay financing, trigger unexpected costs, or even stop a deal entirely.

At CRG Texas Environmental Services Inc., we regularly work with commercial buyers who call us mid-transaction saying, “We didn’t think we would have environmental issues…” The truth is, environmental problems don’t usually come from negligence – they come from starting due diligence too late or not knowing what to look for.

This guide is designed to help you avoid that situation. Below is a practical, real-world environmental due diligence checklist for commercial property buyers, built for today’s market and written for people who want to protect their investment before closing.

What Environmental Due Diligence Means for Commercial Property Buyers in 2026

Environmental due diligence is the process of identifying potential environmental risks associated with a property before ownership changes hands. These risks don’t disappear after closing – they transfer to the buyer.

In today’s commercial real estate environment, environmental due diligence serves three major purposes:

  • It protects buyers from assuming unknown environmental liability
  • It satisfies lender and investor requirements
  • It provides leverage during negotiations

Unlike a standard property inspection, environmental due diligence looks at past, present, and potential future uses of the site and surrounding properties.

Environmental due diligence also plays a key role in protecting buyers from future liability under federal regulations such as the All Appropriate Inquiries (AAI) rule.

Environmental Due Diligence Checklist for Commercial Property Buyers

This checklist outlines the pre-purchase environmental due diligence steps that experienced buyers follow to avoid surprises.

Step 1: Screen the Property Early

Before ordering reports, start with a basic risk screen:

  • What was the property used for historically?
  • What businesses operated on-site or nearby?
  • Is the land developed, redeveloped, or vacant?

A quick anecdote we see often: a buyer assumes vacant land is low risk. A historical review later shows the site was once used for industrial storage decades ago. No buildings remain, but the environmental risk still does.

Early screening helps determine how much due diligence is actually needed.

Step 2: Order a Phase I Environmental Site Assessment (ESA)

A Phase I ESA is the foundation of nearly every commercial real estate environmental checklist. It is commonly required by lenders and is used to evaluate potential environmental concerns tied to the property.

A Phase I ESA typically includes:

  • Review of historical records and regulatory databases
  • A site visit by an environmental professional
  • Interviews with knowledgeable parties when available
  • Identification of potential environmental concerns

The outcome of a Phase I ESA is not a “pass” or “fail.” Instead, it identifies recognized environmental conditions (RECs) – indications that contamination may be present.

From our experience at CRG Texas, most Phase I findings do not automatically derail a deal. What matters is how those findings are evaluated and addressed.

Phase I Environmental Site Assessments are conducted in accordance with the ASTM E1527-21 Phase I Environmental Site Assessment standard, which establishes how environmental risk is evaluated.

Step 3: Understand Phase I Findings Before Reacting

One of the most common mistakes buyers make is assuming that any Phase I finding is a deal-breaker.

In reality:

  • Some RECs are historical and well-documented
  • Some risks are easily manageable
  • Some findings simply require clarification

We often help buyers interpret reports that sound alarming on paper but pose minimal real-world risk. Environmental due diligence is about understanding risk, not avoiding properties altogether.

 

Step 4: Determine Whether a Phase II ESA Is Necessary

If a Phase I ESA identifies potential environmental concerns, a Phase II ESA may be recommended. This is when actual testing takes place.

A Phase II ESA can include:

  • Soil sampling
  • Groundwater sampling
  • Laboratory analysis
  • Targeted investigation of specific areas

While buyers often worry that Phase II testing will “uncover problems,” it often does the opposite – it confirms whether a concern is real or theoretical.

We’ve worked on many projects where Phase II results showed contaminant levels below regulatory concern, allowing buyers to move forward confidently.

Step 5: Evaluate Property-Specific Environmental Considerations

A strong environmental review before buying land or buildings goes beyond Phase I and Phase II alone.

Depending on the property, additional considerations may include:

  • Asbestos or lead-based paint in older buildings
  • Vapor intrusion potential
  • Mold or moisture concerns
  • Underground or aboveground storage tanks
  • Historical fill material on undeveloped land

For land purchases, environmental review should also consider:

  • Prior agricultural use
  • Illegal dumping or fill activities
  • Adjacent industrial operations

This is where working with an experienced consultant adds real value. Not every property needs every assessment – but missing the right one can be costly.

Step 6: Align Environmental Due Diligence With Your Transaction Timeline

Timing is one of the biggest challenges in commercial transactions.

A typical due diligence timeline for real estate environmental reviews includes:

  • Phase I ESA: approximately 2-4 weeks
  • Phase II ESA (if needed): additional time depending on scope
  • Review, negotiations, and lender approvals

Environmental work should begin as soon as you are under contract, not halfway through the due diligence period.

We frequently see closings delayed simply because testing couldn’t be completed in time – not because the property had serious issues.

How Buyers Use Environmental Due Diligence Strategically

Environmental due diligence isn’t just about compliance – it’s also a negotiation tool.

Buyers commonly use findings to:

  • Renegotiate the purchase price
  • Require the seller to address environmental concerns
  • Establish environmental escrows or holdbacks
  • Extend due diligence timelines
  • Decide when walking away is the best option

Finding an issue before closing gives buyers options. Finding it after closing transfers the responsibility entirely to the new owner.

Common Environmental Due Diligence Mistakes to Avoid

Over the years, CRG Texas Environmental Services Inc. has seen a pattern of avoidable mistakes:

  • Delaying the Phase I ESA
  • Assuming vacant land is environmentally clean
  • Ignoring Phase II recommendations
  • Failing to share redevelopment plans with consultants
  • Treating environmental review as a checkbox instead of a strategy

Each of these mistakes can increase risk – and every one is preventable with early planning.

Environmental Due Diligence Checklist for Commercial Property Buyers

Use this simplified checklist as a quick reference:

  • Conduct early environmental risk screening
  • Order a Phase I ESA immediately after contract execution
  • Review historical site uses and neighboring properties
  • Evaluate Phase I findings carefully
  • Scope Phase II testing if recommended
  • Address property-specific environmental risks
  • Align environmental timelines with closing deadlines
  • Use findings to negotiate or mitigate risk

Why Buyers Work With CRG Texas Environmental Services Inc.

Environmental due diligence should bring clarity – not confusion.

At CRG Texas Environmental Services Inc., we help commercial buyers:

  • Identify the right level of environmental review
  • Stay aligned with lender and transaction timelines
  • Understand findings in plain language
  • Make informed decisions about next steps

Whether you are purchasing developed property, redeveloping an existing site, or acquiring land, starting environmental due diligence early helps protect your investment and keeps your deal moving forward.

Final Thoughts

A thorough environmental due diligence checklist for commercial property buyers is one of the most important tools you can use when purchasing commercial real estate in 2026.

Environmental issues don’t always stop deals – but ignoring them can create long-term liability. With the right planning, guidance, and timing, environmental due diligence becomes a confidence builder, not a roadblock.

Ready to Move Forward With Confidence?

If you’re buying commercial property in 2026, environmental due diligence shouldn’t be rushed or confusing.
At CRG Texas Environmental Services Inc., we help buyers understand environmental risk early, stay aligned with lender timelines, and move forward with clarity.

Whether you’re under contract or still evaluating a property, starting environmental due diligence early can protect your investment and keep your transaction on track.

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