Do the 2026 leak-repair rules apply to all commercial air conditioning?

No. The requirements cover applicable appliances with a charge of at least 15 lb containing an HFC or certain substitutes; substitutes with GWP of 53 or below are excluded. The residential/light-commercial AC/heat-pump subsector is also excluded, while chillers and certain VRF systems have separate classifications. EPA January 2026 guidance

For a replacement or service proposal, ask who owns the covered appliance, who will maintain records and whether the bid includes ongoing service obligations. Keep leak-repair requirements distinct from restrictions on installing a new system and from other refrigerant-handling obligations. One answered question does not settle all three.

This pass does not provide a complete compliance calendar for every refrigeration subsector. Cold storage, supermarket and specialist process equipment require their own row-level review of EPA's current restrictions; do not reuse the comfort-cooling answer for those projects.