Let’s Talk about Cost: 2026 AIM Act Compliance Options

 

If you operate a portfolio of retail grocery stores or cold-storage facilities, you have only a few months to avoid a compliance crisis. The hard deadline: January 1, 2026. Leak detection, leak repair, and leak documentation under the AIM Act’s Emission Reduction and Reclamation (ER&R) program change from “good intention” to enforced requirement on that date. Doing nothing isn’t a strategy; it’s negligence that puts your company, shareholders, and your career at risk. Time is running short, but it is still possible to get your sites into compliance before the deadline. The easiest way to compare your compliance options is the simplest one: cost


Three ways to comply

The federal AIM Act (and all state-level rules in CA, NY, and WA) give you three legitimate paths to achieve compliance:

  1. Indirect “Whole System” Automatic Leak Detection (ALD) systems detect changes in the refrigeration appliance’s operating conditions (such as temperatures, pressures, and enthalpy values) over time to detect leaks, often using Artificial Intelligence. When it covers the full system and is audited/calibrated annually, it eliminates the need for monthly/quarterly manual leak inspections for the entire system. Multiple vendors offer this approach - some require the retrofit installation of receiver-level sensors, while others do not require any new hardware, sensors, or internet gateways onsite.

  2. Direct (sensor-based) ALD uses fixed “sniffer” sensors to detect refrigerant gas concentration in the air. Sensors must be placed near all leak-prone equipment and maintained/audited/calibrated each year by an on-site technician. And, any unmonitored portions still trigger the requirement for manual monthly/quarterly inspections (including ALL outdoor components such as rooftop condensers). In practice, that means hardware + installation + maintenance plus ongoing manual inspection labor.

  3. Manual leak inspections are exactly what they sound like: technicians inspect the entire system on a monthly or quarterly basis for refrigerant leaks using handheld leak sensors. No capex on day one, but you inherit a permanent, labor-driven operating expense that scales with your site count. Nearly all service providers offer manual leak checks as part of their service offerings.

Remember, non-compliance penalties are up to $57,000 per violation per day, with personal liability for facility managers under certain conditions. The EPA isn't issuing warnings - they're issuing fines and putting enforcement actions in place.


The bottom line: which option is the cheapest?

We gathered vendor pricing data from multiple top-20 grocery retailers, leading Direct and Indirect ALD vendors, leading maintenance (manual leak inspection) vendors, and industry experts, and the results were clear: Hardware-free whole-system ALD wins decisively (see cost breakdown below). No expensive receiver-level sensor retrofits, no installation crews, no downtime. This option offers the lowest first-year cost and the lowest 3-year cost.

Screenshot of a spreadsheet model that compares the 1-year and 3-year costs of various compliance options including indirect “whole-system” ALD with and without receiver level sensor retrofits, direct ALD, and quarterly manual leak inspections

Reach out if you would like a copy of this cost calculator to run your own numbers, along with real vendor pricing and end-user data from our research!

  • First-year cost: 

    • Whole-system (indirect) ALD systems that do NOT require receiver-level sensors are the cheapest option because they avoid expensive hardware retrofits. And, because it is “whole-system,” it lets you remove routine manual leak inspections from your budget. 

    • Manual leak inspections sit in the middle (all opex). 

    • Direct ALD is the highest cost option, due to hardware, installation, annual calibration, and the manual leak inspections that you still need to address the unmonitored portions of the refrigeration appliances (such as rooftop condensers). Not to mention the project management headache of installing retrofit sensors and miles of capillary tubing at each of your facilities…

  • Three-year cost: Same order. 

    • Whole-system (indirect) ALD that does NOT require receiver level sensors remains the lowest cost option,

    • Manual leak inspection costs rise linearly (predictably), and 

    • Direct ALD costs remain the outlier once you add sensor maintenance and ongoing manual leak inspection obligations. 

Estimated Solution Cost over Time (300 Sites)

Add indirect ALD to your 2026 budget — at no additional cost

If you’re seeking the lowest-cost option to achieve compliance before the January 1, 2026 deadline, standardize on whole-system (indirect) ALD that does NOT require receiver-level sensor retrofits. It’s the lowest cost option, even before you credit a single “soft” benefit such as lower refrigerant leak rates, fewer compliance reporting requirements, fewer maintenance emergencies, and fewer unplanned cooling outages / business interruptions.

Bonus tip: You can fully pay for indirect ALD by cancelling your quarterly/monthly manual leak inspections (which are likely already earmarked in your 2026 budget).

Want to run your own numbers? I'll share the complete cost calculator with real vendor pricing and end-user data from our research. Shoot me an email at amrit@axiomcloud.ai, and I’d be happy to send it over.


 
Amrit RobbinsALD