Until recently, how much energy your building used was your business alone. That era is ending. Across Canada, governments are turning energy reporting from a voluntary good practice into a legal duty, and the deadlines are now measured in months, not years.
Quebec sets a province-wide rule
The newest rule arrived this summer. On July 8, 2026, Quebec's Reglement sur la declaration obligatoire de la performance environnementale de certains batiments came into force. From January 1, 2027, owners of commercial buildings of 5,000 m2 or more, residential or mixed-use buildings of 50 units or more, and buildings owned by certain public bodies must file an annual declaration of their energy consumption with the province's environment ministry by June 30 each year. From January 1, 2028, the net widens to buildings of 2,000 m2 or more and residential buildings of 25 units or more. Tens of thousands of buildings are affected, and the stakes are real: fines can reach $1.5 million for reporting failures and $3 million for false or incomplete information.
Ontario and Toronto: the first movers
Ontario got there first. Under the Reporting of Energy Consumption and Water Use regulation (O. Reg. 506/18), owners of commercial, industrial, institutional and multi-unit residential buildings of 50,000 square feet or more must report annual energy and water use to the Ministry of Energy and Mines by July 1 each year, through ENERGY STAR Portfolio Manager. Buildings of 100,000 square feet or more must also have their data verified by a certified professional every five years. Toronto adds a municipal layer under Municipal Code Chapter 367, Building Emissions Performance: the same 50,000-square-foot threshold reports to the city as well, and buildings between 10,000 and 49,999 square feet join the program in 2027.
Vancouver: reporting, then limits
Vancouver went further than reporting. Its Annual Greenhouse Gas and Energy Limits By-law No. 13472, adopted in July 2022, requires commercial, multi-family and hotel buildings of 50,000 square feet or more to submit an annual energy and carbon report by June 1. From 2026, large commercial buildings above 100,000 square feet also face binding on-site carbon limits, starting at 25 kilograms of CO2e per square metre per year for office space and falling to zero by 2040. Reporting is the first step; limits are the second.
Montreal: disclosure since 2021
Montreal's By-law 21-042, adopted in September 2021, requires owners of buildings of 2,000 m2 or more, or with 25 dwellings or more, to disclose the sources and quantities of energy their buildings consume by June 30 each year, with a performance rating assigned to each building.
What owners should do now
The pattern is unmistakable: the same tool (ENERGY STAR Portfolio Manager), the same annual rhythm, and thresholds that fall year by year. Three practical moves will keep you ahead of it.
First, gather twelve months of consumption data by fuel type now. Utilities need weeks to supply aggregated data, so request it early, well before the June or July deadlines.
Second, check that your meters and submeters actually capture what the forms ask for. A building with one bulk meter cannot report by fuel or by tenant, and that gap is much cheaper to fix in November than in May.
Third, benchmark before you file. A number you have never seen is a number you cannot explain, to a regulator or to a tenant. Buildings that treat disclosure as a management tool rather than a form tend to find the savings first. Platforms such as Tenergen OS turn the same interval data into daily operational insight, so the annual filing becomes a byproduct of running the building well rather than a spring scramble.
Disclosure is no longer a question of if, but of when your building joins the list. The owners who prepare now will file calmly, find the waste first, and keep their options open when limits follow reporting, as they already have in Vancouver.