Building energy reporting rules in Toronto, Montreal and Vancouver: what changes through 2027

Energy benchmarking in Canada started as a provincial program in Ontario and has since become municipal policy in the country's three largest real estate markets. Each city uses ENERGY STAR Portfolio Manager, each has a size threshold that steps down over time, and each is a step toward performance standards that will eventually set limits rather than just ask for data.

If you own or manage multi-residential, commercial or institutional buildings in more than one of these cities, the differences matter. This article lays them out and explains how one validated data set serves all of them.

Toronto

Toronto also applies its own design and performance requirements to development through the Toronto Green Standard, which matters to existing buildings at the point of major renovation.

Toronto's Energy and Water Reporting by-law, under Municipal Code Chapter 367, requires owners of large buildings to report annually to the City. According to the City's page, buildings of 50,000 square feet (4,645 square metres) and larger have reported since 2024 with a July 2 deadline; buildings of 10,000 to 49,999 square feet (929 to 4,644 square metres) begin mandatory reporting in 2027, a date the City postponed from its original schedule in December 2025. Owners report descriptive information (address, property type, gross floor area, construction year) and monthly electricity, natural gas, district energy and water consumption. Buildings of 100,000 square feet and larger must have a certified professional verify their data once every five years, starting with their first reporting year.

The City describes the reporting requirement as the foundation for Building Emissions Performance Standards. As of the City's BEPS page, the standards themselves have not been approved by Council, and low-rise residential buildings of three storeys or fewer will be exempt from any BEPS proposal. The practical implication for owners of buildings in the 10,000 to 49,999 square foot band is that 2026 data may be the first year reported, so the data collection has to be in place now.

Montreal

Montreal's by-law on the disclosure and rating of greenhouse gas emissions of large buildings (by-law 21-042, adopted September 27, 2021) applies to buildings of 2,000 square metres (21,528 square feet) or larger, or with 25 or more residential units, according to the City of Montreal. Owners submit monthly energy consumption data for the whole building for the preceding calendar year by June 30, through ENERGY STAR Portfolio Manager. The by-law phased in from the largest non-residential buildings and City-owned buildings to the 2,000 square metre and 25 unit threshold, and establishes a framework for rating buildings against comparable Montreal properties, with performance thresholds anticipated under the City's climate plan.

Montreal's 25 unit threshold is the lowest in the country, and it pulls in mid-size condominium and rental buildings that would not report anywhere else. The output is framed as emissions rather than energy, so the emission factors applied to electricity and gas matter; see GHG emissions from utility data.

Vancouver

Vancouver adopted its Annual Greenhouse Gas and Energy Limits By-law on July 20, 2022, described by the Institute for Market Transformation as the first building performance standard in Canada. Reporting phased in by building class and size: commercial buildings over 100,000 square feet reported 2023 data in 2024; commercial buildings over 50,000 square feet and multi-family buildings over 100,000 square feet began in 2025; multi-family buildings over 50,000 square feet begin in 2026. Unlike Toronto and Montreal, Vancouver's by-law sets emissions limits: starting in 2026, large commercial buildings over 100,000 square feet face 25 kg CO2e per square metre per year for office space and 14 kg for retail, and from 2040 the on-site carbon limit falls to zero with a heat energy limit of 0.09 gigajoules per square metre per year.

Side by side

• Threshold. Toronto: 50,000 sq ft now, 10,000 sq ft from 2027. Montreal: 2,000 m² or 25 units. Vancouver: 100,000 sq ft, stepping to 50,000 sq ft (multi-family in 2026).
• Deadline. Toronto: July 2 (province: July 1). Montreal: June 30. Vancouver: annual, on the phase-in schedule above.
• What is reported. Toronto: energy and water. Montreal: energy converted to GHG. Vancouver: energy and carbon.
• Verification. Toronto: every five years for 100,000 sq ft and up. Montreal and Vancouver: per their by-laws and program guides.
• Limits. Toronto: not yet adopted. Montreal: rating framework, thresholds anticipated. Vancouver: GHG intensity limits for large commercial from 2026.

What owners in multiple cities should do

1. Inventory every building against every threshold, including the ones that arrive in 2026 and 2027. A 12,000 square foot Toronto building and a 30 unit Montreal building are both in scope soon or now.
2. Get every meter into one system on one calendar. The portfolio view article explains the capture path from bill PDFs and Green Button.
3. Validate before filing. Duplicate bills and missing meters are the two errors that change intensity numbers the most.
4. Keep Portfolio Manager current monthly rather than annually. VE-MAP pushes validated consumption to Portfolio Manager meters with a preview and confirmation, skipping periods already present.
5. Produce an annual benchmark report from the filed data so the filing produces a decision, not just a receipt. See what the annual benchmark report shows.

Beyond the three cities

Ontario's provincial EWRB program covers buildings of 50,000 square feet and larger across the province, and the broader public sector reports separately under O. Reg. 25/23 with conservation and demand management plans every five years (Ontario). British Columbia has a voluntary province-wide program, Building Benchmark BC, built on Portfolio Manager. Expect more municipalities to follow the Toronto model, because the by-law mechanism is now well established.

FAQ

Our Toronto building is 30,000 square feet. When is our first report?

The City's page says mandatory reporting for 10,000 to 49,999 square foot buildings begins in 2027. Confirm the data year with the City, and start collecting 2026 bills now so the first filing is complete.

Does a Montreal condo with 25 units really have to report?

The City's threshold is 2,000 square metres or 25 units or more. Check the by-law text and the City's exemptions for your building's situation.

Can one Portfolio Manager account serve all three cities?

Yes. Each city connects to or receives data from Portfolio Manager. The work is keeping the meters complete and the calendar consistent, which is the platform side of VE-MAP.