A new regulatory framework for measuring and monitoring the energy performance of Québec’s building stock took effect on July 8, 2026, under the Regulation respecting the mandatory reporting of the environmental performance of certain buildings (the “Regulation”).
Owners of certain categories of buildings must now prepare to annually report the energy consumption of their buildings under a new mandatory disclosure and verification regime that will be phased in starting January 1, 2027, and could apply to tens of thousands of buildings across Québec.
Background
The Regulation aims to enable Québec’s environment ministry (Ministère de l’Environnement, de la Lutte contre les changements climatiques, de la Faune et des Parcs) to obtain more comprehensive data on the energy consumption of large buildings in order to support the energy transition of Québec’s building stock. With this Regulation, Québec joins several North American jurisdictions that have already adopted similar reporting frameworks, such as Toronto, Vancouver, Montréal, Ontario and New York. Similar initiatives also exist in Europe, notably in France with the Éco Énergie Tertiaire regulation and across the European Union under the Energy Performance of Buildings Directive (EPBD).
By collecting data on building energy consumption, the Regulation aims to identify the most energy-intensive buildings and guide future energy efficiency initiatives. By making such reporting mandatory, the government gains an additional tool to support its energy transition efforts.
Who Will Be Affected?
The Regulation will apply to affected buildings in two phases.
|
Starting on January 1, 2027 |
Starting on January 1, 2028 |
|
|
|
Exclusions
|
|
What Will Be Required of Owners?
Key requirements for affected owners include:
- Submit a declaration to the Minister annually, no later than June 30 (or no later than September 30 of the year of acquisition if the building was acquired less than 90 days before June 30).
- Disclose information on building characteristics, energy sources used, and related energy consumption volumes and costs.
- Retain all supporting documents relating to the declarations for seven (7) years.
- Have their declarations verified at least once every four (4) years by an independent professional who is a member of a professional order recognized by the Regulation.
Obligations of Energy Distributors
The Regulation applies not only to real estate owners but also to energy distributors. It imposes new obligations on energy distributors, including Hydro-Québec and natural gas distributors, which will be required to create digital platforms that give property owners access to the energy data they need to complete their declarations. Certain distributors will also be required to provide the Minister with information on the energy consumption of the buildings they serve.
Significant Penalties for Non-Compliance
The Regulation provides for both administrative monetary penalties and fines. Depending on the nature of the breach, fines may reach $1.5 million for certain reporting failures and up to $3 million for submitting false or incomplete information or for certain breaches attributable to energy distributors.
Owners and other stakeholders covered by the Regulation should therefore promptly review their internal processes to ensure compliance with the new requirements.
Conclusion
Although the Regulation currently governs the collection and reporting of data, it may signal stricter measures to come. This framework could therefore be the first step toward establishing environmental performance ratings and minimum standards for buildings.
Property owners, managers and developers should now determine whether their buildings will be subject to the new framework and assess the processes and systems needed to collect, store and verify the energy data that must be reported. For many organizations, these preparations will need to begin well before the first reporting deadline in 2027.
Finally, it should be noted that the draft Regulation to amend the Regulation respecting gas from renewable sources, published in the spring of 2026, will not be enacted. This project was part of the government’s plan to decarbonize the building sector, announced in November 2024, and aimed, in particular, to gradually increase the share of gas from renewable natural gas (GRS) consumed in buildings, including by imposing, in certain cases, a 100% RNG requirement for new consumers connected to the gas network. Although this draft regulation was abandoned, the issues it raised remain closely linked to the greenhouse gas emission reduction targets for the building sector, which also underpin the evolution of the regulatory framework relating to the environmental performance of buildings. These issues are now the subject of a public consultation before the Régie de l’énergie (R-4353-2026), which aims to identify the regulatory measures needed to support the continued development and use of GRS while limiting the impact on consumer rates.
