Tracking Building Energy Use

0 Comments


The draft Regulation respecting the mandatory reporting of the environmental performance of certain buildings establishes a framework requiring the systematic collection, verification, and transmission of building energy and environmental performance data for the Minister of the Environment, the Fight Against Climate Change, Wildlife and Parks. Adopted under the Act respecting certain measures enabling the enforcement of environmental and dam safety legislation and the Act respecting the environmental performance of buildings, the Regulation aims to improve governmental knowledge of energy use in the built environment, support climate and energy efficiency objectives, and create a standardized reporting regime across Québec.

The Regulation applies primarily to large residential, commercial, and institutional buildings, while expressly excluding buildings under construction, buildings with a demolition permit, and those whose main use is agricultural or industrial. It introduces a phased implementation schedule, beginning in 2027 for public buildings (excluding municipalities), buildings of at least 5,000 m², or residential or mixed-use buildings with 50 or more dwellings, and expanding in 2028 to buildings of at least 2,000 m² or residential or mixed-use buildings with at least 25 dwellings. Owners of covered buildings, including syndicates of co-owners, emphyteutic lessees, and designated co-owners in undivided co-ownership arrangements, must submit annual declarations through a digital reporting platform by June 30 each year, with limited extensions for recently acquired properties.

These declarations must contain detailed identifying information about the building, including ownership structure, location, year of construction, total floor area, building use, and number of dwellings where applicable, as well as comprehensive data on energy consumption and costs from multiple sources over the relevant reporting period. The Regulation requires disclosure of electricity, natural gas (renewable and non-renewable), and thermal network energy use, as well as information on biomass, heating oil, propane, and other fuels, while allowing specific exclusions for separately metered uses such as electric vehicle charging, industrial processes, subway stations, telecommunications equipment, and greenhouses.

To support this reporting system, energy distributors, including Hydro-Québec and natural gas providers, must develop and administer digital platforms by December 31, 2026 to share granular consumption, cost, and power data with building owners. In parallel, various energy distributors—including electricity, natural gas, heating oil, propane, biomass, and thermal network providers—are required to submit periodic five-year reports to the Minister detailing energy supplied to buildings. The Regulation also introduces a mandatory verification regime, requiring building owners to have their declarations independently reviewed at least once every four years by a qualified professional from specified Québec professional orders, with formal verification reports attached to submissions.

Quebec (Draft) January 20, 2026
Disclaimer: Insights are for informational purposes only and does not reflect RRI’s official position or constitute legal opinion.