Reporting is mandatory, annual, and enforced by regulation. This page sets out exactly which buildings are covered, what the deadlines are, and what changes in 2027 — including the threshold drop that brings thousands of mid-sized Toronto buildings into scope for the first time.
Energy and Water Reporting and Benchmarking requires large buildings in Ontario to measure their annual energy and water use and report it to the province through ENERGY STAR Portfolio Manager. It is set out in Ontario Regulation 506/18, and the City of Toronto operates its own stricter bylaw on top of it.
It is not an audit. It is a disclosure obligation — but it is frequently what prompts an audit, because it is the first time many owners see how their building compares to its peers.
| Requirement | Applies to | Deadline |
|---|---|---|
| Ontario EWRB annual report | Commercial, institutional and multi-unit residential buildings of 50,000 sq ft and over | 1 July, annually |
| Ontario verification | Buildings of 100,000 sq ft and over | First year, then every five years |
| City of Toronto EWRB | 50,000 sq ft and over — no building-type exemptions | 2 July, annually |
| Toronto threshold drop | 10,000 – 49,999 sq ft enters mandatory scope | First report 2 July 2027 |
The City of Toronto applies no building-type exemptions. A building that is exempt under the provincial regulation may still be required to report to the City. Do not assume a provincial exemption covers you if your building is in Toronto.
From 2027, Toronto's reporting threshold drops from 50,000 square feet to 10,000 square feet. The first report under the new threshold is due 2 July 2027.
That brings thousands of mid-sized buildings into mandatory reporting for the first time — buildings whose owners have never used Portfolio Manager, have never aggregated tenant utility data, and in many cases do not know the obligation exists.
A benchmarking submission reports a full calendar year of energy and water data. To file on 2 July 2027 you need complete data for the preceding year, which means the account set-up, meter mapping and data collection have to be working before that year begins.
Owners who wait until spring 2027 will find themselves trying to reconstruct twelve months of utility history from paper bills, across multiple tenants and meters, in a few weeks. It is achievable. It is not pleasant, and it is considerably more expensive.
No. Benchmarking measures and reports consumption. An audit investigates why consumption is what it is and what to do about it. Benchmarking frequently leads to an audit, because a poor score is usually the reason an owner calls us.
It is a regulatory requirement, and non-compliance is a matter for the relevant authority. Beyond enforcement, reported data is publicly disclosed in some jurisdictions, and lenders, tenants and purchasers increasingly ask for it during due diligence.
Yes, and you must. Whole-building data can be assembled through utility aggregation services, tenant consent, or lease provisions that require data sharing. This is routine work and it is one of the main reasons owners outsource the filing.
Not today. Thresholds have moved downward consistently, so it is worth re-checking each year — but there is no current obligation at that size.
No. Toronto's BEPS is frequently described online as being in force. It is not — it remains in development. We will tell you when a requirement is real and when it is not.
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A compliance deadline, an incentive application, a financing requirement, or a capital plan. Tell us which, and we will tell you what you need and what it will cost — as a fixed fee, before any work starts.
If you do not need an audit, we will say so.