Which Toronto buildings must report energy use?

Buildings of 50,000 square feet and over report annually to the City of Toronto, with no building-type exemptions. From 2027 the threshold drops to 10,000 square feet, with the first report due 2 July 2027.

Is Toronto's Building Emissions Performance Standard in force?

No. Toronto's BEPS is frequently described online as being in force. It remains in development. We will tell you what is real and what is not.

Commercial Energy Audit Toronto | EWRB & ASHRAE

Q: Is Toronto's requirement different from Ontario's?

Yes. Toronto applies no building-type exemptions, so a building exempt under the provincial regulation may still be required to report to the City. They are also separate submissions, with deadlines one day apart.

Toronto's reporting regime

Two obligations apply to commercial property in Toronto, and owners routinely satisfy one while missing the other.

Toronto and provincial obligations
Requirement	Threshold	Deadline
Ontario EWRB	50,000 sq ft and over	1 July, annually
City of Toronto EWRB	50,000 sq ft and over, no exemptions	2 July, annually
Verification	100,000 sq ft and over	Every five years
Toronto threshold drop	10,000 – 49,999 sq ft	First report 2 July 2027

The exemption trap

The City of Toronto applies no building-type exemptions. A building exempt under the provincial regulation may still be required to report to the City. Confirming provincial exemption is not the same as confirming you have no obligation.

Why 2027 matters now

From 2027, Toronto's threshold drops to 10,000 square feet — bringing thousands of mid-sized buildings into mandatory reporting for the first time. Most of those owners have never used ENERGY STAR Portfolio Manager, have never aggregated tenant utility data, and in many cases do not know the obligation is coming.

A benchmarking submission reports a full calendar year. Filing on 2 July 2027 means the account, the meter mapping and the data collection all need to be working before that year begins. Owners who start in spring 2027 will be reconstructing twelve months of utility history from paper bills across multiple tenants, in a few weeks.

Toronto's building stock

The city's commercial inventory is unusually varied, and the audit approach differs sharply across it:

Financial District towers — central plant, district energy connections, sophisticated BAS, and tenant metering structures that complicate whole-building data
Mid-century office — the buildings entering scope in 2027, frequently with original envelopes and drifted controls
Converted industrial — the brick-and-beam stock across the east and west ends, where envelope performance dominates
High-rise residential — a large share of the city's floor area, facing both reporting obligations and MLI Select financing opportunities
Institutional — school boards, places of worship, hospitals and municipal buildings across all 25 wards

What we do in Toronto

City of Toronto and provincial EWRB reporting, filed separately as required
Third-party verification for buildings of 100,000 sq ft and over
Portfolio Manager set-up ahead of the 2027 threshold change
ASHRAE Level 1, 2 and 3 audits
Retro-commissioning, envelope assessment and energy modelling
Save on Energy and Enbridge incentive applications, including pre-approval

Getting ahead of it

If your Toronto building is between 10,000 and 49,999 square feet, the useful thing to do this year is not to file anything. It is to get Portfolio Manager set up and the data flowing, so that when the reporting year begins you are collecting rather than reconstructing.

That work is not expensive and it is not urgent in the panicked sense. It is simply much cheaper now than in eighteen months, when every mid-sized building in the city is trying to do it at once.

Commercial Energy Audits in Toronto