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COMPARISON GUIDE
Ontario EWRB vs Toronto's energy reporting bylaw: what's the difference?
Toronto buildings can face two reporting rules. They use the same data and the same software, but different deadlines and size limits.
THE SHORT ANSWER
- Ontario's EWRB (O. Reg. 506/18) covers buildings of 50,000 sq ft and up anywhere in Ontario. Reports are due July 1.
- Toronto's bylaw covers Toronto buildings of 50,000 sq ft and up, due July 2, and adds buildings of 10,000 to 49,999 sq ft from 2027.
- A large Toronto building reports to both. Same data, same software, two submissions.
Side by side
| Ontario EWRB | City of Toronto | |
|---|---|---|
| Where | All of Ontario | City of Toronto only |
| Buildings covered | Commercial, multi-unit residential, institutional and industrial buildings of 50,000 sq ft and up | Buildings of 50,000 sq ft and up now; 10,000 to 49,999 sq ft from 2027 |
| Annual deadline | July 1 | July 2 |
| First report for smaller buildings | Not applicable | July 2, 2027 (10,000 to 49,999 sq ft) |
| Software | ENERGY STAR Portfolio Manager | ENERGY STAR Portfolio Manager |
| Data verification | Buildings of 100,000 sq ft and up, in the first reporting year and every five years | Follow City guidance for your building |
| Who can file | The owner, or a third party the owner authorizes | The owner, or a third party the owner authorizes |
What both rules ask for
Each year you report the building's energy use (electricity, natural gas and other fuels) and water use for the previous calendar year, along with basic facts about the building such as floor area and use. Everything is entered in ENERGY STAR Portfolio Manager, which calculates the building's energy use intensity and, for many building types, a 1 to 100 ENERGY STAR score.
The hard part is usually the data: getting twelve months of bills from every utility account, including tenant-metered spaces, and making sure the floor area and building use are correct. Once a Portfolio Manager account is set up properly, the same data serves both reports.
What's changing in Toronto
Toronto is extending reporting to buildings of 10,000 to 49,999 sq ft, which brings in many smaller offices, retail plazas, low-rise apartment buildings and condos for the first time. Their first report is due July 2, 2027, covering 2026 energy and water use, so the data you need is being created right now.
How to get ready
- Confirm your floor area. It decides which rules apply. Use gross floor area, not leasable area.
- List every utility account. Electricity, gas, water, and any district energy or tenant meters.
- Set up Portfolio Manager once, correctly. Or authorize someone to do it and file for you.
- Diarize July 1 and July 2. Two deadlines, a day apart, for large Toronto buildings.
- Use the score. Your benchmark shows how the building compares with its peers, and where the savings and incentives are.
New to all of this? Start with What is EWRB?, or ask us to file for you.
Sources: Ontario: report energy and water use for large buildings · City of Toronto: energy and water reporting.
Quick answers
Do Toronto buildings have to report to both Ontario and the City?
Toronto buildings of 50,000 sq ft and larger fall under both: Ontario's EWRB report is due July 1 and the City of Toronto report July 2. From 2027, Toronto buildings of 10,000 to 49,999 sq ft report to the City only.
Is the data the same for both reports?
Yes. Both use energy and water data entered in ENERGY STAR Portfolio Manager, so one well-kept account serves both. They are still separate submissions with separate deadlines.
Does a small Toronto building need data verification?
No. Verification by a certified professional applies to buildings of 100,000 sq ft and larger under Ontario's rules, in the first reporting year and every five years after.