Authored by: Rimkus Built Environment Solutions Marketing Team
Ontario’s Energy and Water Reporting and Benchmarking (EWRB) program requires covered building owners to submit a prior-year energy and water report through ENERGY STAR Portfolio Manager by July 1. This filing is a reporting obligation, not an energy-audit requirement. Owners commonly need to confirm whether a property is covered and how to complete the filing correctly.
This guide explains who must report, what filing requires, how to request utility data, and how to navigate common pitfalls. It also clarifies how Toronto’s municipal requirement layers on top of the provincial one.
Key takeaways: What Ontario’s EWRB filing requires
Covered Ontario properties generally report annual energy and water use through ENERGY STAR Portfolio Manager by July 1, with eligibility and verification steps depending on building size and prescribed-property criteria.
What the filing covers
- Covered properties file annually based on prescribed-property, size, and ownership criteria; not size alone; eligibility is confirmed against Ontario Regulation 506/18
- The Ontario EWRB ID is a unique six-digit identifier assigned by the ministry; an incorrect ID can cause a filing rejection
- Properties of 100,000 square feet or larger require periodic verification by an accredited professional, with first-year, fifth-year, and ministerial-request verifications required
Where filings go wrong
- Missing a utility’s own data-request cutoff, which falls weeks before July 1, may leave insufficient time to compile and submit data
- Assuming a Toronto municipal filing satisfies the provincial obligation (or vice versa), when both filings are legally required
- Treating vacancy, a tenant change, or a sale as an automatic exemption, when each requires specific regulatory review and notice to the Ministry
Rimkus supports EWRB filing preparation for Ontario building owners. Contact Rimkus to discuss filing preparation for specific properties or portfolios.
Who Must Report Under EWRB?
Covered Ontario properties must report when they meet multiple criteria simultaneously: at least 50,000 square feet of gross floor area, prescribed-property use classification under Ontario Regulation 506/18, sufficient energy consumption to allow utility data reporting, and, for multi-residential buildings, 10 or more units. A property that fails just one criterion, such as a small apartment building with fewer than 10 units, falls outside the reporting requirement regardless of its size.
Covered property classes include offices, shopping centres, hotels, warehouses, and multi-residential buildings. The energy-consumption criterion ties to consumption information a utility can supply. Gross floor area is measured between principal exterior surfaces of a building’s enclosed walls, including common areas and excluding exterior or unroofed space.
For the reporting obligation, the regulation defines an owner as each owner other than a public agency, subject to exemption provisions. A condominium corporation counts as an owner in its own right, and multiple owners may bear separate compliance responsibility.
The Ontario EWRB filing is a benchmarking report that captures a year of energy and water use, not building-system conditions or retrofit opportunities. Ontario’s approach sits alongside similar benchmarking mandates other jurisdictions have adopted, and the resulting data feeds into broader ESG disclosure expectations from lenders and investors.
What’s the July 1 Filing Deadline?
For properties required to report under Ontario’s EWRB regulation, the annual submission covers the prior calendar year’s energy and water use. Accordingly, 2026 consumption data must be reported to the province by July 1, 2027. Ontario Regulation 506/18 sets July 1 of the following year as the reporting deadline; utility data-request cutoffs are administrative timelines established by individual utilities and do not change that statutory due date.
Owners should therefore work backward from the July 1 deadline and submit aggregation requests early enough to meet each utility’s processing requirements, reducing the risk of a late filing.
What Information Is Required in Portfolio Manager?
An EWRB filing identifies the property using its unique six-digit Ontario EWRB ID assigned by the ministry. This ID stays with a building through ownership changes. Filings also require the property’s Assessment Roll Number, found on the property tax bill, to confirm the EWRB ID. The ministry explicitly rejects data with mismatched IDs, making it critical to confirm the correct ID before starting a filing.
The report includes building name, address, gross floor area, property use types, and annual consumption data for each energy source and water meter: electricity, natural gas, fuel oil, propane, diesel, district energy, and water.
How to Request Whole-Building Utility Data
Where tenants hold their own utility accounts, an owner may need whole-building consumption data from the applicable utility rather than compiling individual tenant bills. Ontario Regulation 506/18 contemplates that utilities provide required consumption information within a reasonable time, though procedures and request cutoffs vary by provider. The utility’s own timeline, not the regulation’s general language, ultimately governs how early an owner needs to act.
Enbridge Gas states that EWRB data requests typically take about four weeks to process and are fulfilled between March 1 and June 1. Requests submitted after June 1 may not be completed in time for the July 1 reporting deadline. Toronto Hydro asks owners to submit requests by April 30 and to allow at least four weeks for processing. Working backward from the July 1 deadline and each utility’s stated request timeline helps provide time to review data, address gaps, and complete the Portfolio Manager submission.
What Verification Is Required for Larger Properties?
Covered properties of at least 100,000 square feet must have the reported information verified in the first reporting year, every fifth year thereafter, and when the Minister requests it. The verifier must hold an accreditation or certification recognized in Canada or the United States; the regulation does not establish a separate EWRB-specific certification. An owner’s own employee can serve as verifier if that person holds the required accreditation.
Verification is distinct from an energy audit or building-condition assessment. It focuses on validating reported figures, not assessing building systems or retrofit opportunities.
How Does Toronto’s Municipal Filing Differ?
Toronto layers its own filing on top of the provincial one through Municipal Code Chapter 367, using the same ENERGY STAR Portfolio Manager platform. A provincial EWRB filing does not satisfy the separate City requirement, and the reverse is also true; both filings must be submitted to remain in compliance. Buildings of 50,000 square feet and larger have filed with the City since 2024. The City’s smaller tier, covering buildings from 10,000 to 49,999 square feet, is set to begin mandatory reporting in 2027, after City Council postponed the start twice, from 2025 to 2026 and then to 2027.
What Are the Most Common EWRB Filing Mistakes?
EWRB filings routinely fail for predictable reasons that owners can avoid with proper planning. The most common errors cluster around three areas: timing, jurisdictional confusion, and data accuracy.
- Missing utility data-request cutoffs. Each utility sets its own request timeline regardless of the July 1 provincial deadline. Enbridge Gas fulfills EWRB data requests between March 1 and June 1, while Toronto Hydro asks owners to submit requests by April 30. Requesting data on June 15 may leave the utility unable to deliver by July 1. Working backward from July 1 to the utility’s cutoff is essential.
- Confusing provincial and Toronto municipal filings. Many owners submit to one authority and forget the other, treating them as separate optional obligations. Both filings must be completed; an owner in Toronto faces dual compliance with the provincial deadline of July 1 and the municipal deadline typically on July 2.
- Submitting incomplete EWRB IDs and missing data. Owners often fail to provide all required building characteristics or omit data for particular fuel sources. The ministry explicitly rejects filings with mismatched EWRB IDs. Confirming the correct ID before starting and verifying that all meter data is complete can help minimize rework and missed deadlines.
Planning for timing, jurisdictional clarity, and data completeness can reduce the risk of a late, rejected, or incomplete EWRB filing.
What Exemptions and Relief Provisions Exist?
Ontario Regulation 506/18 includes exemptions for public agencies occupying 50% or more of a property’s floor area, and for data centres, television studios, or manufacturing processes occupying 10% or more. Relief provisions address specific circumstances like insolvency or tax-sale proceedings but generally require written notice to the Ministry before the filing deadline.
Vacancy, partial occupancy, and ownership changes do not automatically exempt a property from reporting. Owners considering any exemption should review the regulation directly rather than assume eligibility without confirmed regulatory criteria.
What Happens if a Filing is Late or Inaccurate?
An inaccurate, incomplete, or late report can create regulatory and administrative risk. The Auditor General’s 2020 audit found that only 45% of required private-sector buildings had submitted data by the deadline, and 30% of those submissions had missing or inaccurate information.
Toronto’s Chapter 367 carries enforcement provisions including fines up to $100,000 on conviction, plus special fines equal to economic advantage obtained from non-compliance. For continuing offences, fines up to $10,000 per day apply. Owners facing filing problems should seek property-specific advice.
Energy consulting and capital planning support
To discuss EWRB filing preparation for a specific Ontario property or portfolio, contact a Rimkus Building Expert as part of the firm’s broader energy consulting practice. Owners using benchmarking data to inform longer-range decisions can also find related guidance in Rimkus’s resources on capital planning and building performance standards.
Contact Rimkus for issues with your EWRB compliance
Frequently asked questions about Ontario EWRB compliance
Do condominium buildings in Ontario have to report under EWRB?
Yes. Condominium buildings with a gross floor area of 50,000 square feet or larger must report whole-building energy and water consumption to the Province annually under Ontario Regulation 506/18, and the condominium corporation counts as an owner for reporting purposes. In Toronto, the same buildings must also report to the City under Municipal Code Chapter 367.
What should owners do if utility data is late?
Utility procedures and authorization requirements vary by provider, so owners should document their request date and follow up with the utility in writing well before July 1. If data remains unavailable as the deadline nears, EWRB Support can be reached at 1-844-274-0689 or [email protected] for guidance.
Who qualifies as an EWRB verifier?
The regulation requires a verifier to hold an accreditation or certification from a recognized accrediting body in Canada or the United States, but it does not establish a separate certification process specific to EWRB. Ministry guidance permits an owner’s own employee to serve in this role, provided that person holds the required accreditation or certification.
This article is intended to provide general information and insights into prevailing industry practices. It is not intended to constitute, and should not be relied upon as, legal, technical, or professional advice. The content does not replace consultation with a qualified expert or professional regarding the specific facts and circumstances of any particular matter.