Authored by Rimkus Built Environment Solutions Marketing Team
Ontario’s Energy and Water Reporting and Benchmarking (EWRB) program requires large buildings to report annual energy and water data. That reporting duty is separate from an on-site energy audit, and completing it does not, by itself, require commissioning one.
A common question is whether the annual filing satisfies every legal obligation or whether a separate audit is also required. The question is more complex in Toronto, where Chapter 367 adds a municipal reporting duty alongside the provincial rule.
This guide explains which properties must report, how a required data-verification step differs from a full commercial energy audit, and when ASHRAE audit levels become relevant to financing, incentives, or capital planning.
Key takeaways: EWRB reporting and energy audits in Ontario
Ontario’s EWRB program and Toronto’s Chapter 367 create annual reporting duties that are separate from any decision to commission an on-site energy audit. Reporting and auditing serve different purposes and follow different rules.
What the reporting rules require
- Ontario properties of 50,000 square feet or more must report energy and water use annually by July 1
- Buildings 100,000 square feet or larger must have reported data verified in the first reporting year and every fifth year thereafter, as a data-accuracy check, not a technical audit
- Toronto’s Chapter 367 adds a parallel municipal reporting duty, expanding to smaller buildings starting in 2027
When an audit becomes relevant
- ASHRAE Standard 211 defines three audit levels, from a walkthrough to a detailed capital-project analysis
- Financing applications, incentive programs such as Toronto’s Hi-RIS, and capital planning decisions commonly require an audit
- Neither regulation requires an audit solely to complete annual reporting
Rimkus supports Ontario building owners with both annual energy reporting and ASHRAE-level audits. Contact Rimkus.
EWRB reporting and energy audits: two different requirements
EWRB reporting and energy audits answer different questions. Reporting documents how much energy and water a building consumed over a calendar year and compares that consumption to similar properties.
An energy audit is a separate, on-site technical assessment that examines why a building uses energy the way it does, typically reviewing mechanical systems, the building envelope, and operating patterns. It identifies efficiency opportunities and estimates their costs and savings.
Under O. Reg. 506/18 and Toronto’s Chapter 367, covered properties report annual energy and water use to ENERGY STAR Portfolio Manager, a free tool built by the United States Environmental Protection Agency and adapted for Canada by Natural Resources Canada. The report covers January 1 through December 31 and includes gross floor area plus consumption for each energy type used, including electricity, natural gas, fuel oil, district energy, and water.
Mixed-use buildings report floor area separately for each use type, and the result is a benchmarking report showing how a building performed against comparable buildings in its sector.
Buildings of 100,000 square feet or larger have an added step: a certified professional, such as a professional engineer, registered architect, or certified energy auditor, must verify the reported data once every five years and every fifth year thereafter. That verification confirms the entered figures are accurate and reasonable for the building. It does not evaluate building systems or identify savings opportunities, and it is not equivalent to an energy audit.
Meeting the annual reporting obligation, including verification where required, does not require a separate ASHRAE-level audit.
Reporting thresholds for Ontario buildings
Prescribed Ontario properties, such as offices, retail, hotels, warehouses, and multi-unit residential buildings, of 50,000 square feet or more, must report energy and water use annually by July 1.
Toronto’s Chapter 367 adds a parallel municipal duty at the same threshold. The City has confirmed plans to extend reporting to buildings between 10,000 and 49,999 square feet starting in 2027, after City Council postponed the start twice, from 2025 to 2026 and then to 2027.
Ownership, occupancy, and exemption provisions can affect whether a specific property must report, and Ontario’s exemption criteria, phased rollout, and Toronto’s filing mechanics involve enough detail, including several eligibility and exemption categories, that they sit outside the scope of this guide.
Meeting the reporting threshold determines whether a building has an annual filing duty; it does not, on its own, determine whether that building needs an on-site energy audit.
For property managers and facilities teams, the distinction also matters for budgeting. Annual reporting is a recurring administrative task that generally fits within routine operating expenses, while an energy audit is a discrete engagement, typically scoped and budgeted separately and tied to a specific capital or financing decision rather than a fixed annual cycle.
When an energy audit becomes relevant
An energy audit becomes relevant when a decision beyond annual reporting requires it. Financing applications, incentive programs, and capital retrofit decisions are the most common triggers, since benchmarking data alone typically cannot answer the questions a lender, program administrator, or chief financial officer will ask.
Toronto’s High-Rise Retrofit Improvement Support (Hi-RIS) program is a direct example. It requires an energy assessment meeting ASHRAE Level 2 or above, prepared by a qualified energy auditor independent of the applicant, as part of a qualifying application for older multi-unit residential buildings. Other financing and incentive programs commonly ask for similar documentation, and requirements can change, so owners should confirm current technical and credential criteria directly with each program before applying.
An audit can also help explain energy use that looks unusual relative to similar buildings, a signal that benchmarking data can surface but not fully diagnose. Portfolio Manager data collected for EWRB compliance can serve as a useful starting point for scoping that audit, since the platform can calculate energy use intensity for any reporting property and, for eligible property types, generate an ENERGY STAR score for peer comparison.
A low score or an intensity well above a building’s peer group may warrant a closer look, though identifying which systems are driving the gap typically requires the walkthrough and system review that only an on-site audit provides. Reporting and an audit can also draw on overlapping utility and building data, so coordinating data collection between the two may reduce duplicate requests to building staff and utility providers.
From an asset-protection perspective, audit findings can also support longer-term capital planning. Identifying which building systems are approaching the end of their useful life alongside opportunities for efficiency gains can help an owner sequence upgrades rather than addressing each system in isolation.
Timing matters as much as the trigger. A Level 2 or Level 3 report can take several weeks from the initial site visit to a finished report, so an owner preparing a financing application or incentive submission generally benefits from commissioning the audit well ahead of the program deadline. Most programs will not accept a report still in draft, and building the audit into the project timeline early tends to avoid the scramble that comes with a compressed review window.
ASHRAE audit levels for commercial buildings
ASHRAE Standard 211 establishes procedures for commercial-building Energy Audit Levels 1, 2, and 3. The levels are cumulative, so a Level 2 audit includes the Level 1 requirements, and a Level 3 audit builds on both earlier levels.
Every level requires a qualified auditor to visit the site, identify and qualify efficiency measures, complete quality assurance, present results to the owner, and sign the standard’s compliance form. Level 3 also carries its own risk-assessment requirement.
A Level 1 audit combines a review of utility bills, typically covering 12 to 36 months, with a building walkthrough that can often be completed in a single day. The resulting report flags no-cost, low-cost, and capital-project opportunities for further review.
A Level 2 audit adds a heating, ventilation, and air conditioning (HVAC) system assessment and other system-level breakdowns of energy use, along with a financial analysis of the recommended measures. It also documents measures the auditor considered but did not recommend, and sets out a plan for measuring and confirming savings. Owners commonly select Level 2 when they need detailed, quantified findings to support capital planning, since programs like Hi-RIS require an energy assessment at Level 2 or above, and its findings tend to hold up when a lender or program reviewer asks how a savings estimate was built.
A Level 3 audit applies more detailed analysis to selected measures, including schematics and specifications for each major measure. Owners typically use it when a large capital decision calls for greater confidence in the findings. Industry practitioners sometimes describe this level informally as an investment-grade analysis, though Standard 211 itself does not use that term.
Choosing among the three levels
The decision an owner is trying to make usually points to the right level before cost does. A Level 1 walkthrough suits an owner who wants a general sense of where opportunities sit without committing to a financing application.
Level 2 fits most financing and incentive scenarios, since programs like Hi-RIS require an energy assessment at Level 2 or above. Level 3 suits situations where the capital outlay is large enough that an inaccurate savings estimate carries real financial risk, such as a major mechanical replacement or a multi-building retrofit program.
Moving between levels changes the underlying analysis, not just its length, so owners should expect the auditor’s time on site and the resulting report to scale accordingly rather than assume a Level 3 report is simply a longer version of a Level 2 one.
Preparing for a commercial energy audit
A typical audit preparation package includes utility data, building documents, equipment records, and named on-site contacts. Much of that material overlaps with the annual provincial filing, so owners who keep Portfolio Manager current may be better positioned when preparing for an audit. Findings from either process can also feed into broader capital planning and retro-commissioning decisions.
Materials auditors commonly request include utility data for every energy source over the period the audit level requires, as-built drawings and specifications, a prior building condition assessment if one exists, an inventory of energy-consuming equipment with run times and temperature settings, and occupancy details for each space type. Assembling this package before the audit begins can shorten the site visit and reduce follow-up data requests.
An owner working with multiple properties can often reuse much of the same document set across similar buildings, adjusting for building-specific equipment and occupancy details, which tends to make a portfolio-wide audit program faster to execute than treating each building as a standalone engagement.
Engineering support for Ontario energy reporting and audits
Rimkus provides engineering support for annual energy reporting, data verification, and on-site ASHRAE-level audits across Ontario. Contact Rimkus to discuss energy reporting or an audit for a specific building.
Frequently asked questions about Ontario energy audit and reporting requirements
What are the typical costs of commercial building energy audits in Ontario, and how can owners evaluate the return on investment?
Costs vary by building size, complexity, and the ASHRAE audit level selected, so owners typically request a written scope before committing to a project. Return is generally assessed against projected savings and available incentives using measures such as simple payback.
How can commercial landlords and tenants in Ontario collaborate on energy audits and cost-sharing for efficiency improvements?
Landlords and tenants can coordinate utility data access and site access through a written project scope agreed before work begins. How audit and retrofit costs are allocated typically depends on the applicable lease terms.
How do heritage or older commercial buildings in Ontario require special considerations in energy audits and retrofit planning?
Designated heritage properties may require municipal heritage review for work affecting protected features, so retrofit planning should account for that process alongside the energy audit. Compatible measures often include control adjustments and HVAC tuning, which can reduce energy use without altering historic building fabric.
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.