Toronto's 2027 energy reporting rule: is your building now in scope?
Toronto is extending mandatory energy and water reporting to buildings as small as 10,000 sq ft in 2027. If you own a mid-size building in the city, here is what changes, what you have to report, and how to be ready.
For years, Toronto's energy reporting rule only touched the largest buildings. That changes in 2027. Under Municipal Code Chapter 367, the city is extending mandatory energy and water reporting down to buildings of 10,000 sq ft, which brings a large number of mid-size commercial, institutional and multi-residential buildings into scope for the first time.
What is changing in 2027
Toronto's Energy and Water Reporting bylaw phases in by building size. Buildings of 50,000 sq ft (4,645 m²) and up have reported since 2024. Buildings between 10,000 and 49,999 sq ft (929 to 4,644 m²) become mandatory in 2027. City Council postponed that first mandatory year to 2027 in December 2025, which gives owners of mid-size buildings a short runway, not a reprieve.
Mid-size offices, retail, multi-residential and institutional buildings between 10,000 and 49,999 sq ft, many of which have never had to benchmark or report before.
What you have to report
The requirement is whole-building energy and water use for the year, across every fuel and meter, submitted through ENERGY STAR Portfolio Manager. Toronto owners report to both the City of Toronto and the Ontario Ministry of Energy using the same tool, so one clean dataset covers both obligations.
- Electricity, natural gas and any other fuels, for the whole building
- Water use for the whole building
- Twelve consecutive months, in consistent units
- The correct gross floor area for each property
Why the data is the hard part
On paper the rule is simple. The work is assembling twelve months of accurate, whole-building energy and water data, across every meter and fuel, in the right units, for every building. For owners who have never benchmarked, that means finding and reading bills that were only ever paid, not analyzed. Benchmarking and data entry already runs more than $40,000 a year for just 20 buildings, and the first year is always the hardest.
How to get ready before 2027
- Confirm which of your buildings cross the 10,000 sq ft threshold.
- Gather twelve months of energy and water bills for each one.
- Get those bills into clean, structured data, not a spreadsheet that goes stale.
- Set up ENERGY STAR Portfolio Manager and validate the inputs before you submit.
MartinAI does the data part: it reads your bills across every commodity and layout, validates them, and produces the clean, whole-building record Portfolio Manager needs. Set it up once and the 2027 deadline, and every one after it, becomes a background task. For the wider picture, see our overview of upcoming reporting deadlines through 2027, or check the rule for your building.
Frequently asked questions
Which Toronto buildings have to report in 2027?
Buildings with a gross floor area between 10,000 and 49,999 sq ft become subject to mandatory energy and water reporting in 2027. Buildings 50,000 sq ft and up have reported since 2024.
How do I report?
Through ENERGY STAR Portfolio Manager. Toronto owners report to both the City of Toronto and the Ontario Ministry of Energy using the same tool and the same dataset.
What data do I need?
Twelve months of whole-building energy and water use, across every fuel and meter, in consistent units, tied to the correct gross floor area.
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