Vancouver's annual GHG and energy limits for large buildings: reporting, verification, and the 2026 pause

Vancouver's Annual Greenhouse Gas and Energy Limits By-law was the first in Canada to put a hard carbon cap on existing office and retail buildings, with a fee for every tonne over the line. Reporting started in 2024, the first limit year was 2026, and the operating permit that enforces it was to arrive in 2027. Then, on May 21, 2026, Council directed staff to pause enforcement.

A pause is not a repeal. The by-law is still on the books, the City is still accepting reports, staff are due back before Council in the first half of 2027, and every other disclosure regime a large-building owner answers to still applies. This article sets out what the by-law requires, how the report and the verification work, what the pause actually changed, and why the sensible response is to keep the data reporting-ready.

Which buildings are covered

The by-law has two tiers. Reporting applies broadly: the City's reporting page states that it covers commercial or multi-family residential buildings of 4,645 square metres (50,000 square feet) or larger. The limits apply narrowly. Engineers and Geoscientists BC's practice advisory describes the limits as applying to office and retail buildings of 100,000 square feet (9,290 m2) or larger. The same advisory lays out the reporting phase-in: large commercial buildings from June 1, 2024; commercial buildings of 50,000 square feet and larger plus multi-family buildings of 100,000 square feet and larger from June 1, 2025; and multi-family buildings of 50,000 square feet and larger from June 1, 2026.

The limits

The limits are intensity limits: emissions per square metre of floor area per year. EGBC's advisory gives them as 25 kg CO2e/m2/year for office buildings and 14 kg CO2e/m2/year for retail buildings in 2026, both reaching zero by 2040, with a heat energy limit of 0.09 GJ/m2/year from 2040. The City's page on the limits explains what counts: greenhouse gas intensity and heat energy intensity are both calculated from natural gas and district energy use for space heating and hot water, and electricity is excluded because BC's hydroelectric grid produces very low carbon emissions. The same page notes that some commercial kitchens, restaurants, laboratories and specialized equipment may be exempt.

Timing is easy to misread. The 2026 limit applies to the 2026 data year, which is reported in 2027. H.H. Angus puts it directly: the first reporting for the 2026 data year is due June 1, 2027, and operating permits start in 2027 for large office and retail. Prism Engineering's summary of the City's benchmarking analysis adds a useful calibration: 80 percent of buildings already met the 2026 GHGi limits, while only 10 percent met the 2040 heat energy limits. The 2026 line was set so most buildings clear it; the long-run limits are where the retrofit work sits.

The annual Energy and Carbon Report

The report is built in two connected systems. The City's reporting page describes them: ENERGY STAR Portfolio Manager tracks energy use and greenhouse gas emissions, and the Building Performance Reporting System receives the Portfolio Manager data. The data requirement is the part that catches owners: 12 months of energy use data from the previous calendar year, including electricity, natural gas and district energy from both common areas and tenant spaces. Tenant spaces are not optional. An office tower where tenants hold their own gas accounts for supplementary heating still reports the whole building.

Anyone who has set up a property for Ontario's program will find the mechanics familiar; the step-by-step EWRB guide covers the same Portfolio Manager workflow. The difference in Vancouver is what the number is for. In Ontario it is a benchmark. Here, once enforcement resumes, it is the basis for a permit and a fee.

Third-party verification

Because the report drives a fee, it has to be verified. EGBC's advisory sets out the rule as third-party verification starting with the first limit year and then every four years, triggered again in any year where the report shows at least a 15 percent change in weather-normalized emissions or a change in floor area, and names the qualified verifiers as professional engineers, certified energy managers or certified measurement and verification professionals. The 15 percent trigger is the one to remember: a large swing in reported intensity, whether from a retrofit or from a data error, brings the verifier back. That is a strong argument for catching errors before they are reported rather than after. Our piece on emissions data assurance readiness covers what verifiers actually ask for.

The operating permit and the overage fee

The enforcement mechanism is an annual carbon emissions operating permit for the office and retail buildings under the limits. EGBC's advisory gives the fee structure as a $500 base fee and an overage fee of $350 per tonne of CO2e above the limit; Prism Engineering lists the heat energy counterpart as $100 per gigajoule over the heat energy limit. H.H. Angus works an example: a 20,000 m2 building 7 kg CO2e/m2 over the limit is 140 tonnes over, for an annual fee of roughly $49,500. At that scale the fee is a line item a lender or a buyer will ask about, and the report behind it is a document they will want to see.

What the May 21, 2026 pause changed

On Thursday, May 21, 2026, Council passed the mayor's motion to pause the by-laws connected to Energize Vancouver. CBC reported the vote as seven councillors from the mayor's slate in favour and all four opposition councillors against, after a two-day meeting at which most speakers opposed the motion and the provincial housing minister had written asking the City to wait for a provincial review. The City's reporting page now carries the operative statement: on May 21, 2026, Council directed staff to pause enforcement of the Annual Greenhouse Gas and Energy Limits By-law; there are no penalties if you do not submit a report; and staff will review the by-law and are expected to report back to Council in the first half of 2027.

Read that carefully. Enforcement is paused; the by-law is not repealed. Vandecarb's analysis describes the mechanism as pausing implementation through non-enforcement, with the by-law itself remaining in effect. The City's Energize Vancouver page says it will continue to accept energy and carbon reports, and a complete report submitted by September 1 still earns a scorecard comparing the building to similar ones. The staff review could recommend anything from repeal to reinstatement with changes, and Council will decide in 2027. Our survey of building performance standards covers the other regimes still moving while Vancouver's is on hold.

What owners should still do

• Keep reporting-ready data: 12 months per year of whole-building gas, district energy and electricity, including tenant accounts, with the floor area basis documented.
• Keep submitting if the September 1 scorecard is useful to you; it is a benchmark against similar buildings and a dry run for when enforcement resumes.
• Track your own GHGI against the 25 or 14 kg CO2e/m2 line so any capital plan for heating equipment is made with the by-law's trajectory in view.
• Keep the verification file current: bills, meter map, adjustments, floor area. A 15 percent swing in a future report brings a verifier back.
• Remember the other regimes: Canadian sustainability disclosure standards, lender data requests and corporate GHG inventories all want the same building-level data; see the energy-reporting wave building toward 2027.

The data workflow, and how MartinAI fits

In Vancouver the series that matters is gas and district energy, because that is what the limit counts. The workflow: inventory every account, including tenant-held gas accounts; read every bill completely, capturing consumption, billing dates and units rather than just the amount due; normalize gas and district energy to a common energy basis; test the 12 months for gaps, overlaps and estimated reads; tie every monthly figure to its source document; then load Portfolio Manager and push to the City's reporting system. MartinAI does the reading, normalizing, testing and lineage; the owner or consultant does the submission and, when required, the verification. The same clean gas series is what an electrification study needs ahead of the 2040 limits; see using utility data to plan building electrification.

Vancouver's by-law may come back in 2027 changed, unchanged or not at all. The building's gas consumption in 2026 will be the same number regardless. Keeping it clean, complete and traceable is cheap insurance against every version of what Council decides next.