This Act establishes a regulatory framework to measure and manage the environmental performance of buildings in Québec. It defines “environmental performance,” authorizes the government to require information from building owners and certain energy distributors, and gives the Minister powers to set which buildings must be rated, how ratings are calculated, and the standards buildings must meet.
The law also creates enforcement tools and financial linkages: it enables administrative and penal sanctions for non-compliance and reorganizes related energy-transition funding and program responsibilities for energy distributors. The result is a provincial system designed to make building-level energy and emissions data actionable for policy and market actors.
At a Glance
What It Does
The Act requires prescribed information about a building’s energy use, materials and ownership to be declared to the Minister and empowers the Government to require environmental performance ratings and standards by regulation. It tasks identified energy distributors with enabling data transfers to building owners and integrates distributor-funded programs into the province’s climate funding architecture.
Who It Affects
Owners of regulated buildings (including syndicates of co-owners), public bodies, Hydro‑Québec and defined gas and fuel distributors, municipal authorities that may enforce regulations, and recognized third parties who verify declarations and assign ratings.
Why It Matters
It creates the first statutory mechanism in Québec to produce standardized, regulator-held building performance data and to tie distributor programs and contributions to the provincial climate framework—shifting compliance and reporting responsibilities onto owners and energy distributors and making performance visible to markets and regulators.
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What This Bill Actually Does
The Act creates duties, a rating system and enforcement tools focused on building-level environmental metrics. The Minister will be able to require owners, public bodies and certain energy distributors to declare prescribed information about a building — for example energy consumption patterns, physical characteristics and materials — and to provide verification reports produced by persons or bodies recognized by regulation.
Energy distributors designated by regulation must also develop and run a digital platform that lets them transfer a building’s consumption data to the building’s owner.
Regulation will determine which buildings must receive an environmental performance rating and the calculation methods for those ratings. The rules can vary by building type, location, construction works and energy production or consumption patterns, and the Government may permit group ratings or apportion site equipment among buildings.
Where an owner disagrees with an assigned rating, the Act creates an administrative review process with a 60‑day window to apply and a further right to take decisions to the Administrative Tribunal of Québec within 30 days.The Act authorizes the Government to adopt standards tied to ratings — including standards applicable to construction, renovation or demolition — and to require owners to obtain reports at their expense from recognized third parties. For buildings that cannot meet an applicable rating because of exceptional circumstances, owners may propose a corrective program to the Minister; approval suspends the immediate obligation while the program runs, but the Minister may terminate the program for significant non‑compliance.To make results public, the Minister must maintain a register of environmental performance information (with narrow privacy exceptions for certain shelter addresses) and regulations will require owners to post or disclose a building’s rating in specified contexts.
The Act attaches inspection and enforcement powers from existing environmental enforcement legislation and sets out both monetary administrative penalties and criminal sanctions for failures to declare information, send or post ratings, or otherwise comply with enacted rules.The law also amends related statutes to shift programmatic duties and funding. Identified energy distributors must submit five‑year programs and measures for Ministerial approval, carry them out, report on performance at six‑month intervals, and pay an annual contribution to the Minister determined under the province’s climate framework.
The Act merges the Energy Transition, Innovation and Efficiency Fund into the Electrification and Climate Change Fund and contains transitional measures that bridge pre‑existing master‑plan investment amounts into the new contribution architecture until April 1, 2026.
The Five Things You Need to Know
Section 4 requires owners, public bodies and energy distributors designated by regulation to declare specified building data (energy use by timing, location, area, materials, equipment and owner contact) and to supply a verification report from a person or body recognized under regulation.
The Government will determine which buildings require an environmental performance rating and how to calculate it; owners must send assigned ratings to the Minister and may seek administrative review within 60 days, with Tribunal recourse within 30 days of the review decision.
Monetary administrative penalties are set at $250 for a natural person and $1,000 for others for failures to declare, to send a rating, or to post/disclose a rating; separate penal fines range from $1,000–$100,000 for individuals and $3,000–$600,000 for other persons.
The Minister must keep a public register of the environmental performance of buildings, and regulations will require owners to post or disclose a building’s rating in defined circumstances, with a limited privacy carve‑out for addresses of certain victim‑support accommodations.
Identified energy distributors (including Hydro‑Québec and defined gas/fuel distributors) must submit five‑year programs for Minister approval, implement approved measures, report every six months on outcomes, and pay an annual contribution to support climate-related measures under the province’s framework.
Section-by-Section Breakdown
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Enactment and definitions
This chapter inserts the new Act and defines core terms: “environmental performance” (explicitly including carbon footprint, when energy is used, and on‑site energy production) and “building” (broadly, plus equipment that consumes energy). It also specifies that the Act binds the State and clarifies that syndicates of co‑owners count as owners for condominiums. These definitions set the statutory scope for every subsequent obligation and determine who will be subject to reporting and standards.
Mandatory reporting and distributor data platform
Section 4 lists the categories of information the Minister can require by regulation and makes three operational requirements: owners (and regulated public bodies) must declare prescribed data; declarations must be supported by verification reports from recognized parties; and identified energy distributors must develop and operate a digital platform to transfer consumption data to owners. The provision also gives the Minister regulatory authority to impose retention or record‑keeping rules — a practical lever that will affect IT, procurement and verification workflows for both owners and distributors.
Ratings: who, how and dispute process
The Government will specify which buildings need an environmental performance rating and set calculation methods that may vary by building type, location, construction history and energy flows. Regulations will name who may assign ratings and when group ratings or site equipment apportionment are permitted. The regime provides an administrative review path: owners are notified of ratings, can apply for review within 60 days, the review body must give reasons and may amend the decision, and Tribunal appeal must be brought within 30 days — an expedited administrative‑law channel intended to keep rating disputes time‑bounded.
Standards, corrective programs and heritage treatment
The Government can create standards that apply to construction, renovation or demolition and may set different standards for heritage or culturally classified properties. Owners can be required to obtain and deliver verification reports at their expense. Where a building cannot meet a standard for exceptional reasons, the owner may submit a corrective program for Ministerial approval; approval suspends immediate compliance but can be revoked if the owner fails to follow the program. This section balances mandatory performance expectations with a formal pathway for staged compliance.
Public register, posting and measuring tools
The Minister must maintain a public register of the prescribed environmental‑performance information; the Act explicitly makes that register public while carving out the addresses of certain victim‑support establishments. Regulations will set when owners must post ratings and when they must disclose ratings to third parties, and can require installation of energy‑measuring tools. These provisions create a transparency regime that can affect real‑estate transactions, marketing and tenant relations.
Inspections, monetary administrative penalties and penal sanctions
The Act applies inspection and seizure powers from Québec’s environmental enforcement statute to enforce its provisions. It establishes both streamlined monetary administrative penalties for defined failures and heavier penal sanctions for contraventions: low‑level financial penalties for administrative non‑compliance and ranges of criminal fines for more serious breaches. Municipalities can be authorized to impose and collect administrative penalties for infractions in their territories and must use most proceeds to fund building energy‑transition measures.
Delegation, municipal bylaws, energy distributor programs and transitions
The Government may allow the Minister to delegate regulatory application to third parties. Municipal bylaws covering rating and standards are inoperative unless approved by the Minister, and transitional rules preserve certain by‑laws during an approval window. The Act moves programmatic duties into the environment ministry: identified energy distributors must submit five‑year programs for Minister approval, carry them out, report semi‑annually, and pay an annual contribution into the province’s Electrification and Climate Change Fund; transitional provisions carry prior master‑plan investment figures forward until April 1, 2026.
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Explore this topic in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Owners of higher‑performing buildings — public rating and register visibility can increase market value and make energy upgrades a marketable attribute to tenants and buyers.
- Tenants and occupants — improved disclosure and mandatory measuring tools (where required) give users clearer information about energy use and potential costs, aiding leasing and occupancy decisions.
- Provincial regulators and policy planners — centralized, standardized building data and distributor program reports give the Minister tools to monitor and steer the building stock toward climate targets.
- Municipalities running approved enforcement schemes — they may collect penalties and are directed to reinvest proceeds into local building energy transition measures.
- Recognized verification and rating bodies — the Act creates regulated demand for third‑party verification, rating assignments and corrective‑program work under the regulation.
Who Bears the Cost
- Building owners (including condominium syndicates) — they face costs for data collection, verification reports, possible corrective programs, posting/disclosure compliance and any required measuring hardware.
- Energy distributors (Hydro‑Québec, gas and fuel distributors, municipal systems) — they must build and maintain digital platforms, design and deploy approved programs, report semi‑annually and pay annual contributions determined under the climate framework.
- Small landlords and heritage property owners — compliance burdens and prescriptive standards (even with exemptions) can be disproportionately costly or technically challenging for small portfolios and protected buildings.
- Municipal governments — while they can enforce provisions and retain penalties, local administrations may see increased administrative load to process penalties, inspections and interactions with the Minister’s delegated approvals.
- Recognized third parties and experts — while they gain market opportunity, they also carry liability and standardization burdens because the Act vests significant weight in their verification and ratings work.
Key Issues
The Core Tension
The central dilemma is between rapid, standardized transparency and centralized enforcement to meet climate goals versus the practical and financial burdens placed on owners, distributors and local governments: rules that are strict and comparable deliver useful data and push upgrades, but they also impose costs, technical challenges and potential market distortions that the regulations must carefully mitigate.
The law resolves several practical gaps — it creates a single regulator‑held register and ties distributor programs to the climate framework — but it leaves major implementation questions open. The regulations will determine the technical content that matters most: which buildings are covered, the rating algorithms, the recognition regime for verifiers, the data retention rules, and the precise circumstances requiring measuring tools.
Those choices will shape compliance costs, the quality of the data produced, and whether ratings are comparable across building types.
The Act also creates potential friction between transparency and privacy, and between provincial standards and municipal bylaws. Public disclosure of ratings aims to correct information asymmetries in real estate markets, yet the statute only narrowly carves out shelter addresses; broader privacy and commercial confidentiality issues (tenant billing data, aggregated site equipment allocation among multiple buildings) will require detailed regulatory balancing.
Finally, shifting program oversight and contributions to the environment ministry centralizes control but raises questions about funding predictability for distributors, the adequacy of Ministerial review capacity, and the consequences if distributors cannot implement approved programs on schedule.
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