Updated October 3, 2026 · DF Property Management
The reporting rules
Two overlapping requirements apply to larger buildings, including multi-residential buildings, in Toronto:
| Ontario (EWRB, O. Reg. 506/18) | City of Toronto (Municipal Code Chapter 367) | |
|---|---|---|
| Who | Buildings 50,000 sq ft and larger | Buildings 50,000 sq ft and larger now; 10,000 sq ft and larger starting with 2027 reporting |
| What | Annual energy and water use | Annual energy and water use, with emissions data |
| When | By July 1 each year, for the previous year | By early July each year, for the previous year |
| How | ENERGY STAR Portfolio Manager, the same data shared with both | |
Buildings of 100,000 sq ft and larger must also have data verified by a qualified professional periodically — once every five years under the City's by-law. Toronto has also been developing emissions performance standards that would set limits for large buildings over time. Watch for updates: a building that reports today may be measured against a target later.
Reporting is mostly administrative, but it creates a useful dataset. Once you have a few years of Portfolio Manager data, you can compare your building's energy use intensity against similar buildings and see whether a retrofit actually worked.
Where the energy goes
In a typical older GTA rental building with gas heat, the largest loads are:
- Space heating — boilers serving radiators, baseboards or fan coils.
- Domestic hot water — often a large share of gas use, and growing as buildings age.
- Make-up air — the rooftop unit that heats outdoor air and pressurizes corridors.
- Common-area electricity — lighting, elevators, garage ventilation, pumps and fans.
- Suite electricity — where it's included in the rent.
Retrofits that usually pay
LED lighting and controls
Corridors, stairwells and garages are lit around the clock. Replacing older fluorescent and HID fixtures with LED, and adding occupancy sensors in garages, stairwells and service rooms, is usually the fastest payback in the building. Check emergency lighting compliance at the same time.
Boiler plant upgrades
Many 1960s–1980s Toronto towers still run large, old atmospheric boilers. Replacing them with high-efficiency condensing boilers only delivers full savings if return water temperatures are low enough, so pair the upgrade with outdoor reset controls, proper sequencing and, where possible, lower supply temperatures. Time the work to the boiler's end of life in your capital plan.
Domestic hot water
Separate the hot water from the heating plant where it's combined, right-size storage, insulate piping, fix recirculation controls and install low-flow showerheads and aerators. These are low-cost measures with quick results.
Make-up air units
Older make-up air units often run at full volume, all day, all year. Replacing them with high-efficiency units — some with heat recovery — and adding scheduling or demand control can cut gas use significantly while improving corridor air quality.
Heat pumps
Air-source heat pumps are increasingly used in GTA apartment buildings, either for suite heating and cooling (which also helps with summer comfort) or as part of a hybrid plant with gas boilers covering the coldest days. They reduce emissions, but electricity capacity, operating costs and noise need careful engineering review. Check the building's electrical service before committing.
Building envelope
Window replacements, air sealing and over-cladding are expensive and are usually justified by the envelope's condition rather than energy savings alone. When they're due anyway, specify better performance.
Building automation and tune-ups
A building automation system that monitors temperatures and controls equipment helps, but simpler measures matter too: thermostatic radiator valves, regular burner tune-ups, balancing heating loops and fixing stuck dampers.
Planning a retrofit: the right order
- Benchmark. Use your Portfolio Manager data to see where the building sits against similar buildings.
- Audit. An energy audit by an engineer identifies measures, costs and savings for your building specifically.
- Fix operations first. Controls, schedules, tune-ups, leaks. Cheap, fast, and they make later savings easier to measure.
- Align with the capital plan. Do efficiency upgrades when equipment is due for replacement anyway — the extra cost of the efficient option is what you're really comparing.
- Apply for incentives before signing contracts.
- Measure results. Compare a year of utility data before and after, adjusted for weather.
Don't forget water
Water and sewer charges are a large and rising line in most GTA apartment budgets, and they're easy to waste. Older high-flush toilets, running flappers, dripping faucets and leaking hose bibs add up across a hundred suites. A building-wide toilet replacement and a fixture check at every turnover usually pay back quickly. Watch the monthly water meter readings: a sudden jump with no explanation is often a single leak worth finding today.
Cooling and comfort
Efficiency work now has a comfort dimension. In Toronto, RentSafeTO requires air-conditioning systems to run from June 1 to September 30 where they exist, and buildings without suite cooling must have a cool common area kept at or below 26°C starting June 1, 2026. Heat pumps and better envelopes can help meet these expectations.
Incentives and financing
Funding programs change often, so check what's open before you design a project:
- Utility programs from Enbridge Gas and the province's Save on Energy (IESO) for multi-residential and commercial retrofits.
- City of Toronto retrofit programs, including low-interest financing for building improvements.
- Federal programs for deep retrofits of large buildings.
- CMHC MLI Select, which gives better mortgage terms in exchange for energy efficiency commitments, among other options.
Most programs require pre-approval before work begins. Applying after you've signed with a contractor is the most common way to lose an incentive.
Tenants and AGIs
Major retrofits involve suite entry, noise and temporary service interruptions. Give proper notice, post updates on the tenant notification board and plan around heating season. Some capital retrofits may be eligible expenditures for an above-guideline rent increase — but expect the Landlord and Tenant Board to look at whether savings are being passed on, and keep good records.
How we help
For buildings under our apartment building management, we handle annual energy and water reporting, track utility costs monthly in your owner statement, and help scope, tender and supervise retrofits with engineers and contractors — including incentive applications at the right time.