Canada’s greenhouse gas (GHG) reporting landscape continues to evolve. Federal requirements coexist with provincial programs, creating different reporting, compliance and verification considerations depending on where an organization operates.
For organizations with facilities or operations across multiple jurisdictions, understanding which requirements apply, when verification is required and what data is needed to support reporting can quickly become complicated.
Regardless of the regulatory framework, however, effective GHG reporting starts in the same place: with reliable data.
Building a Strong Foundation with GHG Accounting
Every effective GHG strategy starts with reliable data.
GHG accounting provides organizations with a structured understanding of where emissions occur across their operations and, where applicable, throughout their value chain. A well-developed GHG inventory can support regulatory reporting, corporate disclosures and emissions-reduction planning.
It also provides an important foundation for verification. Clear organizational boundaries, consistent methodologies and traceable emissions data make it easier to support the information being reported and respond to questions during an independent review.
RWDI’s experience with GHG accounting includes work examining organizational boundaries for corporate-level GHG inventories and reporting in Canada.
GHG Reporting and Verification Requirements Across Canada
GHG reporting and verification requirements differ across Canada, with federal and provincial programs establishing their own thresholds, reporting obligations and verification requirements.
Understanding the regional differences is an important part of determining your organization’s reporting and verification obligations.
Here’s how the requirements break down across the country.
Federal GHG Reporting Requirements
Canada’s federal GHG reporting requirements operate alongside provincial reporting and carbon-pricing systems, meaning some organizations may need to consider both federal and provincial requirements when determining their reporting obligations.
Greenhouse Gas Reporting Program
Under the federal Greenhouse Gas Reporting Program (GHGRP), facilities are required to report if they:
- Emit 10,000 tonnes CO₂e or more per year.
- Carry out certain specified industrial activities, such as
- electricity generation
- mining
- petroleum refining
- cement production
- hydrogen production
- pulp and paper production
- carbon capture and storage
Facilities that meet the requirements must submit their GHG emissions reports annually by June 1.
Separate federal requirements also exist through Canada’s Output-Based Pricing System (OBPS) for facilities subject to the federal industrial carbon-pricing system. Because the GHGRP and OBPS serve different purposes, organizations need to understand both the emissions reporting requirements that apply to their facilities and any separate compliance and verification obligations associated with the carbon-pricing system under which they operate.
Canada’s Output-Based Pricing System
In general, mandatory participation applies to facilities located in jurisdictions where the federal OBPS is in force that emit 50,000 tonnes or more of carbon dioxide equivalent (CO₂e) annually and carry out a prescribed Schedule 1 activity. Facilities emitting 10,000 tonnes CO₂e or more per year may be eligible to apply for voluntary participation, subject to approval by the federal Minister. As eligibility can depend on several factors, facilities should assess their specific circumstances against the full regulatory requirements.
Regulated facilities are required to submit an annual emissions report and an accompanying third-party verification report by June 1 of the following year. As of the date of this update, the federal OBPS applies to covered facilities in Manitoba, Prince Edward Island, Yukon, and Nunavut, as well as the natural gas pipeline sector in Saskatchewan.
The sections below outline the status of each provincial program, with notes on recent regulatory changes and what you should be aware of.
British Columbia
British Columbia’s industrial GHG requirements are established through the Greenhouse Gas Industrial Reporting and Control Act, the Greenhouse Gas Emission Reporting Regulation and the B.C. Output-Based Pricing System (OBPS).
Industrial operations may be subject to reporting, verification or B.C. OBPS requirements if they:
- Emit 10,000 tonnes CO₂e or more per year, making them reporting operations.
- Emit 10,000 tonnes CO₂e or more per year and produce a regulated product, requiring participation in the B.C. OBPS.
- Produce a regulated product but emit less than 10,000 tonnes CO₂e per year, in which case eligible operations may voluntarily opt into the B.C. OBPS.
- Are reporting operations that are not regulated operations and emit 25,000 tonnes CO₂e or more per year, in which case third-party verification of the Emission Report is required.
Regulated operations must quantify and report their GHG emissions and production data through an Annual Report by May 31 annually. Annual Reports must be independently verified to a reasonable level of assurance by an accredited third-party verification body.
Alberta
Alberta’s industrial GHG reporting and compliance requirements are primarily established through the Technology Innovation and Emissions Reduction (TIER) Regulation.
Facilities may be regulated under TIER if they:
- Emitted 100,000 tonnes or more of CO₂e in 2016 or any subsequent year.
- Imported more than 10,000 tonnes of hydrogen in 2023 or any subsequent year.
- Have opted into TIER because they meet applicable eligibility requirements, including certain facilities that compete directly with TIER-regulated facilities or operate in emissions-intensive, trade-exposed sectors.
- Are conventional oil and gas facilities designated as part of an aggregate facility.
Regulated facilities must submit an annual Compliance Report, which must be verified by an accredited third-party verifier by June 30 annually. Verification can include a review of emissions and production data, benchmark calculations, supporting documentation and facility operations, as well as site visits where required.
Facilities whose emissions exceed their allowable limit can meet their compliance obligation through eligible options under TIER, including Alberta emission offsets, emission performance credits, sequestration credits, investment credits or payments into the TIER Fund.
Saskatchewan
Saskatchewan’s GHG regulatory framework is primarily established under The Management and Reduction of Greenhouse Gases Act and The Management and Reduction of Greenhouse Gases (Standards and Compliance) Regulations, 2023. Together, they establish Saskatchewan’s Output-Based Performance Standards framework.
Facilities are required to register as regulated facilities if they:
- Operate an industrial facility emitting 25,000 tonnes CO₂e or more per year; or
- Operate an electricity facility emitting 10,000 tonnes CO₂e or more per year.
Facilities below these thresholds may also be eligible for voluntary registration, including qualifying industrial, electricity and aggregate facilities.
Regulated emitters must quantify their emissions and commercial production and submit emissions returns for applicable compliance years by June 1 annually. Emissions returns generally require verification by a qualified person in accordance with Saskatchewan’s applicable standards.
Ontario
Ontario’s GHG reporting and verification requirements are primarily established under Ontario Regulation 390/18 (Greenhouse Gas Emissions: Quantification, Reporting and Verification) and the Emissions Performance Standards (EPS) program.
Facilities may be required to report their GHG emissions if they:
- Emit 10,000 tonnes or more of CO₂e per year.
- Import electricity into Ontario and meet the applicable regulatory requirements.
- Are registered, or required to be registered, under the EPS program.
Reports are to be submitted by June 1 annually. Facilities registered or required to be registered under the EPS program are considered covered facilities and must have their emissions report independently verified by an accredited verification body by September 1 annually.
Verification provides an independent assessment of the facility’s emissions report and whether it has been prepared in accordance with regulatory requirements. It can involve examining emissions data, supporting documentation, data management systems and facility operations, as well as site visits where required.
Quebec
Quebec’s GHG reporting requirements are primarily established under the Regulation respecting mandatory reporting of certain emissions of contaminants into the atmosphere and are linked to Quebec’s cap-and-trade system for GHG emission allowances.
Generally, a person or municipality operating an establishment that emits 10,000 metric tonnes CO₂e or more annually must report its GHG emissions. Quebec also has specific reporting requirements for fuel distributors. Reports are to be submitted by June 1 annually.
Third-party verification applies to emitters subject to the cap-and-trade system, including specified sectors with annual emissions of 25,000 metric tonnes CO₂e or more, certain fuel distributors and certain voluntarily registered emitters. Verification must be conducted by an ISO 14065-accredited verification organization for the applicable sector by June 1 annually.
Nova Scotia
Nova Scotia’s Output-Based Pricing System (OBPS) regulates GHG emissions from eligible industrial facilities, including facilities involved in manufacturing and processing, mining, quarrying and oil and gas extraction, and electricity generation.
Facilities may be subject to the program if they:
- Emit 50,000 tonnes CO₂e or more per year, requiring participation in the OBPS.
- Emit between 10,000 and 50,000 tonnes CO₂e per year and conduct an eligible industrial activity, in which case they may apply to participate voluntarily, subject to approval under the program.
Under the OBPS, a regulated facility’s emissions limit is determined using methodologies prescribed by Nova Scotia’s reporting and compliance framework. Depending on the sector and activities performed, this may be based on production levels and applicable performance standards that are designed to encourage emissions reductions while maintaining industrial competitiveness.
Facilities subject to the program are required to quantify and report their annual GHG emissions and obtain an independent third-party verification. Annual emissions reports and verification reports are due by June 1 of the year following the reporting period.
Navigating Canada’s Clean Fuel Regulations
Canada’s GHG regulatory landscape also includes the federal Clean Fuel Regulations (CFR), which establish carbon intensity requirements for gasoline and diesel fuels and create a market-based system for generating, trading, and using compliance credits. The CFR is designed to encourage the production and use of lower-carbon fuels and technologies while reducing the lifecycle carbon intensity of transportation fuels.
Organizations participating in the CFR can include:
- Primary suppliers of gasoline and diesel, including fuel producers and importers that are subject to compliance obligations under the Regulations.
- Organizations implementing projects that reduce the lifecycle carbon intensity of liquid fossil fuels, such as carbon capture and storage (CCS), renewable electricity projects, and other eligible emissions-reduction initiatives.
- Suppliers of low-carbon-intensity fuels, including ethanol, biodiesel, renewable diesel, and other eligible fuel types.
- Organizations supplying energy for advanced vehicle technologies, including electricity and hydrogen used for transportation.
Participation in the CFR involves a range of reporting, record-keeping, and, where applicable, third-party verification requirements. As a result, accurate emissions quantification, robust supporting documentation, and the application of approved methodologies are critical for demonstrating compliance and supporting credit generation.
For organizations navigating these requirements, partnering with an experienced GHG advisor can help address the technical, regulatory, and verification considerations associated with CFR participation. RWDI continues to expand its capabilities in Clean Fuel Regulations verification and advisory services, building on its extensive experience in emissions quantification, greenhouse gas accounting, regulatory reporting, and independent verification.
What Does This Mean for Your Organization?
Understanding whether your organization is subject to GHG reporting or verification requirements is only the first step. The bigger question is whether the information behind that reporting is ready for scrutiny.
Before reporting or verification begins, organizations should be able to:
- Identify the federal and provincial GHG reporting, compliance, and verification requirements that apply to each facility or operation.
- Trace reported emissions back to supporting source data and records, rather than relying only on final calculations.
- Document methodologies, assumptions, emission factors, and calculation approaches used to quantify emissions.
- Explain significant changes in emissions, production levels, or methodologies between reporting periods.
- Identify and address data gaps, inconsistencies, or incomplete records early in the reporting cycle.
- Understand where third-party verification is required and what information will be subject to independent assessment.
For organizations operating across multiple jurisdictions, these considerations become even more important. Reporting thresholds, compliance obligations, and verification requirements can vary significantly among federal and provincial programs. For example, a facility may be subject to a different set of requirements in Alberta, Ontario, British Columbia, or Québec, while also being required to meet federal reporting or compliance obligations.
A proactive approach to emissions management, record-keeping, and verification readiness can help organizations reduce compliance risk, improve reporting efficiency, and avoid last-minute challenges during reporting and verification cycles.
Whether your organization is preparing for its first verification or managing obligations across multiple regulatory programs, early planning and a clear understanding of applicable requirements can help streamline the process and support successful compliance outcomes.
Don’t Wait Until Verification to Discover Data Gaps
Verification provides an independent assessment of an organization’s greenhouse gas (GHG) data, but it should not be the first time the underlying information is critically examined.
Issues such as missing source records, inconsistent quantification methodologies, unclear organizational boundaries, or inadequately documented assumptions can create challenges during reporting and verification. Identifying and addressing these issues after reporting has begun is often more time-consuming and costly than addressing them proactively.
This is where strong GHG accounting practices provide significant value. Establishing a robust GHG inventory, maintaining clear documentation, and ensuring traceability of emissions data well before reporting deadlines can help organizations identify potential issues early, improve data quality, and reduce verification risk.
For organizations developing GHG projects or making emissions-related claims, validation can provide a similar benefit. By independently assessing the proposed methodologies, assumptions, and data before project implementation or claim realization, validation helps build confidence that the project or claim is based on a credible and defensible foundation.
Ultimately, organizations that invest in strong data management, documentation, and verification readiness are better positioned to meet regulatory requirements, support stakeholder confidence, and demonstrate the integrity of their GHG reporting and performance claims.
