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Montreal's By-Law 21-042

Montreal's By-Law 21-042: Building emissions disclosure and benchmarking programme

Onye Dike
Written by Onye Dike
Updated on July 16th, 2026

Summary

Montréal By-law 21-042 requires owners of large commercial, institutional, and multi-unit residential buildings to annually report their buildings' energy consumption and associated greenhouse gas (GHG) emissions. The bylaw establishes a citywide disclosure and rating system that enables Montréal to benchmark building performance, support decarbonisation policies, and encourage energy-efficient building management.

Details

Jurisdictions
  • Montreal
Mandatory for

Montreal's By-law 21-042 applies to owners of existing commercial buildings, institutional buildings, and
multi-unit residential buildings that are 2,000 m² (21,528 ft²) or larger or contain 25 or more dwelling units within the City of Montréal.

Deep dive

3 min read
Updated Jul 16, 2026

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Background

Montréal adopted By-law 21-042 in September 2021 as part of its Climate Plan 2020–2030, which targets carbon neutrality by 2050. The building sector is one of the city's largest sources of greenhouse gas emissions, making it a key focus of Montréal's climate strategy. Unlike building performance standards that impose emissions caps or reduction targets, By-law 21-042 is primarily a building disclosure and benchmarking programme. It requires owners of large buildings to measure and report annual energy consumption, allowing the City to estimate greenhouse gas emissions, compare similar buildings through a performance rating system, and identify opportunities to improve energy efficiency across the building stock. The bylaw also lays the foundation for future performance-based measures envisaged under Montréal's Climate Plan.

Reporting and Compliance Requirements

Building owners subject to the bylaw (see list of buildings) must:

  • Benchmark their building using ENERGY STAR Portfolio Manager® (ESPM).

  • Report monthly energy consumption data covering the previous calendar year.

  • Transfer their building data to the City of Montréal by 30 June each year through the City's ESPM reporting process.

  • Maintain accurate building and energy information, including building characteristics and utility data.

Penalties for Non-Compliance

A person who fails to comply with the bylaw or knowingly submits false or misleading information commits an offence. Individuals are liable to fines ranging from C$500 to C$2,000 for a first offence and C$1,000 to C$4,000 for subsequent offences. Corporations face fines of C$1,000 to C$4,000 for a first offence and C$2,000 to C$8,000 for subsequent offences. Each day that a violation continues is treated as a separate offence, allowing penalties to accumulate.

Current Status and Outlook

By-law 21-042 is fully operational, with annual reporting now taking place through the City's disclosure programme. Montréal has continued refining the framework, including adopting a formal methodology for calculating building GHG performance ratings in 2025. The City has also expanded guidance documents, webinars, and automated data transfers with Hydro-Québec and Énergir to simplify compliance for building owners. As the City's database of building performance grows, Montréal intends to use the information to identify high-emitting buildings, develop targeted retrofit programmes, monitor progress toward its climate objectives, and support future building decarbonisation policies.

Resources


Onye Dike
Added by:
Onye Dike
Sustainability Research Analyst
Onye Dike is a Sustainability Research Analyst at Net Zero Compare, where he contributes to research and analysis on environmental regulations, carbon accounting, and emerging sustainability trends.
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Added on Jul 15, 2026 by Onye Dike · Updated on Jul 16, 2026