Energy codes and building performance standards in Canada

Energy codes set the minimum energy performance for new buildings and major renovations, and building performance standards increasingly set limits for existing buildings. Together they are the main regulatory driver of operational energy and carbon. CON-140 explained how Canadian model codes are developed and adopted by provinces and territories; this lesson looks at the energy and emissions content of those codes, the stretch and step codes that some jurisdictions use to go further, and the benchmarking and performance rules that apply once a building is occupied. Codes change frequently and adoption varies by province and municipality, so treat the details here as a map dated 2026 and always check the edition in force where you build.

How energy codes work

Energy codes usually offer two or three compliance paths. A prescriptive path sets minimum values for each component, such as maximum U-values for walls, roofs and windows, minimum equipment efficiencies, lighting power limits and controls. A trade-off path lets a better component offset a weaker one within limits. A performance path compares an energy model of the proposed building with a model of a reference building that just meets the prescriptive requirements, and the proposed building must use no more energy (or emit no more, in codes with emissions metrics) than the reference. Performance paths give designers flexibility but depend on modelling skill and honest inputs, and most also have mandatory requirements, such as airtightness and controls, that apply whatever the path.

For builders, codes create two practical responsibilities. First, what is built must match what was approved: a substituted window, a missing thermal break or a different mechanical unit can make the building non-compliant even if it was compliant on paper. Second, more codes now require tests and documentation during construction, such as airtightness tests, commissioning reports and as-built energy model updates, which must be scheduled and paid for.

The national model codes and tiers

Canada's national model codes are the National Building Code (NBC), whose Part 9 Section 9.36 covers energy efficiency for houses and small buildings, and the National Energy Code of Canada for Buildings (NECB), which covers larger buildings. The 2020 editions introduced tiered energy performance: five tiers for Part 9 buildings and four tiers for NECB buildings, with Tier 1 the minimum and higher tiers progressively more efficient. Under the NECB 2020 performance path, Tier 2 requires at least a 25 % improvement over the reference building, Tier 3 at least 50 % and Tier 4 at least 60 %. The tiers let provinces and, where permitted, municipalities choose a level now and step up over time toward the federal goal of net zero energy ready codes by 2030.

The 2025 editions of the NBC and NECB, published in late 2025, keep the tiered structure and, for the first time, include performance and prescriptive requirements to limit operational greenhouse gas emissions. They add an optional energy use intensity path for common building types, prescriptive options for the lowest and highest tiers, updated climate data that reflect projected future conditions, and a new framework for alterations to existing buildings that provinces may choose to adopt. As with all national codes, none of this applies until a province or territory adopts it, and provinces can adopt with amendments or exemptions; commentators noted in early 2026, for example, that Ontario had exempted itself from much of the new energy and emissions content.

Provincial and municipal codes

Several provinces and cities go beyond the base code. British Columbia's Energy Step Code sets steps of increasing energy performance, measured with metrics such as thermal energy demand intensity and mechanical energy use intensity, and the province has said it intends to require net zero energy ready performance by 2032. Its Zero Carbon Step Code, added in 2023, sets emission levels from EL-1 (measure only) to EL-4 (zero carbon for space heating, hot water and cooking), and municipalities may require higher steps and emission levels than the provincial minimum. The Toronto Green Standard, in Version 4 as of this writing (check whether a newer version applies), sets tiered performance targets for energy use intensity, thermal energy demand intensity and greenhouse gas intensity, with Tier 1 mandatory for new development and higher tiers voluntary or required for city-owned buildings; Vancouver, Quebec and other jurisdictions have their own approaches.

# Cedar Row against NECB-style tiers and municipal-style intensity limits (illustrative)
ref_mwh, prop_mwh = 1250, 678          # reference-building and proposed annual energy (energy models)
improvement = 1 - prop_mwh / ref_mwh
tiers = [(4, 0.60), (3, 0.50), (2, 0.25), (1, 0.0)]   # NECB 2020 minimum improvement by tier
tier = next(t for t, x in tiers if improvement >= x)
print(f"Improvement over reference: {improvement:.1%} -> Tier {tier}")
area = 8400
metrics = {'TEUI (kWh/m2)': prop_mwh * 1000 / area,
           'TEDI (kWh/m2)': 336 * 1000 / area,
           'GHGI (kg CO2e/m2)': 47 * 1000 / area}
limits = {'Tier A': (135, 50, 15), 'Tier B': (100, 30, 8), 'Tier C': (70, 15, 3)}   # illustrative
for name, lim in limits.items():
    ok = all(v <= l for v, l in zip(metrics.values(), lim))
    print(f"{name}: limits {lim} -> {'meets' if ok else 'does not meet'}")
print({k: round(v, 1) for k, v in metrics.items()})

Improvement over reference: 45.8% -> Tier 2
Tier A: limits (135, 50, 15) -> meets
Tier B: limits (100, 30, 8) -> does not meet
Tier C: limits (70, 15, 3) -> does not meet
{'TEUI (kWh/m2)': 80.7, 'TEDI (kWh/m2)': 40.0, 'GHGI (kg CO2e/m2)': 5.6}

Cedar Row's energy model shows a 46 % improvement over the reference building, which places it in NECB Tier 2 but short of Tier 3. Against the illustrative municipal intensity limits, it meets the first tier easily, but its thermal energy demand intensity of 40 kWh/m² is too high for the second tier, which requires 30. To reach the next tier the team would need a better envelope, such as triple glazing, a lower window-to-wall ratio or a more efficient heat recovery ventilator, rather than more efficient heating equipment, because demand intensity measures heat lost through the envelope and ventilation, not how efficiently it is replaced.

Benchmarking and existing buildings

Most Canadian regulation still targets new construction, but attention is turning to existing buildings. Ontario's Energy and Water Reporting and Benchmarking regulation requires owners of large buildings to report energy and water use annually, and several provinces and cities use ENERGY STAR Portfolio Manager, which Natural Resources Canada supports, for benchmarking. Vancouver has introduced greenhouse gas and energy limits for large existing commercial buildings, and other cities are considering similar rules. The 2025 national codes' new framework for alterations to existing buildings may eventually bring energy requirements to renovations in provinces that adopt it.

Benchmarking matters to builders because it makes performance visible. A building that was designed to an EUI of 80 kWh/m²·yr but reports 130 after occupancy will attract questions, and owners increasingly ask contractors for commissioning, airtightness and as-built documentation that explains the gap.

Federal programs and incentives

Federal policy in Canada works mainly through the model codes, research by the National Research Council, programs run by Natural Resources Canada and the Canada Mortgage and Housing Corporation, and the government's own buildings. The 2024 Canada Green Buildings Strategy set out plans for retrofit support, code development and federal procurement, and the federal Standard on Embodied Carbon in Construction, updated in 2025, applies to large federal projects (Lesson 12). Incentive programs for homeowners and builders change frequently; some, such as the Canada Greener Homes Grant, have closed to new applicants, so check current federal and provincial programs before relying on them in a pro forma.

Policy views differ sharply on these instruments. Supporters of stringent codes and performance standards argue that buildings last for decades, that efficiency is cheapest to build in at the start, and that markets underinvest because of split incentives between owners and tenants. Critics argue that each increment adds to construction and housing costs, that rules written for large cities may not suit small towns or cold rural regions, and that incentives and information may achieve similar results with less burden. Builders should be able to explain the costs and benefits of each option accurately to clients, whatever their own views.

What codes mean on site

Code compliance is increasingly verified by testing and documentation rather than drawings alone. A builder should expect to provide some or all of the following, and to plan time and money for them.