Overview of Québec’s mandatory GHG reporting and cap-and-trade system
Introduced: 2010
Effective from: 2010; latest methodology updates in 2024
Region(s): Québec, Canada
About the policy
Québec’s mandatory GHG reporting and Cap-and-Trade system is part of the Environment Quality Act and forms a core part of the province’s climate strategy, with the goal of reducing emissions 37.5% below 1990 levels by 2030.
This policy requires annual measurement and reporting of greenhouse gas emissions from large facilities and fuel distributors. Entities emitting 10,000 tonnes or more of CO₂e annually must report emissions; those emitting 25,000 tonnes or more fall under the Cap-and-Trade program and must purchase and surrender carbon allowances or offsets equivalent to their verified emissions.
The program is linked with California’s C&T system, forming a cross-border carbon market under the Western Climate Initiative (WCI), and is seen as one of North America’s most robust carbon pricing mechanisms.
Disclosure requirements
- Annual submission of a facility-level GHG inventory, disaggregated by gas and emission source.
- Reporting must follow the regulation respecting mandatory reporting standards, including specific quantification methods.
- Capped emitters must additionally participate in Québec’s Cap-and-Trade system, submitting verified totals and surrendering allowances for all emissions above threshold.
- Data is submitted electronically via the Québec Electronic Reporting System (SGE GES).
- Public disclosure of verified emissions totals is made via Québec’s Cap-and-Trade registry.
Criteria for compliance
- All facilities emitting ≥10,000 tonnes CO₂e/year are subject to mandatory reporting.
- Facilities emitting ≥25,000 tonnes CO₂e/year become “regulated emitters” under the Cap-and-Trade system.
- Fuel distributors (e.g. natural gas, petroleum, propane) are covered if they exceed distribution thresholds.
- Some landfill operations and electricity generators also qualify depending on total emissions.
Compliance timeline
- January-December: Continuous emissions monitoring for the calendar year.
- June 1 (Y+1): Reporting deadline for previous year’s verified emissions.
- June 1 (Y+1): Verification statement due for regulated emitters (≥25,000 t).
- November 1 (Y+1): Deadline for surrendering emissions allowances under the Cap-and-Trade program.
Third-party assurance
- Entities emitting ≥25,000 tonnes CO₂e/year must obtain annual third-party verification from a firm accredited under ISO 14065.
- Facilities in the 10,000–24,999 t CO₂e range may opt for verification, especially if participating voluntarily in the Cap-and-Trade market or public disclosure is desired.
Penalties for non-compliance
Environment Quality Act penalties
- Up to C$500,000 per violation, plus daily fines for continued noncompliance.
- Enforcement actions may include permit restrictions or revocation.
Cap-and-Trade consequences
- Failure to surrender adequate allowances triggers an automatic penalty of three times the shortfall (3× allowances).
- Entities also risk exclusion from future allowance auctions, reputational harm, and additional enforcement orders.
