Mandatory GHG reporting & cap-and-trade overview
Introduced: 2010 (Regulation Respecting Mandatory Reporting of Certain Emissions)
Effective from: 2010; latest methodology updates in 2024
Region(s): Québec, Canada
About
Québec’s Mandatory GHG Reporting & Cap-and-Trade forms a core part of its climate strategy, aligning with the province’s goal of reducing emissions 37.5% below 1990 levels by 2030. The regulation 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
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Annual submission of a facility-level GHG inventory, disaggregated by gas and emission source.
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Reporting must follow the Regulation respecting mandatory reporting standards, including specific quantification methods.
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Capped emitters must additionally participate in Québec’s Cap-and-Trade system, submitting verified totals and surrendering allowances for all emissions above threshold.
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Data is submitted electronically via the Québec Electronic Reporting System (SGE GES).
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Public disclosure of verified emissions totals is made via Québec’s Cap-and-Trade registry.
Who needs to comply
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All facilities emitting ≥10,000 tonnes CO₂e/year are subject to mandatory reporting.
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Facilities emitting ≥25,000 tonnes CO₂e/year become “regulated emitters” under the Cap-and-Trade system.
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Fuel distributors (e.g. natural gas, petroleum, propane) are covered if they exceed distribution thresholds.
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Some landfill operations and electricity generators also qualify depending on total emissions.
Compliance timeline
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January–December: Continuous emissions monitoring for the calendar year.
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June 1 (Y+1): Reporting deadline for previous year’s verified emissions.
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June 1 (Y+1): Verification statement due for regulated emitters (≥25,000 t).
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November 1 (Y+1): Deadline for surrendering emissions allowances under the Cap-and-Trade program.
Third-party assurance
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Entities emitting ≥25,000 tonnes CO₂e/year must obtain annual third-party verification from a firm accredited under ISO 14065.
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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:
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Up to C$500,000 per violation, plus daily fines for continued noncompliance.
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Enforcement actions may include permit restrictions or revocation.
Cap-and-Trade consequences:
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Failure to surrender adequate allowances triggers an automatic penalty of three times the shortfall (3× allowances).
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Entities also risk exclusion from future allowance auctions, reputational harm, and additional enforcement orders.
