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RegulationsJanuary 28, 2025

Submetering Requirements in Ontario: What Building Owners Need to Know

Ontario has some of the most developed submetering regulations in Canada. If you own or manage a multi-unit building in the province, understanding these requirements is essential — both for compliance and for maximizing the financial benefits of submetering.

The Regulatory Landscape

Submetering in Ontario is governed by a combination of federal and provincial legislation:

  • Electricity and Gas Inspection Act (Federal) — Requires all meters used for trade to be verified by Measurement Canada or an accredited Authorized Service Provider
  • Energy Consumer Protection Act, 2010 (ECPA) — Ontario legislation that establishes rules for how electricity can be sold to tenants through submetering
  • Ontario Energy Board (OEB) regulations — Licensing requirements for submetering providers operating in Ontario

Who Can Provide Submetering Services in Ontario?

In Ontario, companies that provide submetering services and bill tenants for electricity must be licensed by the Ontario Energy Board. This licensing requirement ensures consumer protection and sets standards for billing practices, dispute resolution, and service quality.

Note that the OEB license is separate from Measurement Canada accreditation. The OEB license covers the billing side of submetering, while Measurement Canada accreditation covers the verification of meter installations. Both are required for a compliant submetering operation.

When Is Submetering Required?

Ontario does not universally mandate submetering for all buildings. However, there are scenarios where it becomes effectively required or strongly incentivized:

  • New construction: Many municipalities require or strongly encourage submetering in new multi-unit residential buildings as part of green building standards
  • Condominium conversions: When a building converts to condo ownership, individual unit metering is typically expected
  • Energy efficiency programs: Various utility and government programs offer incentives for buildings that implement submetering
  • Voluntary implementation: Building owners can choose to implement submetering to recover energy costs and encourage conservation

Measurement Canada Requirements

Regardless of Ontario-specific rules, any electrical meter used for billing in Canada must comply with federal Measurement Canada requirements:

  • Meters must be Measurement Canada approved types
  • Installations must undergo SE-04 verification by an accredited ASP
  • Meters must be properly sealed to prevent tampering
  • Verification records must be maintained for regulatory compliance

These requirements apply across all of Canada, not just Ontario. If you're billing tenants based on submeter readings, your meters must be verified.

Key Compliance Steps for Building Owners

If you're considering implementing submetering in an Ontario building, here's a compliance checklist:

  • Engage a licensed submetering provider — Ensure they hold a valid OEB license for Ontario
  • Select approved meters — Only use meter types approved by Measurement Canada
  • Hire qualified installers — Meters must be installed by licensed electricians per Ontario electrical code
  • Arrange SE-04 verification — Before billing begins, have an accredited ASP verify each meter installation
  • Maintain documentation — Keep all verification records, serial numbers, and inspection reports on file
  • Follow billing rules — Comply with ECPA requirements for tenant communication, billing format, and dispute resolution

Common Mistakes to Avoid

  • Billing before verification: You cannot legally bill tenants using unverified meters
  • Using non-approved meters: Only Measurement Canada approved meter types are valid for trade
  • Skipping documentation: Poor record-keeping creates liability during audits
  • Ignoring OEB requirements: Operating without proper licensing exposes you to regulatory action

How Meter Audit Can Help

As a Measurement Canada accredited ASP, Meter Audit provides SE-04 verification inspections for electrical submeter installations across Ontario and all Canadian provinces. We also offer end-to-end submetering solutions — from consultation and system design through verification and documentation.

Contact us to discuss your Ontario submetering project →

Need help with Ontario submetering compliance?

We'll guide you through the regulatory requirements and handle your SE-04 verification.

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