A company established in Quebec does not fall under a single carbon regime, but under several that overlap: a provincial mandatory reporting regulation, a provincial carbon market, a federal reporting program, disclosure expectations from financial regulators, and sometimes a European directive when the parent company is based in Europe. Each has its own threshold, its own deadline and its own reporting channel.
This article brings that framework together: who reports what, from which threshold, by which date, and how to build a carbon footprint that feeds these obligations without being redone four times over. Every threshold and every date links back to its official source.
What a carbon footprint means for a Quebec company
A carbon footprint quantifies an organization's greenhouse gas (GHG) emissions over a given period, converted into CO2 equivalent (CO2e). The international reference methodology remains the GHG Protocol, which splits emissions into three scopes:
This breakdown belongs to voluntary carbon accounting and reporting frameworks. Quebec and Canadian regulatory regimes, by contrast, reason in terms of facility-level emissions, not scopes. A complete carbon footprint and a regulatory declaration are therefore not the same exercise, even though they draw on the same source data.
Mandatory reporting in Quebec: the RDOCECA
The Regulation respecting mandatory disclosure of certain emissions of contaminants into the atmosphere, commonly known by its French acronym RDOCECA, governs the annual reporting of atmospheric emissions in Quebec. It applies on a calendar-year basis.
According to the ministère de l'Environnement, de la Lutte contre les changements climatiques, de la Faune et des Parcs (MELCCFP), you must report your GHG emissions if at least one of these conditions applies:
Companies that purchase electricity generated outside Quebec are also covered. The regulation does not cover GHGs alone: it also applies to sulphur dioxide, nitrogen oxides, particulate matter, volatile organic compounds, carbon monoxide, certain metals, polycyclic aromatic hydrocarbons, and dioxins and furans.
Three operational points are worth remembering. First, the deadline: the declaration for 2025 had to be submitted by June 1, 2026, through the PES-IQEA electronic service platform. Second, exiting the regime: a company keeps reporting until its emissions have stayed below the threshold for four consecutive years. Third, verification: emitters subject to the carbon market must submit their verification report within the same deadline. A regulation amending the RDOCECA was also enacted on December 10, 2025.
The Quebec cap-and-trade system (SPEDE)
The Quebec cap-and-trade system for greenhouse gas emission allowances, known by its French acronym SPEDE, was established in 2013 and linked to the California system in 2014. The MELCCFP states that covered companies account for roughly 80% of Quebec's GHG emissions.
Covered entities include:
For large emitters, other than those distributing fuels and combustibles, coverage starts on January 1 of the year emissions reach 25,000 tonnes and runs until December 31 following the third consecutive declaration below that threshold. Compliance periods last three years. By November 1 following the end of a period, the emitter must hold, in its compliance account, as many emission allowances as declared and verified emissions.
The gases to be covered are CO2, CH4, N2O, HFCs, PFCs, SF6 and NF3. Biogenic CO2, CO2 captured or transferred off-site, and emissions from mobile equipment are excluded. Notices of non-compliance can lead to fines and legal proceedings. Administrative measures may also apply: a penalty on emission units, suspension of free allocation, or a ban from participating in auctions. A public consultation on a draft regulation amending the SPEDE closed on July 3, 2026.
The federal GHG reporting program
The Greenhouse Gas Reporting Program (GHGRP) run by Environment and Climate Change Canada has collected emissions data from Canadian facilities since 2004. The information is gathered under section 46 of the Canadian Environmental Protection Act, based on a notice published in the Canada Gazette.
The threshold matches Quebec's: operators of facilities emitting 10,000 tonnes or more of GHGs in CO2 equivalent annually must file a report, before June 1. Fourteen activity categories must also supply additional data and apply a prescribed methodological framework: aluminum, ammonia, and base metal production, cement, electricity, heat and steam, ethanol, hydrogen, iron and steel, lime, mining, nitric acid, petroleum refining, pulp and paper, and geological CO2 capture and storage.
A Quebec facility that exceeds 10,000 tonnes therefore falls within the scope of both regimes, provincial and federal, with two separate reporting channels and the same June 1 deadline. The point of vigilance is less about the calculation itself than about consistency: two diverging sets of figures for the same facility are difficult to defend in the event of an audit.
Climate disclosure: where Canadian regulators stand
On April 23, 2025, the Canadian Securities Administrators (CSA) announced that they were pausing their work on a mandatory climate-related disclosure rule, as well as on amendments to diversity disclosure requirements. The CSA stated that they will continue to monitor regulatory developments and intend to revisit these projects, with advance notice to issuers before any change in status.
Two elements remain in force despite this pause. First, securities legislation already requires issuers to disclose material climate-related risks to their operations, on the same basis as any other material information. Second, the Canadian Sustainability Standards Board (CSSB) published its first standards in December 2024, broadly aligned with the ISSB's. The CSA presents these as a useful voluntary framework that issuers are encouraged to reference.
For federally regulated financial institutions, Guideline B-15 from the Office of the Superintendent of Financial Institutions (OSFI) is more prescriptive. In February 2025, OSFI aligned the Scope 3 emissions disclosure date with the CSSB standards' timeline, i.e. fiscal year 2028, and set fiscal year 2029 for the off-balance-sheet component of assets under management. In January 2026, it paused the consultation on this latter expectation and postponed its effective date to a later, unspecified time, while keeping the expectation of quantifying and managing transition risks.
A Quebec subsidiary of a European group: how CSRD fits in
This is the scenario that generates the most confusion in practice. Directive (EU) 2026/470 of February 24, 2026, published in the Official Journal of the European Union on February 26, 2026 and effective on the twentieth day following its publication, redefined the scope of European sustainability reporting.
The threshold is now as follows: companies with net turnover exceeding EUR 450,000,000 and averaging more than 1,000 employees during the financial year are covered, both at the individual and at the consolidated level for parent companies. Member States must transpose Articles 1 to 3 of the directive by March 19, 2027 at the latest.
Three practical consequences for a Quebec entity:
The Quebec specificity: a structurally low Scope 2
The MELCCFP's Quebec GHG emissions inventory provides a useful benchmark for framing a carbon footprint in Quebec. In 2023, total emissions stood at 77,968 kilotonnes of CO2 equivalent, down 8.5% from 1990. The electricity and heat production sector accounted for only 392 kilotonnes, or 0.5% of the total. Transportation represented 44.8% of Quebec's emissions, including 33.4% for road transport alone.
The methodological consequence is direct: in a Quebec footprint, Scope 2 emissions tied to grid electricity carry little weight, whereas they often dominate footprints built in jurisdictions with a fossil-heavy electricity mix. The analytical effort shifts toward Scope 1, natural gas combustion for heating and processes, vehicle fleets, and toward Scope 3, purchases and logistics. A company that mechanically applies a footprint model designed for another country misses the bulk of its actual footprint.
Building a usable carbon footprint in Quebec
A work sequence that limits rework:
What Kabaun covers
Kabaun is a carbon management platform built for groups and mid-sized companies. On a Quebec file, the relevant capabilities are:
Two limitations to know before starting a project from Quebec: data is hosted exclusively in the European Union, and billing as well as monetary reporting are done in euros. The natively supported frameworks beyond the GHG Protocol are BEGES, PCAF, GLEC, AGEC and REEN; Quebec and federal reporting regimes are not covered by a dedicated module.
FAQ
From what threshold must a company report its GHG emissions in Quebec?
The threshold is 10,000 tonnes or more of GHGs in CO2 equivalent emitted during the calendar year. Other situations trigger the obligation independently of this threshold: distributing 200 litres or more of fuels and combustibles, capturing, storing, eliminating or recovering emissions, transferring emissions to another operator or receiving them from another operator, or purchasing electricity generated outside Quebec.
What is the difference between the RDOCECA and the SPEDE?
The RDOCECA is a reporting regulation: it requires companies to measure and submit their emissions. The SPEDE is a carbon market: it requires covered emitters to surrender an emission allowance for every tonne emitted. The latter relies on the data declared and verified under the former. A company can be covered by the RDOCECA without being subject to the SPEDE.
Does a company emitting 25,000 tonnes have to report both in Quebec and federally?
Both regimes operate in parallel with the same 10,000-tonne reporting threshold and the same June 1 deadline, but through separate channels: PES-IQEA in Quebec, the Environment and Climate Change Canada reporting channel federally. Check with both administrations for the requirements applicable to your facility before preparing your filings.
Is climate disclosure mandatory for Canadian companies?
The Canadian Securities Administrators paused the development of a dedicated mandatory rule in April 2025. Securities legislation, however, still requires the disclosure of material climate-related risks. The CSSB standards published in December 2024 constitute a voluntary framework. Federally regulated financial institutions, meanwhile, fall under OSFI's Guideline B-15.
Our European parent company is subject to CSRD, what must we produce in Quebec?
If the group exceeds EUR 450,000,000 in net turnover and averages 1,000 employees, the parent company publishes a consolidated report that covers the Quebec subsidiary. The subsidiary feeds this report with data, without a separate publication obligation of its own. If your entity averages fewer than 1,000 employees and sits within the value chain of a reporting company, the directive limits what can be required of you.
Why does Scope 2 carry so little weight in a Quebec carbon footprint?
Because electricity and heat production accounted for only 0.5% of Quebec's emissions in 2023 according to the MELCCFP inventory. Electricity purchased from the grid therefore carries a low carbon intensity, and most of the footprint concentrates on Scope 1 and Scope 3.
Further reading
On the Kabaun blog:
Official sources:
Conclusion
Quebec's carbon framework reads in four layers: provincial reporting from 10,000 tonnes, SPEDE coverage from 25,000 tonnes, federal reporting from 10,000 tonnes, and disclosure requirements driven by financial regulators or by a European parent company. The useful work consists of building a single, documented and verifiable activity data set capable of feeding these four outputs.
First concrete step: list your Quebec facilities and estimate, for each one, annual emissions in CO2 equivalent. That figure determines which regimes you fall under.
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