Export and Import Reporting Changes

Summary#

The Canadian Energy Regulator (CER) is proposing new Export and Import Reporting Regulations (and a companion Toll Information Reporting Regulations) to replace older rules made under the former National Energy Board. The changes would change what data exporters, importers and some pipeline companies must report, and how often, to modernize reporting and improve market monitoring. This is a proposal published on December 14, 2024 and it is open for comment for 45 days — it is not law yet.

What it does#

• Replaces the old National Energy Board Export and Import Reporting Regulations with the proposed Export and Import Reporting Regulations (and moves some rules into a separate Toll Information Reporting Regulations).
• Removes requirements to report in‑transit oil and gas flows, matching proposed changes to export authorization rules.
• Updates how electricity exports are reported (stops using specialized “transfer classes” because market practice has changed).
• Changes the reporting point for oil and gas prices from “pipeline” injection to the actual “mode(s) of transport” (to reflect marine and other transport).
• Reintroduces a monthly reporting duty for all natural gas importers (previously only some importers had to report).
• For pipeline toll reporting:
  • Keeps the existing quarterly financial reports but adds monthly reporting of traffic (throughput) for certain pipeline companies.
  • Shifts emphasis from detailed forecast calculations to actual results, while still requiring explanations for differences.
• The new regulations would come into force when the related Export and Import (Orders, Licences and Permits) Regulations are registered.

Who's affected#

• Companies that export or import oil, gas or electricity.
  • There are currently about 93 electricity export permit holders and about 142 natural gas importers (figures used in the analysis).
• Large pipeline companies that charge tolls — currently 13 companies file toll surveillance reports.
• Holders of natural gas in‑transit orders (about 27 order holders under the old rules).
• The Canadian Energy Regulator (CER) itself, which collects and uses the data to monitor markets.
• Industry groups and Indigenous parties consulted, including the Canadian Association of Petroleum Producers, the Canadian Electricity Association, and the Gitxaala Nation.
• Small businesses: the government’s analysis says there are currently no small businesses exporting or importing these commodities, so small business impacts are expected to be minimal.

Why it matters#

• The CER says the update will reduce unnecessary or outdated report requirements and align reporting with how the energy industry actually works today.
• The government estimates net administrative savings for businesses, with a present value decrease of $22,696 over 10 years (an annualized average of $3,231). The proposal estimates an increase in toll-reporting costs with a present value of $29,019 over 10 years (annualized $4,132).
  • Estimated annualized average change for the export/import reporting element: a decrease of about $1,155.
  • Estimated annualized average change for the toll reporting element: an increase of about $1,477.
• Monthly traffic reporting by pipeline companies aims to give regulators and toll payers timelier data for transparency and fair toll setting.
• Better, more relevant data could help the CER publish more accurate market reports, which businesses, investors and the public use to understand supply, demand and prices.
• This is a proposed regulation. Interested parties have 45 days from publication to comment; the rules are not final until the regulatory process is completed.