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Updated: · Includes the DACG of September 30, 2026
UPAC Guide 2026 · From Voluntary to Mandatory

If you're near the threshold

Chapter 6 · Four reasons to get ahead, and two that weigh more than the regulatory one.
For those not yet covered

If you're near the threshold, it pays to look at it now.

With the DACG, the fuel threshold was set at 70,000 barrels of oil equivalent (boe) per year, 30% below the previous value of 100,000. If your facility is close—for example, above 56,000 boe, or 80% of the threshold—it pays to do the exercise now, with time to spare.

01

Starting late costs more than starting on time

A management system rests on an energy baseline built from measured data covering at least one full operating cycle. The same implementation, carried out with two years of lead time or with eight months, neither costs the same nor delivers the same.

02

Technical capacity is finite

With broader coverage and certification required by January 2028, demand for consultants and for certification-body auditor days will concentrate in the same window. Those who contract in a calm market negotiate better terms.

03

At that level of consumption, efficiency pays for itself

A well-run system delivers reductions on the order of 5 to 15% of consumption. If a company is about to become a UPAC, it already has the problem that ISO 50001 solves. The obligation only puts a date on it.

04

Being close to the threshold almost always means growing

Without measurement, it is impossible to know how much of an increase comes from growth and how much from waste. And customers in demanding supply chains ask for consumption and footprint data.

In summary

The same project, two different moments.

Starting nowStarting when it becomes enforceable
You choose the support model that suits youYou take whatever is available
The energy baseline is built from real data over a full cycleYou work with whatever data there is time to gather
The project is planned over two to three yearsThe project is compressed into whatever time remains
The system is designed to save, and complies along the wayThe system is designed to comply, and rarely saves
You contract in a calm marketYou contract in a saturated market
The difference between a system that saves and one that only complies lies in the assessment. If the energy baseline and the main energy uses come from field measurements, the system points to where to act. If they come from estimates, the system documents but does not steer.
UPAC Guide 2026

The other chapters.

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From Voluntary to Mandatory

A 19-page corporate guide with the article-by-article comparison, the three new obligations under the Regulations, what the law provides regarding penalties, the DACG thresholds and deadlines, the AVEE and a fourteen-question self-assessment. We will send it to your email.

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