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

UPAC thresholds

Chapter 2 · Two thresholds, and exceeding either one is enough.
Who is covered

Two thresholds, and exceeding either one is enough.

Any individual or legal entity is considered a High Energy Consumption User (UPAC) if it has facilities that exceeded either of these criteria in the immediately preceding calendar year (DACG, Article 4).

45 GWh
of electricity per year; applies once exceeded
70,000 boe
of fuels per year, in barrels of oil equivalent; applies once exceeded
The DACG set the fuel threshold at 70,000 boe. The previous value was 100,000: the 30% reduction expanded the pool of facilities covered. The electricity threshold remains at 45 GWh. Transportation fuels are not counted.
Calculate my thresholds
How it is counted

Three clarifications that change the answer.

Most errors in determining whether a facility is a UPAC come from here, rather than from the calculation.

01

By facility, not by corporate group

A group may have one plant well above the threshold, another just below it and a third far from reaching it. Each one is assessed separately.

02

Electricity comes from the utility bills

Twelve months of the facility's billed consumption. It is the most readily available data point and the fastest way to confirm or rule out UPAC status.

03

Fuels, converted to a common unit

Natural gas, LP gas, diesel, fuel oil and any other energy source are converted to barrels of oil equivalent based on their heating value, and then added together.

04

It is reviewed every year

Consumption follows production: an additional shift, a new line or a process change can push a facility across the threshold without anyone noticing.

UPAC Guide 2026

The other chapters.

Free document

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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With each facility’s annual electricity and fuel consumption, we can settle it in one call. If it is, we will tell you what comes next and in what order.

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