On August 6, 2026, the Ontario Ministry of Environment, Conservation and Parks (MECP) announced changes affecting some companies that hold an Environmental Compliance Approval (ECA). Specifically, those companies that hold an ECA facing the deadline to transition to an Air Emissions Environmental Activity and Sector Registry (EASR).
EASR Background
The EASR is an online self-registration registry established by the Ontario Environmental Protection Act (EPA) and implemented by the MECP in 2011. The EPA requires a person who is engaging in certain activities (lower-risk activities) prescribed in the regulation to register those activities in the EASR.
Current Requirement to Transition from an ECA to EASR
On January 31, 2017, changes were made to O.Reg. 1/17 (O. Reg. 1/17: Registration Under Part II.2 of the Act – Activities Requiring Assessment of Air Emissions). These changes gave companies a 10-year window to change from the ECA to the Air Emissions EASR.
This would require those with prescribed business activities that are approved under an ECA to transition to an EASR even if there were no operational changes. This could include preparation of reports (air, noise, odour assessments), dispersion modeling, and more.
The ten-year window for transitioning from an ECA to an EASR is January 31, 2027.
According to a blog post by Blakes, “The current law requires most of these facilities to register on the Environmental Activity and Sector Registry (EASR) by January 31, 2027, or run the risk of penalties for non-compliance. If an eligible facility is required to register but does not do so by the deadline, its ECA will cease to apply on this date. As a result, the January 31, 2027, deadline is more than an administrative requirement; it may affect a facility’s legal authority to carry out the activity. Importantly, the requirement to transition applies even where no operational changes to the facility are contemplated.”
On August 6, 2026, the Ontario MECP issued a notice, “Changing the Transition Requirements in the Air Emissions Environmental Activity and Sector Registry Regulation” (Image purchased from Shutterstock).
MECP Announces Changes
On August 6, 2026, the Ontario MECP issued a notice, “Changing the Transition Requirements in the Air Emissions Environmental Activity and Sector Registry Regulation.”
The proposed changes would remove the requirement to transition from an ECA to an EASR by the January 31, 2027, deadline. Under the proposed changes, registration of the EASR would be required only when the proposed modification to a facility or the activities at the facility would otherwise trigger an amendment to its ECA (Environmental Registry of Ontario).
According to the announcement, instead of the deadline approach, the proposed change-based approach would only be triggered when a facility undertakes changes to its operations that would otherwise require an ECA amendment. These changes may include:
- Modifications that would typically require an amendment to an existing ECA, such as changes to air pollution control equipment or operational parameters that would change air emissions, and
- New activities prescribed under the Air Emissions EASR regulation.
These changes only apply to air and noise emissions under O.Reg. 1/17.
What Should You Do?
If you currently have an air ECA and you have not, or are not planning on, any modifications that would affect your ECA (assuming the proposed changes become final), you can continue to operate under your existing approval. However, keep in mind that changes outlined above would require a transition to an air emission EASR.
If you need assistance with an environmental assessment, permitting, etc., we can help. For more information or for assistance, contact Christopher Paré, P.Geo. (Ext 114), or Ehsan Momeni, P.E. (Ext. 123), at 519-948-7300.
Alan Hahn drafted this blog. Alan has an undergraduate degree in Environmental Studies and completed a graduate program in Environmental Management. He has worked in environmental management for more than 45 years. He has written hundreds of blogs and articles. His published work includes HazMat Magazine, BizX Magazine, Michigan Lawyers Weekly, GreenStone Partners, Manure Manager Magazine, and Progressive Dairy.
Christopher Paré, P.Geo., reviewed this blog. Chris is a senior geoscientist and manager of Dragun’s Windsor, Ontario, office. Chris has more than 35 years of experience on projects ranging from environmental site assessments (Phase One/Two ESA), excess soils, remedial investigations, soil and groundwater remediation, Permits to Take Water, Records of Site Conditions, vapour intrusion, and site decommissioning. Chris is a frequent speaker, author, and expert witness. See Chris’ bio.
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