Building Codes are developed by the Federal government via the Canadian Commission on Building and Fire Codes and published by the National Research Council of Canada.

Provinces then adopt, usually with some amendments (though Manitoba passed a bill to Harmonize with what was released but that Bill was never fully implemented).

Municipalities implement codes through permits and inspections.

Manitoba is in the midst of adopting a new set of Codes

In June 2023 they opened a consultation period that includes collecting feedback on the energy efficiency Tiers. Consultation ends on June 26 2023 at 11:59 PM.

They are proposing that Manitoba adopt energy efficiency Tier 1 across the board.

For commercial this makes sense given that we did skip an entire code cycle.

For residential this decision makes less sense given that many homes in Manitoba are already being built at the equivalent of Tier 2 and 3. This is because Manitoba used to be a leader in energy efficient building thanks to decisions that were made when adopting the 2010 codes, especially thanks to a special heat-recovery ventilation amendment.

You can learn more about how to advocate for higher energy efficiency tiers here.

On October 20th 2022 the Manitoba government announced there plans to accelerate adoption of 2020 National Model Building Codes rather than a two-step adoption of the 2015 editions followed by the adoption of the 2020 codes at a later time.

This is thanks to all the industry feedback so many Manitobans provided. Thank you for speaking up!

Rumoured target adoption date is January 2024, later than the original target date of around November 1st 2023, which means Manitoba will remain a code cycle behind for longer.

The 2020 codes are tiered codes and the first tier of the 2020 codes is very similar to the 2015/17 codes, which the province had planned to implement this year.

According to Manitoba’s current legislation (Building and Mobile Home Act), only the Province has the regulatory power to set what Tier is adopted (unlike BC with their Step Code). Municipalities are the ones that enforce the codes though. This is the where permits come in and those only exist because of bylaws. But no municipalities can put anything in place that forces builders to build above the province’s code. Of course a building owner can do what they want as codes are only a minimum. Of course those jurisdictions can create incentives to go above codes (for example by creating grants) but it cannot be mandatory.

Canada’s 2020 model building codes are ready for provincial/territorial adoption and that is being worked on across the country.  Scoll down to learn more about the codes currently in place in Manitoba.

These codes are the first to have energy efficiency Tiers.

Learn more about Tiered Building Codes – What They Are, Why They Matter, and What It Means for Existing Buildings in Canada from Manitoba’s own ioAirFlow

Manitoba Building Code adption showing that Tier 1 is adopted in 2023 and Tier 2 in 2024 for commercial buildings and 3 Tiers for Resildiencial energy efficiency goes up the higher the Tier

Find out the background on SBM’s building code advocacy efforts for higher Tier adoption.  Energy performance tiers are established to provide a framework for the road map to achieving higher levels of energy efficiency.

Significant Technical Changes – 2020 National Model Codes

Nearly 400 technical changes approved by the Canadian Commission on Building and Fire Codes are introduced in the 2020 editions of Canada’s National Model Codes. The most significant technical changes NATIONAL ENERGY CODE OF CANADA FOR BUILDINGS (NECB) are summarized below.

Click here to see a summary of all the different codes areas that was put together by the Canadian Commission on Building and Fire Codes.

The application of the NECB is extended to cover alterations, such as tenant improvements, to buildings originally constructed in accordance with the Code.

Building envelope
Whole-building airtightness testing is introduced as an option for complying with air leakage requirements. Maximum overall thermal transmittance values for opaque building assemblies and fenestration are reduced to improve the thermal performance of the building envelope.

Lighting power densities are updated to reflect improvements in the efficacy of lighting products available in the North American market. Lighting power allowances are provided for use in additional exterior applications, including applications not listed in the Code.

HVAC and service water systems
The trade-off compliance paths for HVAC and service water systems, which were complex and not widely used, are removed. Performance requirements for HVAC and service water heating equipment are updated to align them with Canada’s Energy Efficiency Regulations and relevant standards, and to add new equipment types.

Tiered energy performance compliance
New Part 10 is introduced to establish a performance compliance path with 4 tiers, each successive tier being increasingly stringent in terms of building energy consumption.

On May 12th 2022, SBM hosted a lunch and learn on the topic

  • What do Manitoban’s need to know about Canada’s first national tiered building codes? 
  • How do these codes differ from conventional codes? 
  • And,what can we do to lay the groundwork for successful adoption and compliance?

Watch recording now on You Tube

NEW MODEL BUILDING CODES what is in them and what can we expect? Thursday May 12 at noon via Zoom with Kevin Lockhart from efficiency Canada and Bob Deeks a Certified Housing Professional


In 1997,
Canada createdthe Model National Energy Code for Buildings,its first national standard for building energy performance.Fourteenyears later, the federal government updated it and renamed it the National Energy Code for Buildings (NECB). The 2011 NECB achieved a 25% performance improvement over its predecessor. The 2015 NECB included changes such as new thermal requirements for semiheated buildings, and maximum allowable lighting power densities harmonized with the ASHRAE 90.1 2013 standard. This version had an average annual energy savings of 2.5% over the 2011 NECB.The National Research Council estimates that the 2017 version of the NECB achieves an average annual savings of 7.8% to 11.9% above the 2015 version. (source:
Efficiency Canada)


Housing and Small Buildings
The Manitoba Building Code is adopted as regulation 31/2011 under the Buildings and Mobile Homes Act. Section 9.36 applies of the Manitoba Code applies to houses and smaller buildings and follows the 2012 National Building Code’s provisions for energy efficiency. The energy efficiency provisions came into force on April 1, 2016.

Large Buildings
The Manitoba Energy Code for Buildings (MECB) was created through regulation 213/2013 under the Buildings and Mobile Homes Act. It applies to “larger buildings” (greater than 600 square meters of floor area). The MECB follows the 2011 National Energy Code of Canada. This code became effective on December 1, 2014.

Stretch or Step Codes
No stretch or step codes have been adopted in Manitoba.

Net-zero energy ready commitment
No formal commitment to adopt net-zero energy ready building codes.

See how Manitoba compares to other provinces

map of canada showing which provinces have adopted which codes.  Manitoba is the only province with its colour

Manitoba is the only province that did not adopt the 2015 codes and so are the only ones building using the 2011 codes.

graph of all the provinces showing that Manitoba is alone
These are the high-level improvements of the 2015 over the 2011 codes:
  • higher insulation values on building envelope (walls, ceilings, fenestration, doors, etc)
  • higher HVAC equipment energy efficiencies
  • higher domestic hot water system equipment energy efficiencies

More details include:

  • Energy codes serve to provide a uniform standard which influences how buildings are designed and built, offering several pathways; meet prescriptive requirements, evaluate trade-offs, or computer modelling of energy performance to show compliance.
  • Each new release of the NECB serves to promote energy efficiency by incrementally raising the minimum performance thresholds of elements such as the windows, insulation and efficiency of heating, cooling and ventilation equipment.
  • Manitoba currently uses the Manitoba Energy Code for Buildings (MECB) which was introduced in 2013 and adopted the National Energy Code for Buildings (NECB) from 2011 with a few amendments. From an energy performance perspective, one of the principal amendments of MECB 2013 was to improve the minimum energy efficiency of windows by about 10%.
  • In the subsequent years, the MECB has not been updated, while other provinces have adopted more recent versions of the NECB, for example Ontario and British Columbian introduced their own specialized building energy codes in 2017, while Saskatchewan and Alberta both adopted the NECB 2017 in 2019.
  • Among the changes that NECB 2017 introduced was the requirement to include the impact of thermal bridging, where a building component  such as framing members or balconies allows heat to easily bypass the insulation layer, and lowers the effective thermal resistance of the building envelope.  Depending on the type of construction, this can be a significant change which will generally require more insulation and careful detailing to pass Code.
  • Manitoba is now lagging behind in code adoption, and while further delays won’t be doing our building industry any favours, it is important to introduce a new code in a manner which is carefully planned and well supported.  New buildings constructed today will need to fit into Canada’s strategy to achieve Net Zero by 2050 and deliver on its commitments to address the climate change crisis.


 Report on Strengthening Canada’s Building Code Process from Efficiency Canada

Report on Tiered Energy Codes Best Practices for Code Compliance


Future Codes

In 2021 the Manitoba Government passed Bill 38 (The Building and Electrical Permitting Improvement Act) to harmonize with the National model building codes.

SBM submitted this letter of support for Bill 38 in January 2021

Some additional background:

1. The 24 month and 18 month period in the legislation is required to allow projects in the design phase to proceed to construction/permitting phase with certainty of not having to redo the design.  Developers, consultants and contractors require this certainty for budgets, schedules, etc.  It also allows time for the stakeholders to be educated on the additional requirements in the new code.  In other words, you can’t just flip a switch and have the code come into effect without a lot of market disruption.  Please note that NECB 2011 was proclaimed on December 20, 2013 and came into effect in Manitoba on December 31, 2014 and that SBM and others did lots of educational programming for that to happen so quickly!

2. Here is the Regulation that adopted the NECB 2011 and amendments.  It is hard to tell  how significant the amendments were but there is nothing in Bill 38 that prohibits Manitoba from doing amendments.  The opinions are that the new code requirements and frequency of new codes are going to be so incrementally greater than previous, that amendments will not be an issue anyways – it will be fast and furious!

3. It has been mentioned that the Manitoba Building Codes committee is not active any longer and that Manitoba input into the code development will be diminished. The Canadian Commission on Building and Fire Codes policy position is to “analyze the impact of a uniform performance goal for all of Canada compared to regionally-specific goals and pay particular attention to constraints in Canada’s North.”  As well, CCBFC works closely with the Provincial/Territorial Policy Advisory Committee on Codes (PTPACC) of which Manitoba is represented.

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