Ontario Regulation 633/21, made under section 25.35.8 of the Electricity Act, 1998, requires Ontario electricity and natural gas local distribution companies to make customer energy data available in the Green Button format — both Download My Data and Connect My Data. It is the only consumer energy data mandate in Canada and one of very few anywhere that compels adoption of an externally-authored standard rather than creating a data right of its own.
Ontario Regulation 633/21
Statute Ontario, Canada
O. Reg. 633/21 is the cleanest available test of a specific regulatory design: what happens when a government mandates adoption of a standard someone else wrote, rather than building a data right.
Made under the Electricity Act, 1998, it requires Ontario’s licensed electricity and gas distributors to offer Green Button — both Download My Data (a customer-exported file) and Connect My Data (a consented third-party API). The Ontario Energy Board supervises.
- Province-scale - Ontario only. There is no federal Canadian equivalent and no other province has followed, which makes Canada the one country where a mandated and an unmandated utility cohort can be compared under otherwise similar conditions.
- Standard-adoption, not right-creation - it points at an existing NAESB specification rather than commissioning schemas, an accreditation regime or a register. That is far cheaper to legislate.
- Supervised by an energy regulator - the OEB has a broad remit and no API programme, which is a different enforcement posture from a dedicated data-standards body.
What it produced
The State of Canadian Energy APIs scored eighteen organizations. Ontario’s bound utilities land in Thin and Emerging — Hydro Ottawa 40.4, Toronto Hydro 39.7, Alectra 27.7, Hydro One 23.1 — against a national average of 32.8. The highest score in Canada, 51.6 with the market’s best agent-readiness at 87.5, belongs to Hydro-Québec: a Crown corporation in a province with no data mandate at all.
Two of the bound utilities were recorded as claiming a compliance that could not be verified from outside. In one case the onboarding host returns HTTP 200 for every path requested of it, including invented control paths, because it is a single-page-app catch-all — precisely how a compliance claim comes to look like an implementation.
The regulation did do one thing no unmandated market managed: three Ontario utilities publish the same Green Button ESPI specification, a genuine shared vocabulary. But they implement a document the Green Button Alliance wrote, and conformance is not the same as building an API.
The comparison that matters
Set this against the Consumer Data Right, which was extended to Australian energy in the same period. Australia legislated a data right — primary legislation, a dedicated regulator, a standards body writing conformant schemas, an accreditation regime, a public register and a security profile every participant implements identically — and produced thirteen live consumer APIs and a market average of 41.6.
Ontario required adoption of a standard and produced three conformance implementations and two unverifiable claims.
Both are called mandates. They are not comparable instruments, and the difference is the machinery behind them. Across the ninety-five energy organizations researched for that quartet, a verified mandate was worth about twelve points and a merely-claimed one was worth less than having no obligation at all.
Referenced in API Evangelist papers
This regulation shows up in my published research. These reports read the machine-readable evidence provider by provider — and put this regulation in the context of a real sector.
The State of Canadian Energy APIs
The only consumer energy data mandate in Canada — and its bound utilities cluster in Thin and Emerging while the country's best energy API belongs to a province with no mandate at all.
Implemented by these standards
A regulation is the law; a standard is the machine-readable contract that makes it real. These are the technical standards that implement this regulation, catalogued at standards.apievangelist.com.
Green Button
The standard this regulation makes compulsory for Ontario's licensed distributors, at NAESB REQ.21 ESPI v3.3.
