2025–26 Annual Report of the Commission of the Canada Energy Regulator - Appendix J: Financial Resources Requirements
The CER Act requires companies operating oil and gas pipelines to set aside financial resources to cover the costs of any unintended or uncontrolled release from a pipeline, such as a spill. The financial resources sections of the CER Act reinforce the “polluter pays” principle. Companies are required to maintain financial resources that, at a minimum, match the absolute liability limit applicable to the company. The Pipeline Financial Requirements Regulations (Regulations), which came into force in July 2019, set out absolute liability limits for CER-regulated companies. These absolute liability limits range from $200 million to $1 billion for oil pipelines, $10 million to $200 million for gas pipelines, and $5 million to $10 million for other commodity pipelines, depending on factors such as pipeline capacity, diameter, and commodity transported.
The Regulations outline the specific types of financial instruments that the Commission may order companies to maintain, as well as the minimum portion of the financial resources required to be readily accessible to the company. The financial resource types prescribed by the Regulations are as follows:
- Insurance policy;
- Escrow agreement;
- Letter of credit;
- Line of credit;
- Participation in a pooled fund, as referred to in subsection 139(1) of the CER Act;
- Parent company guarantees;
- Surety bond or pledge agreement, or indemnity bond or suretyship agreement; and
- Cash or cash equivalents.
The Regulations also state that only authorized in-service pipelines will be considered in the determination of a company’s absolute liability class. Therefore, those pipelines that are not in service are currently exempt from filing an absolute liability limit and financial resources plan.
To ensure compliance with the Regulations, the CER developed filing guidance and required all companies to file financial resources plans for evaluation. These plans set out the financial resources each company has available to respond to releases and demonstrate how companies meet the financial resources requirements in the CER Act and Regulations. If the plans are insufficient, the Commission has the authority to order companies to maintain additional financial resources.
Table J.1: CER Regulated Companies Financial Resource Plan Evaluation Status: Active companies
| Company | Class | Absolute Liability Limit (ALL) | Status of Financial Resources Plan |
|---|---|---|---|
| 1057533 Alberta Ltd. | Oil Class 3 | $200 million | Approved |
| 2193914 Canada Limited | Gas Class 1 | $200 million | Approved |
| 6720471 Canada Ltd. | Gas Class 4 | $10 million | Approved |
| Alliance Pipeline Ltd., on behalf of Alliance Pipeline Limited Partnership | Gas Class 1 | $200 million | Approved |
| ARC Resources Ltd. | Gas Class 2 | $50 million | Approved |
| Astara Energy Corp. | Gas Class 2 | $50 million | Approved |
| Aurora Pipeline Company Ltd. | Oil Class 2 | $300 million | Approved |
| Campus Energy Partners Operations Inc. | Gas Class 1 | $200 million | Under Review |
| Canada Border Services Agency | Gas Class 4 | $10 million | Approved |
| Canadian-Montana Pipe Line Corporation | Gas Class 2 | $50 million | Approved |
| Cavvy Production Ltd. | Gas Class 2 | $50 million | Conditional Approval |
| Cenovus Energy Inc. | Oil Class 2 | $300 million | Approved |
| Centra Transmission Holdings Inc. | Gas Class 2 | $50 million | Approved |
| Champion Pipe Line Corporation Limited | Gas Class 2 | $50 million | Approved |
| Chief Mountain Gas Co-op Ltd. | Gas Class 4 | $10 million | Approved |
| Canadian Natural Resources Ltd. | Oil Class 2 | $300 million | Approved |
| Emera Brunswick Pipeline Company Ltd. | Gas Class 1 | $200 million | Approved |
| Enbridge Bakken Pipeline Company Inc., on behalf of Enbridge Bakken Pipeline Limited Partnership | Oil Class 2 | $300 million | Approved |
| Enbridge Gas Inc. | Gas Class 2 | $50 million | Approved |
| Enbridge Pipelines (NW) Inc. | Oil Class 3 | $200 million | Approved |
| Enbridge Southern Lights GP Inc. on behalf of Enbridge Southern Lights LP | Oil Class 2 | $300 million | Approved |
| Enbridge Pipelines Inc | Oil Class 1 | $1 billion | Approved |
| Enercapita Energy Ltd. | Gas Class 2 | $50 million | Approved |
| Energy Transfer Operations GP LLC on behalf of Sunoco Pipeline LP | Gas Class 2 | $50 million | Approved |
| Express Pipeline Ltd. | Oil Class 1 | $1 billion | Approved |
| Foothills Pipe Lines Ltd. | Gas Class 1 | $200 million | Approved |
| FortisBC Huntingdon Inc. | Gas Class 1 | $200 million | Approved |
| Genesis Pipeline Canada Ltd. | Oil Class 2 | $300 million | Approved |
| Great Lakes Pipeline Canada Ltd. | Gas Class 1 | $200 million | Approved |
| Kingston Midstream Westspur Limited | Oil Class 2 | $300 million | Approved |
| Kinder Morgan Utopia Ltd. | Oil Class 2 | $300 million | Approved |
| LBX Pipeline Ltd. | Oil Class 2 | $300 million | Approved |
| Lignite Pipeline Canada Corp. | Gas Class 2 | $50 million | Approved |
| Maritimes & Northeast Pipeline Management Limited | Gas Class 1 | $200 million | Approved |
| Many Islands Pipe Lines (Canada) Ltd. | Gas Class 1 | $200 million | Approved |
| Milk River Pipeline Ltd. | Oil Class 2 | $300 million | Approved |
| Minell Pipeline Ltd. | Gas Class 2 | $50 million | Approved |
| Montreal Pipe Line Limited | Oil Class 2 | $300 million | Approved |
| NOVA Gas Transmission Ltd. | Gas Class 1 | $200 million | Approved |
| Niagara Gas Transmission Limited | Gas Class 1 | $200 million | Approved |
| NorthRiver Midstream Canada Partner Limited, as general partner and on behalf of NorthRiver Midstream Canada LP | Gas Class 2 | $50 million | Approved |
| NorthRiver Midstream G and P Canada Pipelines Inc. | Gas Class 1 | $200 million | Approved |
| Ovintiv Canada ULC | Gas Class 2 | $50 million | Approved |
| PKM Cochin ULC | Oil Class 2 | $300 million | Approved |
| Pembina Energy Services Inc. | Gas Class 2 | $50 million | Approved |
| Pembina Prairie Facilities Ltd. | Gas Class 2 | $50 million | Approved |
| Pine Cliff Border Pipelines Ltd. | Gas Class 2 | $50 million | Approved |
| Pine Cliff Energy Ltd. | Gas Class 2 | $50 million | Approved |
| Plains Midstream Canada ULC | Oil Class 1 | $1 billion | Approved |
| Pouce Coupé Pipe Line Ltd. | Oil Class 2 | $300 million | Approved |
| Prairie Thunder Resources Limited | Oil Class 3 | $200 million | Approved |
| SCL Pipeline Inc. | Gas Class 2 | $50 million | Approved |
| Souris Valley Pipeline Limited | CO2 or Water Class | $5 million | Approved |
| South Bow GP | Oil Class 1 | $1 billion | Approved |
| St. Clair Pipelines Management Inc. on behalf of St. Clair Pipelines L.P. | Gas Class 1 | $200 million | Approved |
| Steel Reef Pipelines Canada Corp. | Gas Class 2 | $50 million | Approved |
| Strathcona Resources Ltd. | Gas Class 3 | $50 million | Approved |
| Surge Energy Inc. | Gas Class 3 | $50 million | Approved |
| TransCanada Pipelines Limited | Gas Class 1 | $200 million | Approved |
| Tidewater Midstream and Infrastructure Ltd. | Gas Class 2 | $50 million | Under Review |
| Trans-Northern Pipelines Inc. | Oil Class 2 | $300 million | Under Review |
| Trans Québec and Maritimes Pipeline Inc. | Gas Class 1 | $200 million | Approved |
| Trans Mountain Pipeline ULC | Oil Class 1 | $1 billion | Approved |
| Tundra Oil & Gas Limited | Oil Class 3 | $200 million | Approved |
| Twin Rivers Pulp Ltd. | Other Commodity Class 1 | $10 million | Approved |
| Vector Pipeline Limited on behalf of Vector Pipeline Limited Partnership | Gas Class 1 | $200 million | Approved |
| Veresen Energy Pipeline Inc. | Gas Class 1 | $200 million | Approved |
| Veresen NGL Pipeline Inc. | Gas Class 2 | $50 million | Approved |
| County of Vermilion River No. 24 Gas Utility | Gas Class 4 | $10 million | Approved |
| Westcoast Energy Inc. | Gas Class 1 | $200 million | Approved |
| Westover Express Pipeline Ltd. (used to be Enbridge Line 10) | Oil Class 2 | $300 million | Approved |
| Whitecap Resources Inc. | Oil Class 2 | $300 million | Approved |
| Zibi Community Utility | CO2 or Water Class | $5 million | Approved |
Table J.2: CER Regulated Companies Financial Resource Plan Evaluation Status: Non-active companies (Abandoned)
| Company | Class | Absolute Liability Limit (ALL) | Status of Pipeline |
|---|---|---|---|
| 2670568 Ontario Limited (formerly Resolute FP Ltd) | not applicable | not applicable | Deactivated |
| AltaGas Holdings Inc. for and on behalf of AltaGas Pipeline Partnership | not applicable | not applicable | Abandoned |
| Canlin Energy Corporation | not applicable | not applicable | Deactivated |
| DR Four Beat Energy Corp. | not applicable | not applicable | Orphaned |
| ExxonMobil Canada Ltd. | not applicable | not applicable | Abandoned |
| Forty Mile Gas Co-op | not applicable | not applicable | Abandoned |
| Lotus Creek Exploration Inc. | not applicable | not applicable | Deactivated |
| Glencoe Resources Ltd. | not applicable | not applicable | Orphaned |
| ISH Energy Ltd. | not applicable | not applicable | Abandoned |
| Kiwetinohk Energy Corp. | not applicable | not applicable | Abandoned |
| Kingston Midstream Virden Limited | not applicable | not applicable | Deactivated |
| Obsidian Energy Ltd. | not applicable | not applicable | Abandoned |
| Omimex Canada, Ltd. | not applicable | not applicable | Abandoned |
| Portal Municipal Gas Company Canada Inc. | not applicable | not applicable | Deactivated |
| Prospera Energy Inc. | not applicable | not applicable | Abandoned |
| SanLing Energy Ltd. | not applicable | not applicable | Orphaned |
| Shiha Energy Transmission Ltd. | not applicable | not applicable | Deactivated |
| Spartan Delta Corp. | not applicable | not applicable | Abandoned |
| Strategic Oil & Gas (Strategic Transmission) | not applicable | not applicable | Orphaned |
| Tamarack Acquisition Corp. | not applicable | not applicable | Abandoned |
| TAQA North Ltd. | not applicable | not applicable | Abandoned |
| Terra Energy Corp. | not applicable | not applicable | Orphaned |
| Tourmaline Oil Corp. | not applicable | not applicable | Abandoned |
| Whitecap Resources Inc. (formerly, Veren Inc.)Footnote 11 | not applicable | not applicable | Deactivated, Abandoned |
| Vermilion Energy Inc. | not applicable | not applicable | Abandoned |
| Yoho Resources Inc./SanLing | not applicable | not applicable | Abandoned |
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