Reminder: Directive 040 pressure and Packer Isolation Test requirements

Directive 040 Section 2.2.3 requires that annual pressure and testing surveys be completed by December 31, 2025 and submitted by March 31, 2026. 

Failure to obtain and submit the required pressures and, in some instances, fluid analysis, will result in a $1000 administrative penalty (fine) plus you will still have to obtain and submit the test data to fulfil the 2025 requirement. Contact us if you require assistance requesting a waiver.

The list of wells and projects requiring annual testing can be found HERE

Directive 087: Well Integrity Management Section 2 Table 1 requires that packer isolation tests (PIT) results must be conducted and reported on qualifying wells by the end of December 31, 2025. Results of PITs must be submitted on the AER’s Form F022: Packer Test Record.

AB: Release of AERH2S Model

On November 4, 2025, the AER released AERH2S model for determining emergency planning zones (EPZ) for all sour well and pipeline applications. AERH2S is an updated and renamed version of the AER’s existing model, ERCBH2S, first released in 2008.

AERH2S is available for use immediately. However, the AER have adopted a phased implementation for the release of the revised model. Until further notice, use of AERH2S is optional for Directive 071: Emergency Preparedness and Response updates to EPZs established before January 1, 2026. ERCBH2S remains effective, available, and accepted by the AER for existing EPZs. The use of AERH2S under Directive 071 is required for any Directive 056 applications made after January 1, 2026, including amendment applications.

The AER have also released an updated technical reference document and user guide. The AERH2S model and the support materials are available on the AER website under Systems and Tools.

There have been no updates to the CAPP guidelines, and CAPP Guideline: H₂S Release Rate and Audit Forms (July 2012) remains current.

Additional information can be found in Bulletin 2025-34


At Benoit Regulatory Compliance, we prepare H₂S Release Rate Reports and EPZ calculations for new well applications, ensuring full compliance with AER requirements. Our team works closely with operators to deliver clear, reliable reports to keep projects moving forward without delays. 

AB: Release of Site-Specific Risk Assessment Submission Checklist

On November 4, 2025, the AER published the “Site-Specific Risk Assessment Submission Checklist” (SSRA checklist).

The Alberta Tier 2 Soil and Groundwater Remediation Guidelines (part of the Remediation Regulation under the Environmental Protection and Enhancement Act) specify the requirement to seek acceptance of an SSRA by the appropriate regulator. In August 2022, Alberta Environment and Protected Areas published Supplemental Guidance on Site-Specific Risk Assessments in Alberta.



The SSRA checklist is a summary of the minimum expectations when submitting an SSRA. The checklist’s purpose is to assist in compiling and submitting SSRAs to the AER, facilitating a consistent and efficient review. It is recommended, though voluntary, that the completed SSRA checklist be included with the record of site condition submission through OneStop.

For details on contamination management requirements and AER processes, see Manual 021: Contamination Management.

Additional information can be found in Bulletin 2025-33

SK: Updates

October 28, 2025: The ER posted notice to inform industry of wording changes to the Annulus Test Import data form "How To" sheet. The changes were required to provide clarity to the data input surrounding the questions regarding "Continuous Monitoring". The updated version can be found here: Annulus Test Import data file.



October 30, 2025: The Government of Saskatchewan has been informed that the Canadian Centre for Cyber Security (CCCS) is reporting a significant increase in cyberattacks targeting Industrial Control Systems (ICS) across critical sectors, including water, oil and agriculture. The CCCS alert contains direction on how to report such activity. To learn more about current cyber alerts, visit the Canadian Centre for Cyber Security.

BC: Mandate Expansion – Updates for Operators

On November 7, 2025, the BCER announced several updates to systems, processes and documentation to further enhance permitting efficiency and transparency. 

While the changes primarily apply to Renewable Energy and Prescribed Transmission Line proponents, there are some changes for other energy operators to be aware of.

Changes for all proponents:

1. The Oil and Gas Activity Application Manual and the Oil and Gas Activity Operations Manual have been renamed the Energy Resource Activity Application Manual and Energy Resource Activity Operations Manual.All existing links and bookmarks will now point to the renamed documents.
2. The Rights Holder Engagement (RHE) line list in the Application Management System (AMS) has been updated to reflect changes for the new prescribed transmission line activity types. After November 6, 2025, applicants should complete and upload the newest version of the RHE line list in their application. The updated RHE line list can be found in the supporting documents section of Chapter 6 of the Energy Resource Activity Application Manual.



Additional information can be found in TU 2025-17

BC: Changes to Orphan Site Restoration Levy 

On Oct. 22, 2025, the BCER approved an increase to the Orphan Site Restoration Levy to ensure adequate funding for restoration of orphan sites.



On November 3, 2025, oil and gas permit holders were invoiced an additional $9 million (to the April 2025 $15 million) to bring the total Orphan Site Restoration Levy to $24 million. This Orphan Site Restoration Levy for oil and gas permit holders will be invoiced annually, starting in 2026.

Additional information can be found in TU 2025-16