Toronto\\\’s Proposed Renovictions Bylaw: 2024 Overview

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Originally published July 9, 2024. This article reflects Toronto's proposed renovictions bylaw as it stood at that time.

Toronto's proposed Renovictions Bylaw moved one step closer to becoming reality after receiving unanimous approval, with amendments, from the Planning and Housing Committee on June 13, 2024.

The proposal was intended to address concerns about “renovictions,” where tenants are displaced under the stated need for major renovations.

At the time, the proposal raised important questions for both tenants and property owners about how the City would distinguish legitimate renovation work from bad-faith attempts to end a tenancy.

The Purpose of the Proposed Renovictions Bylaw

The primary goal of the proposal was to provide additional protection for tenants facing displacement because of major renovations.

The discussion took place amid broader concerns about the loss of affordable rental housing and allegations that some renovation-related evictions were being used to remove existing tenants and re-rent units at substantially higher market rents.

For property owners, however, the proposal also raised practical questions about legitimate renovations that genuinely require a rental unit to be vacant.

How the Proposed Bylaw Could Affect Property Owners

Additional Administrative Requirements

One concern for landlords was the possibility of additional City documentation and administrative requirements when undertaking renovation work that required tenants to leave a unit temporarily.

Owners undertaking legitimate work could need to demonstrate that the renovation was substantial enough to require vacancy and that the necessary building permits and documentation were in place.

Potential Impact on Renovation Timelines

Additional documentation and municipal processes could also affect project schedules.

For owners of older rental housing, delays can be particularly important when work involves building systems, structural repairs, or upgrades that cannot reasonably be completed while a tenant remains in the unit.

Potential Unintended Consequences

Although the stated purpose of the bylaw was tenant protection, some property owners were concerned that additional complexity could discourage legitimate investment in aging rental properties.

Owners facing higher compliance, financing, and construction costs could become more reluctant to undertake optional improvements or major upgrades.

There was also concern that some of those additional costs could ultimately influence the economics of renovated rental housing.

Renovictions Were Already Receiving Greater Scrutiny

The proposed Toronto bylaw was introduced against a backdrop of increasing attention to N12 and N13 notices across Ontario.

A report cited by ACORN Canada found that between 2017 and 2021, Ontario experienced a 70% increase in N12 filings, with 18,151 notices filed during that period.

Toronto recorded 5,085 of those notices, while Brampton recorded 1,193.

The same reporting indicated that N13 notices associated with demolition, conversion, or major repair and renovation work increased significantly between 2017 and 2022.

These figures helped explain why renovation-related evictions had become a more prominent policy issue by 2024.

What Property Owners Could Do at the Time

For landlords planning significant renovations, the safest approach was to document the project carefully and ensure that the proposed work, permits, notices, and construction plan were properly coordinated.

Renovation-related tenancy matters can involve both construction and residential-tenancy law, so owners considering work that could affect an occupied unit were advised to obtain appropriate legal guidance.

Professional Property Management can also help coordinate tenant communication and property operations alongside a larger renovation project.

Where construction itself is substantial, an integrated Design-Build process can help owners coordinate feasibility, permitting, budgeting, and construction planning.

Why the Debate Mattered

The renovictions debate highlighted a difficult policy balance.

Tenants need meaningful protection against bad-faith eviction. At the same time, Toronto's aging rental housing stock requires ongoing investment, repairs, and modernization.

The challenge for policymakers was to create rules strong enough to deter abuse without making legitimate renovation work unnecessarily difficult.

As of this article's original July 2024 publication, the Toronto proposal was still evolving, and property owners were watching closely to understand what the final requirements would mean for future renovation projects.