Toronto, Hamilton and London all passed similar anti-renoviction bylaws in 2024 intended to prevent evictions under the guise of renovations. But now, as the three municipalities prepare to implement their new licensing programs in June/July of 2025, some experts warn that the incoming requirements may do more harm than good. According to the three panelists who spoke at the “Revitalize and Relocate” seminar on December 6 at the Buildings Show in Toronto, landlords and tenants should expect more delays and disruptions to the renovations process, with trickier timelines that will likely lead to fewer new rental units and sub-par conditions going unaddressed—especially given landlords aren’t able to increase rents for returning tenants after investing heavily in their properties.
“It’s all just a lot of political smoke-blowing,” said Justin Taylor, Chief Operating Officer at Signet Group and Chair of the Greater Toronto Apartment Association. “The City of Toronto is instituting a program ostensibly to protect the rights of tenants from improper use of N13s when those protections are already in place under the RTA. Currently, corporations can be charged $250k per unit on top of a year’s rent for bad faith evictions. Adding this new licencing requirement will only make the planning process longer, more complicated, and more expensive—to no one’s best interest except to garner votes and add some revenue for the City.”
As Taylor pointed out, it isn’t usually necessary to move tenants out of their suites to perform renovations, except in the case of emergencies, substantial upgrades, and of course, demolitions.
“I am unaware of any major landlords that are moving people out under false pretences,” he added, noting that City staff have stated only about 120 bad faith incidents occur each year. “These are coming from small landlords, condo rental owners or home owners who likely want to end their rental agreements to sell their properties or to increase income, as costs for upkeep, taxes, utilities, condo fees, and mortgages have all far outpaced annual guideline increases.”
When the Notice to End Tenancy is needed
The N13 form is a legal document used by Ontario landlords to notify tenants of the termination of their tenancy for a pending demolition, conversion, renovation or major repair. Previously, the permit application sufficed as proof of the intended work, but beginning in July 2025, landlords will need to obtain a building permit before filing for a Residential Rental Renovation Licence within seven days of issuing an N13 notice. The landlord will also have to post a city-provided Tenant Information Notice at each affected unit informing tenants that the licence has been applied for and instructing them on how to obtain information about their rights.
The cost for the licence will be $700 per unit in Toronto and Hamilton, and $600 per unit in London. Though each municipality’s bylaw differs slightly, documents needed to get the license may include: a report from a qualified building professional confirming the need for the unit to be vacated; confirmation of the approved building permits; confirmation that the Tenant Information Notice was posted; a copy of the N13 notice; and a tenant accommodation and compensation plan, ensuring all displaced tenants have temporary housing or monthly ‘rent-gap’ payments to cover the rent difference if they find their own interim accommodations.
According to Kristin Ley, Partner at Cohen Highley LLP Lawyers, incorrectly completing an N13 form in Toronto can have significant repercussions for property owners in that errors or omissions may lead to delays, penalties, or even fines up to $100,000 for a failure to comply.
“There is already a lot of uncertainty in the renovation process, and this will only exacerbate and complicate that process more,” she said. “With multiple timelines running at once, knowledge and coordination will be key. Landlords will have to be aware of all the steps and have everything in order so that when they get to their hearing, they can be successful.”
Harry Fine, a former LTB adjudicator, licensed paralegal and former director of the Paralegal Society of Ontario, concurred, adding that landlords have been painted as the “bad guys” by various levels of government and the media—especially since COVID-19—and now the majority are paying the price for the undeserved reputation.
“These new bylaws won’t make it easy, especially for the small mom and pop landlords who are trying to comply and make the necessary improvements at their properties,” he said. “We may see more instances where landlords are making private deals with their tenants to get them to move out rather than going through the official eviction process.”
Fine refers to this approach as “Cash for Keys”, describing it as a route taken by a landlord to remove the risk of being rejected for city-approved evictions or to move things along quickly before permits expire. This type of deal involves the tenant agreeing to leave without the right to return, with compensation usually starting at about four months’ rent. However, as Fine noted, even that sum is often insufficient to compensate for the increased rent tenants will pay if they agree to move out of their current unit.
“An alternative will be to do smaller, quicker jobs on an individual basis rather than undertaking full renovation projects,” he said. “This might allow the tenant to stay in the unit while the work is being done, or perhaps the tenant will be satisfied with a five-day stay at a hotel while the renovations occur.”
According to Ley, landlords need to understand that regardless of how they choose to approach their renovations in the future, with or without the N13, they should expect to pay more than they used to.
“The bylaws, especially those in Toronto and Hamilton, have introduced tremendous cost for a landlord to carry out necessary repairs to their properties where vacant possession is required,” she said. “If some work can be accomplished while the tenants remain in the units, that will likely be preferred, but landlords will then need to ensure that they are complying with a different set of regulations to minimize liability (i.e. rent abatements) relative to any potential interference with tenants’ reasonable enjoyment.”
