Category: Toronto City Council

The City of Toronto is in the process of developing a new renovictions bylaw aimed at protecting renters from illegitimate evictions and preserving the dwindling stock of affordable housing. To gather public input, the City held a series of consultations from August 13 to September 30, 2024. These included in-person and virtual drop-in sessions, an online survey, and various focus groups. Below are our key recommendations for the proposed bylaw.

What can the City do to make the rules clearer and easier for landlords or property owners who want to renovate their apartments and follow the rules?

The City should take measures to ensure that landlords are well informed and have access to education and training opportunities, including by collaborating with community agencies. This should include a clear understanding of tenant rights and landlord responsibilities related to habitability standards to ensure that units are maintained in a state of good repair, and that renovations requiring vacant possession are rarely required. The City and landlords alike should work to ensure that tenant displacement is avoided at all costs and tenants’ security of tenure is protected through the Renovictions Bylaw.  

Ideally, the renovation licensing system should be integrated with the City’s RentSafeTO program and new multi-tenant housing licensing framework to form a more robust landlord licensing system that provides clear, accessible information and holds landlords accountable to upholding habitability and safety standards in all rental buildings. This would provide a more streamlined, accessible, and accountable process with clear direction for landlords. This system could also include stopgap measures to require landlords to explore all possible avenues to complete repairs and renovations without displacing tenants, which could include access to guidance, tools, and/or other supports. 

The Renovictions Bylaw should also ensure that there is a clear, accessible process for landlords to apply for a renovation license, without any loopholes and minimal exemptions. This could include tying the building permit application process to the licensing system to ensure landlords do not bypass the licensing system once they obtain their permits. This integrated licensing system would also provide opportunities for regular, ongoing checks and balances on renovation projects and tenant displacement. The City could also advocate to the provincial government to coordinate this process with the issuance of N13 notices by the Landlord and Tenant Board for a fulsome, integrated monitoring and accountability framework to ensure all parties are well-informed, renovations are being carried out in good faith, and tenants are adequately supported if vacant possession is required. 

The Renovictions Bylaw should also make clear that the onus of proof for renovations requiring vacant possession is on landlords, not tenants. In addition to license requirements (e.g., application fee, N13 notice, building permit, qualified persons report), this should also include landlord requirements related to tenant notification and accommodation plans, both before, during, and after the renovations are completed. To support this process, the City (potentially in collaboration with tenant support organizations) could create tools and/or templates to support both landlords and tenants in meeting the requirements of the Renovictions Bylaw (e.g., British Columbia Tenant Notice: Exercising Right of First Refusal). 

Licence applications should also explicitly require consent or confirmation from the tenant that they agree to the arrangements outlined in the tenant accommodation plans, including as it relates to temporary accommodation or compensation (which should reflect asking rents and moving costs), as well as conditions for the tenant to return to the unit if they exercise their first right of refusal (e.g., rental rates and increases, occupancy of the same unit, access to amenities, etc.). For tenants that do not exercise their right of first refusal, the Bylaw should require landlords to provide adequate compensation for the loss of affordable housing (similar to the rent gap assistance for temporary relocation, reflecting asking rents). It is critical that any landlord costs (e.g., compensation through tenant accommodation plans and fines for non-compliance) are greater than the cost of doing business to deter bad faith activities. 

To ensure both landlords and tenants are well informed of their rights and responsibilities under the Renovictions Bylaw, the City should prioritize the hiring of additional staff, including for customer service, program support, and enforcement to ensure that: landlords applying for a renovation license have completed all the requirements; tenants have clear, accessible pathways to receive support and report complaints; and there is sufficient on-site enforcement to confirm that renovation activities are proceeding as outlined in the license and that tenants are adequately informed of progress updates.

What supports would you suggest that tenants need in order to exercise their rights to prevent a renoviction, and to understand their rights under a future Renovictions bylaw?  

It is critical that tenants have access to clear information about their housing rights, including as it relates to a future Renovictions Bylaw (e.g., tenant notification requirements, accommodation and compensation plans, exercising right of first refusal, where to access information and support, etc.). To support an equity and rights-based approach, this should include publicly accessible information in multiple languages and formats, with information about tenant rights and where to seek further information and/or support, including from the City and community agencies. As such, the City should work closely with community agencies that have close tenant connections (e.g., legal clinics, settlement agencies, etc.) to conduct a robust education and awareness raising campaign about the Renovictions Bylaw through a variety of formats (e.g., online, phone calls, door knocking, etc.).  

The City should also take a holistic, integrated approach to the implementation of the Renovictions Bylaw across various City departments to ensure that staff are well informed of the Bylaw requirements, as well as tenant rights and landlord responsibilities, to provide adequate service and support. As noted above, this will require resourcing for additional staff positions, including a secure and accessible pathway for tenants to seek information and report violations, as well as for follow up enforcement actions. 

Similarly, the City should ensure that tenants have access to adequate legal information and support. It is encouraging that the City is continuing to support community agencies through the Toronto Tenant Support Program, with a dedicated focus on the Renovictions Bylaw, and it will be equally important to ensure tenants are well informed of where they can access legal information and support across the city.  As noted above, this could also include access to guidance, tools, and templates related to exercising the right of first refusal, tenant notification requirements, and accommodation and compensation plans. To ensure accommodation plans are developed in good faith and with full tenant consent, the Renovictions Bylaw could also include a requirement for an independent tenant and/or legal verification process to oversee the development of the accommodation plans. Finally, the Renovictions Bylaw should provide flexibility around timelines (e.g., 120 day notice period) to ensure tenants have sufficient time to access legal information and support to make an informed decision. 

What are the most important things for the City to consider as it is developing a Renovictions bylaw for Toronto?

To ensure the City is taking a rights-based approach to the Renovictions Bylaw, it should be focused on preventing tenant displacement, protecting tenants’ security of tenure, and preserving affordability across the city. In the context of the current rental housing crisis and provincial landscape (i.e., soaring rents, low vacancy rates, few affordable options, and vacancy decontrol), landlords are strongly incentivized to evict tenants paying below market rents in order to bring in tenants that can pay higher market rates. This pattern disproportionally impacts low-income, racialized, and other marginalized tenants, leading to increasing rates of housing precarity and homelessness. 

As such, where vacant possession is proven to be necessary under the Renovictions Bylaw, tenants should be adequately supported and compensated in a way that reflects the current cost of renting (i.e., asking rents, rather than average market rents), as well as moving costs (both in and out). Tenant accommodations plans should reflect a rights-based approach, recognizing different tenant needs based on neighbourhood services/amenities (e.g., childcare, schools, healthcare, employment, etc.), family size/status, accessibility, and cultural adequacy.  

As noted above, the Renovictions Bylaw should ensure that tenants are well informed throughout the entire process, including as it relates to their rights (e.g., right of first refusal, notification requirements, accommodation and compensation, etc.), progress updates on the license application and renovation process, where to seek legal information and support, and channels to report violations. 

The City should also seek to integrate the Renovictions Bylaw with the new multi-tenant housing (MTH) licensing framework, recognizing that MTH tenants are some of the most marginalized communities in the city, and the most vulnerable to displacement. As noted above, the City should take a holistic landlord licensing approach, which should include sufficient resourcing for the MTH renovation program, in addition to temporary accommodations for displaced tenants. 

To ensure the Renovictions Bylaw meets its stated goals of protecting tenants and preserving affordable, habitable homes, it should include robust and well-resourced monitoring, enforcement, and evaluation mechanisms, including a sufficient staff complement. This could also include licensing parameters to prevent mass evictions and the impacts of gentrification of lower income neighbourhoods, such as requiring licenses for individual units rather than whole buildings and/or limiting the number of licenses available per year and/or by neighbourhood. 

Above and beyond renovictions, the City should also explore opportunities to address and prevent other types of formal and informal evictions that tenants are facing across the city, which could include implementing a comprehensive rental housing licensing program similar to what some municipalities in British Columbia have adopted (e.g., New Westminster, Ladysmith).

The 2024 City of Toronto Budget commits historic new investments for affordable housing and supports for renters across the city, marking a significant departure from previous budgets focused on keeping property tax increases low and prioritizing homeowners over renters. R2HTO strongly supports the budget’s increased investments toward the preservation of affordable housing and protections for renters, which are critical to advancing the right to housing.  

In particular, we are glad to see a significant increase in funding for MURA beginning this year (funded in part through dedicated funds from the federal HAF), which will expedite the acquisition and preservation of more affordable housing across the city. We are also encouraged by increased investments toward Toronto Rent Bank and TTSP, greater staff complements for EPIC and RentSafeTO, and additional federal funding for the COHB, all of which will help ensure low-income and other vulnerable renters can remain housed.  

We commend Mayor Chow for demonstrating strong acumen around provincial and federal collaboration, securing much needed funding to meet the needs of Toronto residents. Additionally, we support the property tax rate increases, including for multi-residential properties, which will protect renters in rent-controlled units from untenable AGIs. 

Notwithstanding these important investments and initiatives, there are a few key areas where the 2024 budget could have gone further to realize the right to housing for renters across the city.  

Of critical concern is the lack of funding for renter support, education, and protection under the new MTH framework. This poses a significant risk of displacement and homelessness, considering that MTH’s provide some of the city’s most affordable housing to some of its most vulnerable residents. As the City prepares to roll out its new MTH framework in April, it should explore options to support renters, in addition to further engagement and education with MTH operators to discourage and mitigate potential MTH losses. 

While we support the increased investments toward other renter support programs, they fall short of Mayor Chow’s election campaign commitments, which included tripling EPIC and doubling Toronto Rent Bank funding to meet the depth of need facing renters. In fact, as noted below, EPIC received less new funding in the 2024 budget compared to the previous year, while Toronto Rent Bank received the same level of new funding. Further, while additional staff for RentSafeTO will help increase capacity for unit assessments and repairs, the program could have a much greater impact through a more robust landlord licensing system. 

With respect to affordable housing preservation, the Mayor previously committed $100 million annually toward an affordable housing acquisition program, whereas MURA will ultimately receive $100 million over three years. In addition to exploring options to continue scaling up MURA, the City must adequately monitor and report on its efforts toward housing preservation and development to ensure they are not contributing to the loss of existing affordable housing stock. Similarly, immediate action should be taken to expedite the launch of HART, including implementation of the Renovictions By-law and more effective monitoring and reporting on the Rental Demolition and Conversion By-law.

Year-Over-Year Comparison

While gaps remain in the 2024 City of Toronto Budget, it is worth examining some of its key housing-related commitments in relation to previous budgets, considering the significant shifts in approach toward taxation and spending.

	2023	2024	YoY $	YoY %
MTH	+$3.5 million1	+$2 million2	-$1.5 million	-43%
MURA	No new $	+$41 million	+$41 million	+100%
EPIC	+$1.1 million	+0.9 million	-$0.2 million	-18%
Toronto Rent Bank	+$1 million	+$1 million	No change	No change
TTSP	No new $	+$0.3 million	+$0.3 million	+100%
RentSafeTO	+$0.9 million	+$0.9 million	No change	No change
Residential tax rate increase3 Multi-res. tax rate increase4	7% 4.25%	9.5% 3.5%	–	+2.5% -0.75%

The 2024 budget marks a significant increase in housing-related investments compared to the previous year, with the additional $41 million for MURA comprising the vast majority of new and enhanced housing-related funding. While the 2024 budget also invests more toward TTSP, interestingly, there was a decrease in overall new spending for the MTH framework and EPIC, while new funding levels remained the same for RentSafeTO and Toronto Rent Bank compared to 2023, as noted above. Moreover, all MTH funding to date has been dedicated toward planning, licensing, enforcement, renovations, and repairs, with no funding allotted for renters. 

Little progress was made in the 2024 budget to advance the launch of HART and implement the Renovictions By-law, following the introduction of those initiatives in the 2023 budget, aimed at supporting renters who have been evicted or are at risk of eviction. However, the residential tax rate continued to increase in the 2024 budget to adequately fund urgently needed city programs and services, while the multi-residential rate decreased compared to the 2023 budget, with a particular focus on protecting renters from AGIs. 

Considering the concerning rate of affordable housing loss across the city, it is encouraging to see the 2024 budget prioritize the preservation of existing affordable housing through partnerships with the non-profit and Indigenous housing sectors. However, to meaningfully advance the right to housing and define itself in contrast to the previous administration, the new administration under Mayor Chow must also ensure that adequate supports are in place to keep renters housed affordably and sustainably. 

On February 15, the City of Toronto passed its 2023 budget. The Right to Housing Toronto (R2HTO) submitted our recommendations to the Budget Committee in January, emphasizing the need for the City to take a rights-based approach by ensuring a participatory process, and that the maximum of available resources are being made available, prioritizing those who need it the most. 

Here are some of the positives and negatives of what has been committed to this year in the budget.  

• First, we are disappointed that the budget process did not take a rights-based approach. Funds were allocated to various programs, and then the leftover funds were used to fund critical initiatives in the city to house people. A rights-based approach would have prioritized the needs of those most impacted by the affordable and adequate housing crisis, and allocated the maximum available resources for initiatives that can house all Torontonians.  
   
• Councillor Carroll’s proposal to allocate $800K to open an additional 24/7 warming centre until April 15 passed. Currently, with no 24/7 warming centres, this is a positive step that will support 50 people for 2-months. However, Councillor Bravo’s proposal to allocate $900K for 24/7 warming centres that would be provided in partnership with non-profit community partners did not pass. One 24/7 warming centre for 2-months is not enough to meet the needs of unhoused people.  
   
• Councillor Carroll’s proposal to expand the proposed budget of $6.2 million for the Rent Bank by $1 million passed, which will help more tenants to pay their rent arrears and stabilize their housing passed.  
   
• RentSafeTO will have $848K to hire 8 new full-time staff thanks to Councillor Matlow’s motion.  
   
• Budget commitments will also support Housing Secretariat’s office to develop a renovictions bylaw, increase the supply of affordable & supportive housing for Indigenous and Black communities, and more. However, proposal by Councillor Matlow to expand the Tenant Support Program to support the growing number of tenants dealing with renovictions failed.  
   
• Budget commitments for ML&S department will also support the implementation of multi-tenant houses licensing program and the enforcement of short-term rentals.   
   
• Toronto also approved $882K to allocate to establishing the Housing Commissioner role with the Ombudsman’s office.  
   
• The budget also commits funds to support the City Planning department in the creation of new housing under the EHON program and other revitalization projects. 

Following nearly three years of consultations, Toronto City Council has voted for the adoption of an Inclusionary Zoning (IZ) policy. This means that new housing developments near major transit areas in Toronto will be required to have a specific percentage of affordable units, whether it be condominiums or rental buildings. It is a welcome decision to see Toronto join nearly 500 other North American municipalities in adopting IZ.

Toronto’s IZ is mandatory which demonstrates the commitment to ensuring that developers participate in making our city more affordable for residents. We are glad to see that the period of affordability has been extended to 99 years, essentially making the housing developed affordable for many years to come. The definition of affordability is also based on a household’s income, ensuring that they do not spend more than 30% of their income on housing.

While we applaud the passing of IZ in Toronto, we want to acknowledge that this policy could have been bolder. The policy passed requires a much lower set-aside rate and a slower phase-in period than what some studies had shown to be feasible. What this means for our residents is the loss of an opportunity to build a higher number of affordable housing our residents need.

We hope that by passing IZ, City Council will now have the policy tool it needs to build more affordable homes and to review this policy in a timely manner so it becomes stronger and more effective in increasing affordable housing choices. We also hope that the integrity of the policy will be upheld over the long haul, where such reviews will be grounded in a rights-based framework, similar to that recognized in the HousingTO 2020-2030 Action Plan.

City Councillors in Toronto had an opportunity twice this year to approve a framework to permit and regulate multi-tenant homes (MTH) across the city that would protect the residents of unregulated MTH, and preserve these deeply affordable housing options for residents. Both times, City Council failed to get enough votes to pass this crucial policy and instead chose to defer the proposed MTH regulatory framework. The Mayor, while deferring the vote for a second time, asked City staff to reconsider several aspects of the proposed framework such as parking spaces, and increasing the number of enforcement workers.

MTH offers some of the most affordable housing options for Toronto’s residents and they exist in almost every neighbourhood across the city, whether or not some people choose to recognize them. These are the housing options for many students, newcomers, seniors and people living on fixed incomes. The failure of passing the new regulatory framework means that many of these residents will continue to live in the shadows, in often unsafe and inadequate homes. As their homes remain illegal in many parts of Toronto, these residents live with the fear of losing their home if they raise their housing concerns with City authorities, and are left without legal protections to improve their living conditions.

The City of Toronto made a commitment to advance the right to housing in its HousingTO 2020-2030 Action Plan. This implies that the City adopts policies that help all residents access safe, adequate and affordable homes. The City of Toronto’s Housing Charter and a human rights approach to housing recognizes that “all residents should be able to live in their neighbourhood of choice without discrimination”. The current regulatory framework of the City’s multi-tenant homes is discriminatory and in conflict with the City’s Housing Charter commitments to uphold people’s right to housing.

Our City is once again allowing a dangerous and discriminatory status-quo to continue by deferring its vote on the new regulatory framework. We call on Mayor John Tory and Toronto City Council to end the ongoing discirmination against tenants living in MTH by approving and implementing the new regulatory framework. Protecting these residents and ensuring their safety is of paramount importance.

Nearly a year ago, in September 2020, the Right to Housing Toronto (R2HTO) provided the City with a set of rights-based recommendations to uphold its commitment to realize the right to housing for all residents living in encampments.

Since the COVID-19 pandemic began, encampments have increased across the city, many of which are as a result of unsafe conditions in shelters and the lack of access to adequate and affordable homes.  

Ahead of Toronto City Council’s meeting on June 8 and 9, 2021, R2HTO joined 20 organizations and groups who signed a joint statement urging the City to act in compliance with human rights legislation at the provincial, national, and international levels by enacting a rights-based approach to engage with encampment residents and people experiencing homelessness.

At the Council meeting, Councillor Mike Layton introduced a motion asking for the City to reiterate its commitment to a human rights approach to housing for those experiencing homelessness, as well as to ensure that City staff develop and implement a response that is consistent with the Jury’s recommendations from the Faulkner Inquest, as it specifically relates to the health and safety of those living in encampments. The motion passed with near unanimous support, which was a welcome development and is a crucial approach to addressing the housing and homelessness crisis in Toronto.

A core aspect of a rights-based approach to addressing serious human rights issues like homelessness is to meaningfully engage impacted communities. At this same council meeting, Councillor Layton’s introduced a motion to meaningfully engage encampment residents and people with lived experience of homelessness in developing a strategy to provide them with housing opportunities. Unfortunately, this motion failed to gain support from a majority of City Councillors.

On July 21, following the City’s clearing of several encampments, advocates including R2HTO once again urged the City to take a rights-based approach by consulting encampment residents in their efforts to find them adequate and safe housing. We supported a set of rights-based recommendations laid out in A Path Forward which was presented to Mayor John Tory.

We will continue to urge the City to address homelessness by upholding its obligations and implementing rights-based recommendations in all areas of its housing policies and practices. 

The City of Toronto made a commitment to advance the right to housing in its 10-year HousingTO Action Plan, through its housing policy. This commitment means the City adopts policies that help all residents in the city access adequate and affordable homes. Today, City Councillors in Toronto had an opportunity to pass a policy to permit and regulate multi-tenant homes across the city that would recognize Toronto’s deeply affordable housing options and to ensure that tenants with lower incomes can live in safe and adequate homes. We are disappointed that Toronto’s City Council didn’t have the votes to pass this important framework and instead had to defer passing the proposed multi-tenant housing regulatory framework.

Multi-tenant homes provide an important affordable rental option for many low-income Torontonians. These homes can be found across the entire city but are unfortunately not permitted in many parts of the city. This has forced many residents to live in the shadows, oftentimes in unsafe and inadequate conditions, with the fear of losing their homes if they raise their housing concerns with City authorities.

The City of Toronto’s Housing Charter and a human rights approach to housing recognizes that “all residents should be able to live in their neighbourhood of choice without discrimination”. The current regulatory framework of the City’s multi-tenant homes is discriminatory. Failing to harmonize the regulatory regime across Toronto is in conflict with the City’s Housing Charter commitments and violates people’s human rights.

Leaving many multi-tenant homes to operate in an unregulated regime is to pretend that these homes and their residents do not exist and don’t matter. How long will the City of Toronto let the residents of multi-tenant homes be left without legal protections and living in potentially unsafe homes?

Today the City not only failed to protect its lower income residents, but it also failed to acknowledge that multi-tenant houses are an important part of its affordable rental housing stock. It also lost a crucial opportunity to implement a more cost-effective way of increasing the affordable housing stock that Toronto desperately needs. City Council has an opportunity to right their wrong in September, and protect the right to housing in Toronto. This is our chance to do better. Let’s not lose our chance to do so.