Why Multi-Tenant Housing Matters for the Right to Housing

In 2019, the City of Toronto took a historic step by recognizing housing as a human right in its Housing Charter and HousingTO 2020-2030 Action Plan. To date, certain housing policies and programs are contributing to the City’s progress in advancing the right to housing. Notably, the City introduced its new multi-tenant housing (MTH) regulatory framework on March 31, 2024, to expand access to safe, secure, and affordable housing across all neighbourhoods.  

With the City’s MTH regulatory framework in place, all rooming houses should provide adequate housing for renters. Central to this framework are the key elements of the right to housing, including affordability, security of tenure, and habitability, which help protect renters and prevent homelessness. Below, we explore each of these elements and their impact on Toronto’s most vulnerable residents. 

Affordability  

Housing costs should not threaten or compromise other basic needs or human rights, such as access to food. Multi-tenant houses are often the cheapest housing option available in the private rental market, making them an important source of deeply affordable housing. The MTH framework is an important step toward protecting and increasing the stock of affordable rental housing in Toronto. By permitting MTHs across the city, it helps ensure renters have access to a diverse range of affordable housing options in all neighbourhoods.  

Security of tenure 

Housing policies and legislation should provide legal protection against forced evictions, harassment, and other threats. The City’s MTH Framework can help renters stay in their home by putting rules, guidelines and supports in place. By taking a human rights-based approach to implementing the MTH framework, the City has a key role to help address issues of renter displacement. Additionally, MTH renters are protected under Ontario’s Residential Tenancies Act (RTA), which includes protections that can safeguard them from unlawful evictions, harassment or other threats. 

Habitability  

Housing must be safe and well-maintained so it does not jeopardize people’s health and safety. The City’s MTH Framework sets and enforces standards that hold MTH operators accountable to health and safety requirements, helping ensure that MTH residents live in and have access to well-maintained and habitable homes that truly support their wellbeing.   

Supporting vulnerable residents  

Additionally, MTHs are a critical part of Toronto’s affordable housing system and provide homes for some of the city’s most vulnerable residents, including refugees, newcomers, social assistance recipients, students, and other low-income and marginalized groups.    

When MTH renters lose their home, many face the risk of homelessness due to a shortage of affordable housing and limited rehousing supports. By taking a human rights-based approach to implementing the MTH framework, the City has a key role in preventing renter displacement and homelessness of vulnerable renters. MTHs can also reduce pressure on emergency shelters by increasing the supply of deeply affordable housing and helping people move from temporary shelters into stable homes. 

Protecting housing rights  

In the midst of an escalating housing and homelessness crisis, the City’s MTH framework is an important step toward protecting affordable housing across the city.  By prioritizing the right to housing throughout the implementation of the MTH framework, the City can help ensure that renters have safe, secure, and affordable homes, while upholding the right to housing across Toronto.  

 

Year One of the Multi-Tenant Houses Framework: Recommendations to the City 

On March 31, 2024, the City of Toronto introduced a new city-wide regulatory framework for multi-tenant (rooming) houses (MTHs), with the goal of expanding access to safe, secure, and affordable housing across all neighbourhoods. City staff are currently preparing an update report on the first year of the implementation of the MTH framework, focused on licensing and compliance.  

To inform the report, the City gathered feedback through an online survey from MTH owners, operators, renters, advocates, neighbours, and general residents. Below are our key findings and recommendations for the City to take a human rights-based approach to implementing the MTH framework, reflecting feedback from MTH renters, advocates, and other stakeholders. 

Stay tuned for our next steps to continue holding the City accountable to implementing the MTH framework through a human rights-based approach. 

In your view, what are the main successes with the new permissions and licensing requirements? 

In the midst of an escalating housing and homelessness crisis characterized by rising rents, increasing evictions, diminishing affordable options, and limited renter protections, the MTH framework is an important step toward protecting and increasing the stock of affordable housing across the city. MTHs are a vital element of affordable housing infrastructure and provide homes to some of the most vulnerable members of our communities, including refugees, newcomers, social assistance recipients, students, and other low-income and marginalized groups.  

Two strong components of the framework include permitting MTHs across the city and requiring MTH operators to meet health and safety standards. These elements are essential to providing a diverse range of affordable housing options in all neighbourhoods, while ensuring that MTH residents benefit from well-maintained, habitable homes. Not only is this a right afforded to all renters under the provincial Residential Tenancies Act, but it is also a key element of the right to housing, to which the City has committed through its Housing Charter and HousingTO Action Plan.  

While not specifically connected to the permissions and licensing requirements, it is very promising that the City introduced the MTH renovation and repair fund to help operators come into compliance with the new framework, while protecting renters from having renovation costs imposed on them. The City has also taken important steps to develop and share resources with MTH renters and operators about the new framework, including as it relates to renters’ rights and operators’ responsibilities. 

In your view, what are the main challenges or issues with the new permissions and licensing requirements? 

Our primary concerns with the MTH framework include: 

  • High risk of renter displacement.  
  • Loss of affordable housing.  
  • Lack of targeted supports and protections for MTH renters facing displacement as a result of requirements under the framework.  

There are a few scenarios that we are particularly concerned about that remain unaddressed through the City’s current programs and policies:  

  • Potential displacement and loss through the six-room cap: As MTH operators work to comply with the requirements under the framework, for those operating in areas of the city with a six-room cap, this could potentially lead to the closure of existing rooms that exceed the cap. This would effectively lead to the loss of housing for MTH renters in those rooms. While the City has signaled that such buildings may be “grandfathered in” under the new framework (i.e., by operators applying for a variance through the Committee of Adjustment), this has not been clearly communicated to the public and does not seem well understood across City divisions enforcing the MTH framework. Moreover, the additional administrative burden to apply for a variance may discourage operators from complying. This could lead to either the sale or conversion of MTHs or the ongoing unlicensed operation of MTHs (see below). 

  • Potential displacement and loss through operator sales or conversions: The requirements under the MTH framework are important to protect existing housing and the people who live in it. However, the largely unknown segment of unlicensed MTH operators may not see the benefits of licensing and may be dissuaded by the requirements under the new framework (e.g., applications, renovations, inspections, fines, etc.). In Toronto’s current real estate market, selling or converting an MTH (e.g., into luxury rentals, condos, single family homes, etc.) could be both, very lucrative and attractive to MTH operators who are not interested in coming into compliance with the new framework. In the absence of reliable, fulsome data on the stock of unlicensed MTHs across the city, some MTH operators would be able to easily bypass the requirements related to MTH closures, leading to high risk of renter displacement. 

  • Potential displacement and loss and/or unsafe living conditions through ongoing unlicensed MTH operations: Similar to the comments above, rather than selling or converting an MTH, some unlicensed MTH operators may choose to continue operating without coming into compliance with the new framework. This could lead to MTH renters continuing to live in unsafe and unhealthy conditions. It could also lead to renter displacement through informal evictions, in particular in cases where renters are not aware of their rights and of the operators’ responsibilities.  

While the City has pointed to existing renter support programs to help prevent displacement and MTH loss (e.g., Eviction Prevention in the Community (EPIC), TO Tenant Support Program, Rent Bank, Housing Stabilization Fund, Toronto Emergency Management, and the newly launched Situation Table for Housing-at-Risk (STAR)), none of them address the specific situations of renter displacement and MTH loss outlined above. Though the City does have some programs, services, and polices in place to support renters displaced by an MTH closure (e.g., Housing Help Centres, Ending Operations Plan, dwelling room replacement policy), in the absence of sufficient data on MTHs across the city, the City will not be able to adequately ensure that MTH operators are adhering to City policies and that MTH renters have information about supports available to them. Moreover, in the absence of sufficient stock of affordable housing in both, the private market and community housing sector, there are increasingly few options available to displaced MTH renters.  

While it is promising to see the establishment of the MTH renovation and repair fund to help operators come into compliance with the new framework, we are concerned that the current funding available ($3 million in 2025) is insufficient to meet the needs across the sector. Anecdotally, we have heard that some operators may need close to the full allocation of program funding for the year for their individual MTH portfolios alone.  

Finally, we recognize that the first phase of the implementation of the MTH framework is focused on supporting operators in bringing their properties up to code (e.g., meeting Ontario Building Code and fire code requirements), but from a human rights-based perspective, adequate housing means more than simply meeting minimum safety standards. Future phases of the implementation of the framework should support operators in meeting accessibility, climate resilience, and other standards of the right to adequate housing. 

Is there anything the City could do differently to get the word out or explain the new framework? 

The City has taken some good initial steps to promote the new MTH framework, including: 

  • Providing information about renters’ rights and operators’ responsibilities in multiple languages. 
  • Supporting and participating in the MTH Community of Practice facilitated by Fred Victor. 
  • Supporting the Federation of Metro Tenants’ Associations (FMTA) to conduct door-to-door outreach to MTH renters.  

As the City’s new Rental Renovation License Bylaw comes into effect, it will be critical for the City to also ensure that MTH renters have a clear understanding that they are covered under the bylaw (an important feature of the bylaw), and that they have the same rights as all other renters related to compensation, accommodation, right of first refusal, etc. if they are temporarily displaced due to renovations. 

Reflecting our comments above, we would also encourage the City to: 

  • Conduct more proactive outreach with MTH renters and provide ongoing engagement opportunities to hear directly about their experiences and feedback related to the new framework. This could include the establishment of an MTH Renter Advisory Group and/or MTH town halls.  

  • Prioritize data collection on: 
    – Renter displacement 
    – License applications 
    – Renovations 
    – Closures and conversions. 
    – Complaints. 
    – MTH licensing tribunal outcomes 

  • Engage with MTH operators, especially unlicensed operators, to: 
    – Track MTHs across the city. 
    – Explain the benefits of the MTH framework 
    – Gather feedback 
    – Support compliance with the framework. 

Is there anything else you’d like us to know about your experience with multi-tenant houses? 

Several City divisions are responsible for the implementation of the MTH framework, including the Housing Secretariat, Municipal Licensing and Standards (MLS), Toronto Building, and Toronto Fire. However, based on our experience and as outlined in the recent Ombudsman Toronto investigation into the City’s response to a vital services outage in an MTH, it is not clear that all divisions are equally focused on preventing renter displacement and the loss of MTHs through the framework, nor are they all familiar with and trained in the City’s commitment to the right to housing.  

Nevertheless, it is encouraging to see the recent launch of the STAR table, including its initial focus on providing support for MTH and renovictions cases. This follows prolonged community advocacy to launch the delayed Housing At-Risk Table (HART), which was meant to coordinate interdivisional planning and responses related to evictions and affordable housing loss. 

To take a rights-based approach to the MTH framework and help address issues of renter displacement and MTH loss, the City should build on the mandate of the STAR table to evaluate and continue to improve the MTH framework. Building on our comments above, this could include: 

  • Developing targeted programs and policies to support MTH renters facing displacement. 
  • Coordinating enforcement and implementation of the MTH framework across City divisions to prioritize renter safety and security and affordable housing preservation. 
  • Providing training on the right to housing for all staff involved in the implementation of the MTH framework. 
  • Gathering data on unlicensed MTHs, renter displacement, and MTH loss across the city. 
  • Monitoring the impact of the framework, including through direct engagement with MTH renters.  
  • Prioritizing and maximizing funding for the MTH renovation and repair fund, including by directing federal and provincial funding toward the program and leveraging the City’s Multi-Unit Residential Acquisition (MURA) program to acquire and preserve MTHs at risk of sale or conversion. 

2025 City of Toronto Budget Analysis

Following historic investments in affordable housing and renter supports in the 2024 budget, the 2025 budget makes modest new investments in these areas. The 2024 budget was the first under Mayor Chow’s administration and marked a significant departure from previous budgets that had focused on keeping property tax increases low and prioritizing homeowners over renters. However, the modest investments in renter supports and affordable housing in the 2025 budget stand in contrast to public sentiment: the majority of respondents (67 per cent) to the City’s initial consultation on the budget identified affordable housing and shelter as the top services requiring increased support.

Nevertheless, we are encouraged to see additional investments in critical renter support programs and increased staffing levels to support the implementation of new and ongoing rental programs. Renters make up nearly half of all Toronto residents, with equity-deserving renters facing disproportionate rates of housing insecurity and eviction. Investing in eviction prevention and stability programs and other initiatives to preserve existing affordable housing are thus critical to upholding the right to housing.

Key Housing Priorities for the 2025 Toronto Budget

Toronto is grappling with a growing housing affordability and homelessness crisis. The City’s budget process presents a vital opportunity to uphold its commitment to the right to housing by prioritizing and maximizing investments in programs, services, and infrastructure that address the needs of residents most affected by the crisis.

On January 21 and 22, Toronto residents can address the budget committee to voice their priorities for the 2025 City Budget. With input from community partners including Social Planning Toronto, ACORN, Don Valley Community Legal Services, The Neighbourhood Organization, the Advocacy Centre for Tenants Ontario and No Demovictions we crafted key messages emphasizing the urgent need to fund renter supports and preserve affordable housing. We presented them at the Housing Deputation Workshop on January 17, hosted by Social Planning Toronto.

Join us is sharing these key messages and we encourage you to use them when you speak at the Budget Committee at this week’s public hearings/deputation sessions or through written submissions. Make your voice heard and help shape a budget that reflects the urgent needs of our communities.


To better address this crisis, we urge the Budget Committee to increase investments in key initiatives:

Renter Supports

  • Toronto Rent Bank: Increase funding to provide financial assistance to more low-income individuals and families, and expand eligibility to Ontario Works & Ontario Disability Support Program recipients.
  • Eviction Prevention in the Community (EPIC): Support the new Interim Rent Relief Pilot targeting households who are transitioning from a lower to a higher income, and provide increased and sustained program funding for tenants at risk of homelessness.
  • Toronto Tenant Support Program (TTSP): Increase funding for TTSP organizations to deliver legal supports, as well as enhanced tenant outreach, education, and engagement activities. Additionally, expand funding to more community organizations to provide services.
  • Housing Help Centres: Increase funding to support unhoused people in accessing housing and avoiding eviction.

Housing benefits, subsidies and social housing

  • Portable Housing Benefits (Housing Allowance): Create a city-funded program to provide portable housing benefits to Toronto residents in the private rental housing market, prioritizing persons experiencing homelessness, survivors of gender-based violence, and Indigenous persons.
  • Toronto Community Housing and Seniors Housing: Prioritize and invest in rent-geared-to-income (RGI) social housing that remains affordable in perpetuity, for those most in need including seniors.

Affordable housing preservation

  • Multi-Unit Residential Acquisition (MURA): Increase funding for the City to purchase at-risk private market rental housing to secure homes as permanently affordable non-profit housing and maximize funding for the greatest impact. Additionally, increase vacant home tax and use revenue towards funding the MURA program long-term.
  • Multi-Tenant Houses (MTH): Increase funding for the MTH Renovation and Repair fund to support operators to come into compliance with the new framework and to prevent tenant displacement for some of the most marginalized individuals in the city. Additionally, increase funding to support enhanced outreach, education, and supports for MTH tenants.
  • Renovictions bylaw: Support increased funding to support the implementation of the new Rental Renovation. License Program, including new permanent staff for administration, investigation, and enforcement activities, as well as additional funding for a comprehensive public education and communications strategy.
  • Rental replacement policy: Hire City staff to ensure that developers provide adequate replacement units to displaced tenants facing eviction due to demolition.
  • RentSafeTO: Support the hiring of additional inspectors, fully funded by an increase to the Registration Fee for. Apartment Buildings, to ensure apartment buildings are maintained in good condition.

City Council adopts new renovictions bylaw

Following prolonged advocacy from renter groups and advocates across the city, Toronto City Council (nearly) unanimously approved a new bylaw on November 13, 2024, that would help address rising rates of renovictions. Renovictions can happen in a few ways. Sometimes a landlord will refuse to allow a renter to return to their unit after renovations are complete, even though the renter had indicated they wanted to return before they moved out for the renovations to be carried out. Other times, a landlord may illegally raise the rent for a renter who returns to their unit after a renovation, or they may simply not undertake major renovations after evicting renters.  

The Rental Renovation Licence bylaw includes a number of key provisions that aim to protect renters and preserve affordability, while ensuring rental units are kept in a state of good repair. Under the new bylaw, landlords must: 

  • Apply for a Rental Renovation Licence within seven days of issuing a renter an N13 notice to end their tenancy. 
  • Obtain a building permit before applying for the Rental Renovation Licence. 
  • Obtain and submit a report from a qualified person identifying that the renovation or maintenance work is so extensive that the renter must leave the unit, and pay a Rental Renovation Licence fee of $700.00 per unit. 
  • Post a Tenant Information Notice to inform the renter of the licence application and to enable the renter to seek information about their rights. 
  • Complete a plan to provide renter(s) who choose to return to their units with temporary, comparable housing at similar rents, or provide monthly rent-gap payments (based on post-2015 average market rents) to cover the rent difference. 
  • Provide moving allowances to all renters.  
  • Provide renters with severance compensation where the renter is choosing not to return to the unit after the renovation or repair work is complete. 
  • Post the issued Rental Renovation Licence on the door of the unit. 

The bylaw will come into effect on July 31, 2025, and additional funding will be made available through the Toronto Tenant Support Program in the interim period to support renters facing renovictions before the bylaw is in force. 

The bylaw incorporates many of the recommendations that R2HTO and other advocates shared through the City’s consultation process over the summer. In particular, we are glad to see a strong focus on accommodation, compensation, and information for renters, as well as resources to support monitoring, evaluation, and accountability processes. It is also promising that the bylaw will cover multi-tenant homes (MTH), as MTH renters are some of the city’s most marginalized communities and the most vulnerable to displacement.  

Leading up to the November 13, 2024 City Council meeting, R2HTO submitted a joint letter with WomanACT and deputed to the Planning and Housing Committee, outlining areas of support for the bylaw and opportunities for improvement, including: 

  • Ensuring Tenant Accommodation Plans account for diverse renter needs and clearly outline conditions for a renter’s return to the unit. 
  • Ensuring renters who are displaced due to emergency repairs or renovations have access to the same supports as other displaced renters. 
  • Closing loopholes by developing a fulsome, integrated monitoring and accountability framework. 
  • Addressing other types of formal and informal evictions, which could include developing a comprehensive rental housing licensing program. 

The adoption of this bylaw is a significant win for renters across the city and marks an important step forward in the City’s commitment to advance the right to housing. R2HTO will be monitoring the implementation of the bylaw closely to ensure that it achieves its goals of protecting renters, preserving affordability, and ensuring rental buildings are well maintained.

Renovictions Bylaw: Recommendations to the City

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).

Key Takeaways from the 2024 City of Toronto Budget

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. 

What’s included in Toronto City Council’s 2023 budget

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. 

Toronto City Council finally votes for Inclusionary Zoning

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 Council lacks support from councillors to legalize Multi-Tenant Housing framework yet again

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.