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.