By A.J. Keilty, President, KEILTY Realty Management
If a piece of paper has arrived telling you to repair something at a rental property, the first thing to work out is which statute produced it. Ontario runs two property standards regimes side by side, they are mutually exclusive on any given building, and they send you to different places on different clocks. Get that wrong and you can spend your appeal window arguing at the right volume in the wrong forum.
Two regimes is the property standards answer, not the whole answer. Other statutes can produce an order about the same building on their own appeal routes, fire safety legislation being the obvious one, so the identification step below is the first thing to do whatever the order turns out to be. This post covers the two property standards regimes only.
The short answer is that the order came either from an inspector under the Residential Tenancies Act, 2006, which goes to the Landlord and Tenant Board within 20 days, or from an officer under the Building Code Act, 1992, which goes to a municipal property standards committee within 14 days. Which one you got is decided by your municipality, not by you.
The short version.
Start with the deadline, because both statutes require the order to carry one on its face. Clause 225 (2) (d) of the Residential Tenancies Act requires an inspector's work order to set out "the time limit for applying under section 226 to the Board for a review of the work order", which names the Board expressly. Clause 15.2 (2) (d) of the Building Code Act requires the order to indicate "the final date for giving notice of appeal from the order", and clause 15.2 (2) (c) requires it to warn you that the municipality may otherwise do the work at your expense. Neither statute requires the order to cite its own enabling section, so looking for a section number is a practical habit rather than a statutory entitlement.
Where the paper does not settle it, work it out from the gate in section 224 (1) of the Residential Tenancies Act. The prescribed provincial maintenance standards apply to a complex in a local municipality if "(a) there is no municipal property standards by-law that applies to the residential complex; or (b) there is a municipal property standards by-law that applies to the residential complex and the prescribed circumstances apply." Nothing has ever been prescribed for limb (b). We searched all eight regulations made under the Act, being O. Reg. 516/06, 517/06, 394/10, 9/18, 906/21, 178/26, 240/26 and 308/26, and the words "property standards" appear in none of them. Our reading is that this makes the question binary in practice: does your municipality have a property standards by-law that applies to this building, or does it not?
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The job titles differ, which is worth noticing on the signature line. The Residential Tenancies Act uses "inspector", and section 226.1 provides that "A local municipality may appoint inspectors for the purposes of sections 224.1 and 225." Note the verb. Appointing an inspector is permissive, not mandatory, so a small municipality with no by-law may also have nobody appointed to inspect under the Act.
The Building Code Act uses "officer", and its enforcement machinery is bound up with the by-law itself. Section 15.1 (3) lets the council of a municipality pass a standards by-law where an official plan containing provisions relating to property conditions is in effect, or where the council has adopted a policy statement under section 15.1 (2). Section 15.6 (1) then requires that a by-law passed under section 15.1 "shall provide for the establishment of a committee composed of such persons, not fewer than three, as the council considers advisable to hold office for such term and on such conditions as the by-law may establish." Reading those two together, our view is that a municipality cannot have a property standards by-law without also having a committee to hear appeals from it, because the requirement is imposed on the by-law rather than on the council.
There is a third tell worth knowing. Complaints go to different places. Under the Residential Tenancies Act, section 224.1 (1) applies only "If the prescribed maintenance standards apply to a residential complex located in a local municipality", and where it applies, that municipality "shall receive any written complaint from a current tenant of a rental unit located in the residential complex respecting the standard of maintenance that prevails with respect to the rental unit or the residential complex." Section 224.1 (2) then obliges it to cause an inspector to make whatever inspection it considers necessary. So that duty exists only on the no-by-law side of the gate, the complainant must be a current tenant, and the complaint must be in writing.
Section 227 confirms the division of labour by carving the Minister out of it: "Except for section 224 and except as otherwise provided in sections 224.1 and 226.2, the Minister shall, (a) monitor compliance with this Act; (b) investigate cases of alleged failure to comply with this Act; and (c) where the circumstances warrant, commence or cause to be commenced proceedings with respect to alleged failures to comply with this Act." Those sections came into force on 2018-07-01. Guideline 5, which still tells readers work orders will also be issued by the Ministry of Housing where there is no by-law, prints a date of 2018-12-15 and carries no revision line. Our reading is that the Guideline has not caught up with the 2018 amendments and the machinery is now municipal.
Four things, and section 225 (2) makes all four mandatory. The inspector "shall set out in the order, (a) the municipal address or legal description of the residential complex; (b) reasonable particulars of the work to be performed; (c) the period within which there must be compliance with the terms of the work order; and (d) the time limit for applying under section 226 to the Board for a review of the work order."
Two of those are worth checking carefully before you do anything else. Item (b), reasonable particulars, is what you would be disputing if the order is vague about scope. Item (c), the compliance period, is a different date from the appeal deadline and is the one that decides whether you are in breach. They are two separate dates doing two separate jobs, and appealing in time does nothing about the compliance period unless the order is stayed or the time is extended.
The Building Code Act order carries a comparable list at section 15.2 (2), with one item the RTA order does not have: clause (c) requires the order to give notice that if the repair or clearance is not carried out in time, "the municipality may carry out the repair or clearance at the owner's expense". That warning is not decoration. It is the statute telling you the municipality has a self-help remedy, which we come to below.
One thing neither statute imposes: there is no limitation period on issuing an order. Section 225 contains no time limit of any kind on when an inspector may act, and the only dates inside it are the compliance period and the review deadline that the order itself must state.
To the Board, on an L6, within 20 days. Section 226 (1) provides that a landlord who has received an inspector's work order and is not satisfied with its terms "may, within 20 days after the day the order is issued, apply to the Board for a review of the work order."
Read that clock carefully, because the trigger and the start date are different events. The trigger is that you received the order. The clock runs from the day it was issued. An order issued on a Monday and received on a Thursday has already spent three of its twenty days.
The form is the L6, titled on the Landlord and Tenant Board's forms page "Application for Review of a Work Order about Provincial Maintenance Standards". It costs $201 flat. The L1, L2, L3, L9 and L10 are listed at "$201 or $186 through the Tribunals Ontario Portal", and the L6 gets no such discount. The page lists the L6's filing methods as mail or courier, ServiceOntario, or email, with no Portal option, and our reading is that the missing discount follows from the missing Portal route rather than from anything the fees table says. That is the opposite of the tenant-side maintenance application, the T6, which is Portal-filable at "$53 or $48 through the Tribunals Ontario Portal". Fees read at the publisher on 2026-09-17, and the forms page carries no last-updated stamp of any kind.
Section 226 (2) then sets out what the Board may do. It may "(a) confirm or vary the inspector's work order; (b) rescind the work order, if it finds that the landlord has complied with it; or (c) quash the work order." Note that clause (b) is conditional on compliance, so doing the work and then asking for rescission is a real route, and it is a different argument from saying the order should never have issued.
If you are outside the 20 days, section 190 (1) is the provision to reach for: "The Board may extend or shorten the time requirements related to making an application under section 126, subsection 159 (2) or section 226 in accordance with the Rules." Section 226 is named in it expressly. The carve-out for prescribed time requirements sits in section 190 (2), and our reading is that it therefore does not touch the section 190 (1) power. Note also that the extension is granted "in accordance with the Rules", so the Board's Rules of Procedure govern how you ask. That is an extension the Board may grant, not one you are entitled to, and we would not plan a file around it.
To a committee, by registered mail, within 14 days. Section 15.3 (1) provides that "An owner or occupant who has been served with an order made under subsection 15.2 (2) and who is not satisfied with the terms or conditions of the order may appeal to the committee by sending a notice of appeal by registered mail to the secretary of the committee within 14 days after being served with the order."
Three differences from the Board route matter. The clock runs from service, not from issue. And the method is prescribed: registered mail to the secretary, not a filing portal and not an email.
The third is that the appellant class is wider, because "owner" is defined inclusively in section 15.1 (1) to take in "the person for the time being managing or receiving the rent of the land or premises in connection with which the word is used, whether on the person's own account or as agent or trustee of any other person, or who would receive the rent if the land and premises were let", and separately a lessee or occupant required by a lease to repair and maintain the property. Reading that against the mandatory service limb of section 15.2 (3), our view is that a property manager can hold the appeal right in their own name and be a person the order had to be served on.
Take a Prescott duplex. The officer serves the order on Monday 2026-10-05. The appeal to the committee is due by Monday 2026-10-19. If instead the same building had been in a municipality with no by-law and an inspector had issued an RTA work order on the same Monday, the L6 would be due 20 days after that day, which falls on Sunday 2026-10-25, and Sunday is a holiday under section 88 (2) of the Legislation Act, 2006, so section 89 (1) carries it to Monday 2026-10-26. Note that Saturday is not a holiday under that section, which the example happens to dodge. The windows themselves are six days apart, not seven; in this particular year the Sunday adds the extra day.
What the committee can do is in section 15.3 (3.1). On an appeal it has all the powers and functions of the officer, and it "may do any of the following things if, in the committee's opinion, doing so would maintain the general intent and purpose of the by-law and of the official plan or policy statement: 1. Confirm, modify or rescind the order to demolish or repair. 2. Extend the time for complying with the order." Note that the test is the committee's own opinion rather than an objective standard, which is what an appellant is actually arguing to. The power to extend time under paragraph 2 is worth knowing about, because it is a different ask from rescission and needs different material.
There is a further appeal, and it is two steps rather than one. Section 15.3 (4) lets the municipality, or any owner or occupant or person affected by the committee's decision, appeal to the Superior Court of Justice "by notifying the clerk of the municipality in writing and by applying to the court within 14 days after a copy of the decision is sent." The clock runs from the day a copy is sent, not received, and doing only one of the two steps is doing neither. The court then appoints a time and place under section 15.3 (5), and under section 15.3 (6) "the judge has the same powers and functions as the committee."
The order becomes final without anyone deciding anything. Section 15.3 (2) provides that "An order that is not appealed within the time referred to in subsection (1) shall be deemed to be confirmed."
Then section 15.3 (7) tells you what a confirmed order is: an order deemed confirmed under subsection (2), or confirmed or modified by the committee or a judge, "shall be final and binding upon the owner and occupant who shall carry out the repair or demolition within the time and in the manner specified in the order." So silence does not leave you where you were. It converts the officer's view into a binding personal obligation to do the work, on everyone who answers to that inclusive definition of owner. One drafting oddity to expect if you look it up: section 15.3 (7) refers to confirmation "by the committee under subsection (3)", but subsection (3) now says only that the committee shall hear the appeal, and the confirm, modify and rescind powers sit in subsection (3.1).
The order can also outlive your ownership of the building. Section 15.2 (4) provides that the order "may be registered in the proper land registry office and, upon such registration, any person acquiring any interest in the land subsequent to the registration of the order shall be deemed to have been served with the order on the day on which the order was served under subsection (3) and, when the requirements of the order have been satisfied, the clerk of the municipality shall forthwith register in the proper land registry office a certificate that such requirements have been satisfied, which shall operate as a discharge of the order."
Read the deeming carefully. It is backdated to the original service date rather than running from the purchase, so our reading is that a buyer can acquire a registered order with the appeal window already long gone. That makes it a timing problem rather than merely a disclosure item, and the discharge certificate at the end of the same subsection is the document that closes it out.
Three different kinds of cost, and only one of them is a fine.
First, the municipality can do the work. Section 15.4 (1) lets it cause the property to be repaired or demolished where a confirmed order is not complied with, section 15.4 (2) lets its employees or agents enter at any reasonable time without a warrant for that purpose, and section 15.4 (3) provides that the municipality is not liable to compensate the owner, occupant or any other person for anything done "in the reasonable exercise of its powers under subsection (1)". Section 15.4 (4) then gives it a lien on the land for what it spent, with priority lien status as described in section 1 of the Municipal Act, 2001 or section 3 of the City of Toronto Act, 2006.
Two qualifications on that. The Act imports the lien's status rather than spelling out where it ranks, so we would not tell you it outranks a mortgage without reading those other Acts. And the immunity in section 15.4 (3) runs in favour of "a municipal corporation or a person acting on its behalf", bounded by the "reasonable exercise" of the repair power, so it is not absolute.
Second, there is an administrative penalty, which arrived with the 2017 amendments in force on 2017-12-14. Section 15.4.1 (1) lets a municipality require a person, subject to such conditions as it considers appropriate, to pay an administrative penalty where it is satisfied the person failed to comply with either a section 15.1 by-law or a confirmed order. It is capped: section 15.4.1 (3) provides that the amount "(a) shall not be punitive in nature; and (b) shall not exceed the amount reasonably required to promote compliance", and section 15.4.1 (5) makes the scheme subject to regulations, so whether the route is live where your building sits is not answered by the Act alone.
Section 15.4.2 (1) makes an imposed penalty a debt to the municipality, and section 15.4.2 (2) provides that "If an administrative penalty imposed under section 15.4.1 is not paid within 15 days after the day that it becomes due and payable, the treasurer of the municipality may add the administrative penalty to the tax roll for any property in the municipality for which all of the registered owners are responsible for paying the administrative penalty, and collect it in the same manner as municipal taxes." The clock runs from when the penalty becomes due and payable, not from when it was imposed, and the power is permissive.
There is a trade attached: section 15.4.1 (4) provides that once a person "is required by a municipality to pay an administrative penalty under subsection (1) in respect of a contravention, the person shall not be charged with an offence in respect of the same contravention." Our reading is that this is the municipality's election rather than a protection you can claim, because it bites only once a penalty has actually been required, and on its own words it reaches only the same contravention.
Third, prosecution, and the two regimes have swapped places recently. Under the Residential Tenancies Act, clause 234 (t) makes it an offence to fail to comply with a work order issued under section 225, and since 2026-07-01 the maximum fine under section 238 is $100,000 for a person other than a corporation and $500,000 for a corporation.
Under the Building Code Act there is no property-standards-specific offence at all. Non-compliance is prosecuted under clause 36 (1) (b), failing to comply with an order made under the Act, and the maxima in section 36 (3) and (4) are $50,000 for an individual on a first offence and $100,000 on a subsequent one, and $500,000 for a corporation on a first offence and $1,500,000 on a subsequent one. Section 36 (5) defines a subsequent offence as one where "there has been a previous conviction under this Act", so any prior conviction counts, not only a property standards one.
Put the individual figures side by side and the Residential Tenancies Act is now twice as harsh on a first offence, which was not true before 2026-07-01. On a repeat the individual maxima meet at $100,000, because section 238 draws no first-versus-subsequent distinction at all, while the Building Code Act's corporate maximum then runs three times higher. These are maximums rather than tariffs.
Both prosecutions are bounded, and the limitation periods are not the same. Under the Residential Tenancies Act, section 239 (2) bars a proceeding for an offence more than two years after the date it was committed. The Building Code Act is shorter and it runs from knowledge rather than from the act: section 36 (8) bars a proceeding more than one year after the facts first came to the knowledge of "an officer, where the proceeding is in respect of the enforcement of by-laws passed under section 15.1". That one is worth knowing precisely because it cuts the owner's way.
One more limit, same direction: the continuing-offence provision at section 36 (6) of the Building Code Act, at up to $10,000 per day, is on its own words confined to orders made by a chief building official under section 14 (1) and clauses 15.9 (6) (a) and 15.10.3 (8) (a). Our reading is that it therefore does not reach a property standards order made by an officer under section 15.2 or section 15.7, which are the orders this post is about.
A different order arrives and the sequence reverses. Section 15.7 (1) provides that "If upon inspection of a property the officer is satisfied that there is non-conformity with the standards in a by-law passed under section 15.1 to such extent as to pose an immediate danger to the health or safety of any person, the officer may make an order containing particulars of the non-conformity and requiring remedial repairs or other work to be carried out immediately to terminate the danger." Section 15.7 (3) then provides that "After making an order under subsection (1), the officer may, either before or after the order is served, take any measures necessary to terminate the danger and, for this purpose, the municipality may, through its employees and agents, at any time enter upon the property in respect of which the order was made without a warrant."
The judicial check comes afterwards and the municipality has to seek it, but not immediately. Section 15.7 (7) provides that "As soon as practicable after the requirements of subsection (5) or (6) have been complied with, the officer shall apply to a judge of the Superior Court of Justice for an order confirming the order made under subsection (1) and the judge shall hold a hearing for that purpose." Subsections (5) and (6) are the after-the-fact service steps, under which you receive the order together with a statement describing the measures taken and the amount spent. So the clock on the hearing starts once you have been served with that statement, not when the work happened.
Under section 15.7 (8) the judge confirms, modifies or rescinds the order and separately determines "whether the amount spent on measures to terminate the danger may be recovered in whole, in part or not at all". Section 15.7 (9) makes that disposition final, and section 15.7 (10) gives a lien for whatever is recoverable, again with priority lien status.
Our reading of that sequence is that on an emergency order there is no 14 day window to protect, because section 15.3 gives an appeal only from an order made under section 15.2 (2). What you have instead is a hearing the municipality is obliged to bring, at which the amount you pay is expressly in issue under section 15.7 (8) (b).
Yes, and the mechanism sits in the Board's remedies rather than in either order, which is why it is easy to miss when you are reading the order itself.
If a tenant or former tenant applies under paragraph 1 of section 29 (1), which is an order determining that the landlord "has breached an obligation under subsection 20 (1) or section 161", section 30 (1) gives the Board nine things it may do. Three of them are about rent and they are graduated. Paragraph 6 can bar charging a new tenant more than the last lawful rent. Paragraph 7 can bar giving a notice of rent increase at all. Paragraph 8 can bar taking an increase for which notice has already been given but which has not yet been taken.
Read the unlocking condition, because it has two limbs and they are cumulative. Each of those three paragraphs runs "until the landlord has, (i) completed the items in work orders for which the compliance period has expired and which were found by the Board to be related to a serious breach of a health, safety, housing or maintenance standard, and (ii) completed the specified repairs or replacements or other work ordered under paragraph 4 found by the Board to be related to a serious breach of the landlord's obligations under subsection 20 (1) or section 161." So doing the work in the inspector's order is not enough on its own if the Board also ordered work under paragraph 4.
There is a separate brake on an above-guideline increase, and it needs no order in existence. Section 126 (12) is the gate: it provides that "Subsection (13) applies to a rental unit if the Board finds that, (a) the landlord, ... (iii) is in serious breach of the landlord's obligations under subsection 20 (1) or section 161; and (b) the rental unit is affected by, ... (iii) a serious breach referred to in subclause (a) (iii)." Both limbs are required.
Section 126 (13) is the brake itself, and it puts a step on the landlord. It requires the Board either to dismiss the application for that unit, or to provide that the rent not be increased "until the Board is satisfied, on a motion made by the landlord within the time period specified by the Board, on notice to the tenant of the rental unit", that the breach no longer affects the unit.
Nothing lifts on its own. You have to bring the motion, inside the time the Board sets. There is a parallel route for elevators at section 126 (12.1). So a serious breach can cost you an above-guideline increase in a municipality where no work order could ever have been issued, which is the point of the paragraph 1 route we cover in what happens if a tenant files a T6 against you.
Then the standards still apply to you and nobody can enforce them with an order. Section 224 (2) provides that the prescribed maintenance standards apply to a complex in unorganized territory "but only for the purposes of a landlord's obligations under subsection 20 (1) with respect to maintenance standards."
Read the limiting words. Our reading is that the standards become the content of your section 20 (1) duty and nothing more: there is no local municipality to receive a complaint under section 224.1, nobody to appoint an inspector under section 226.1, and so no work order under section 225 and no L6, because there is nothing to review. A property standards by-law is not possible either, since section 15.1 (3) of the Building Code Act gives the power to "The council of a municipality" and there is no council.
What remains is the tenant's application to the Board under paragraph 1 of section 29 (1), which is available everywhere in Ontario and needs no by-law, no inspector and no order. Mobile home parks and co-operatives each add their own wrinkle, and we work all three settings through in which maintenance standards apply to a mobile home park, a co-op or unorganized territory.
Work the paper before you work the building. Identify the statute from the citation on the order and from the job title of the person who signed it. Write down both dates separately, the compliance period and the appeal deadline, and note which event each runs from, because one runs from issue and one from service. Check whether the order names your manager as well as you, since under the Building Code Act it may.
Then decide what you are actually disputing. If the work is right and the timeline is impossible, the Building Code Act route gives you an express power to extend time under section 15.3 (3.1) paragraph 2, and the Board route gives you variation under section 226 (2) (a). If the work is wrong, you are asking to quash or rescind, and those are different arguments on different evidence. And if you are going to comply anyway, doing the work first and then asking for rescission is expressly available on the Board side under section 226 (2) (b). On the by-law side, section 15.5 lets an owner who has done the work request a certificate of compliance on payment of a fee, which is the document to have before you sell or refinance.
None of that is complicated. What makes it go wrong is the calendar, because two of the three clocks here are 14 days long and one of them starts before the order reaches you. For what the underlying repair obligation actually requires of you, we set that out in what repairs a landlord is responsible for in Ontario, and for the practical response to an order once you have identified it, see what to do if you get a work order on an Ontario rental.
How do I tell which property standards order I received? Read the citation at the top. An order citing section 225 of the Residential Tenancies Act is a provincial work order reviewed by the Landlord and Tenant Board. An order citing a municipal by-law and section 15.2 (2) of the Building Code Act, 1992 is appealed to a municipal property standards committee. Section 224 (1) decides which regime applies, and it turns on whether a municipal property standards by-law applies to the complex.
How long do I have to appeal a property standards order in Ontario? It depends on which one you got. Section 226 (1) of the Residential Tenancies Act gives 20 days after the day the work order is issued, on an L6 at $201. Section 15.3 (1) of the Building Code Act gives 14 days after being served, by registered mail to the secretary of the property standards committee. One clock runs from issue and the other from service.
What happens if I do not appeal a property standards order? Section 15.3 (2) deems an unappealed Building Code Act order to be confirmed, and section 15.3 (7) then makes it final and binding on the owner and occupant, who must carry out the repair or demolition within the time and in the manner specified. The municipality may also do the work itself under section 15.4 and take a lien on the land for what it spent.
What is the maximum fine for ignoring a property standards order? Under the Residential Tenancies Act, failing to comply with a section 225 work order is an offence under clause 234 (t), and since 2026-07-01 the section 238 maxima are $100,000 for an individual and $500,000 for a corporation. Under the Building Code Act, section 36 (3) and (4) set $50,000 for an individual on a first offence and $100,000 on a subsequent one, and $500,000 and $1,500,000 for a corporation. These are maximums rather than tariffs, and the Building Code Act carries the shorter limitation period, one year from an officer's knowledge under section 36 (8) against two years from commission under section 239 (2) of the Residential Tenancies Act.
Can a property standards order stop me raising the rent? Indirectly, yes. Paragraphs 6, 7 and 8 of section 30 (1) let the Board bar a new rent, bar a notice of increase, or bar taking an increase already noticed. Each lifts only when the landlord has completed both the work order items whose compliance period has expired and any work the Board itself ordered under paragraph 4, where each was found related to a serious breach. Separately, section 126 (12) and (13) can dismiss or suspend an above-guideline increase where the landlord is in serious breach and the unit is affected by it, with no work order needed, and the suspension lifts only on a motion the landlord brings within the time the Board sets.
Not sure which order you are holding, or how many days are left on it? Get in touch and we will read it with you.
This post is general information about Ontario residential tenancy law as of 2026-09-17, not legal advice. Legislation, regulations, by-laws and tribunal practice change. For advice on a specific property or situation, speak with a lawyer or licensed paralegal.
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