Get ready for changes to the Ontario Fire Code
Exit doors, keys, and special devices
By David Gargaro
Rental property owners should take note: the Ontario Fire Code’s new requirements are going into effect on January 1, 2026. The new requirements affect equipment and operations in residential buildings. They introduce new national standards for inspection and testing, demand more rigorous documentation, and create faster enforcement mechanisms through administrative monetary penalties.
Bringing Ontario up to national standardss The most impactful update to the Ontario Fire Code is the adoption of national ULC standards (ULC-S536 and ULC-S537). They expand how fire alarm systems are inspected, tested, and verified. Annual and monthly reports, attendance logs, and equipment checks will all have prescribed formats. The emphasis is on consistency and traceability. Operators must demonstrate that inspections were performed, as well as how, when, and by whom. Rental property owners and managers cannot use simple checklists when performing inspections. They must demonstrate specific, detailed reporting, most of which uses newly standardized forms.
More detailed inspection and reporting The changes to the Fire Code will affect how rental property owners and their contractors manage data, documentation, and testing. Battery testing will become more complex. Historically, inspectors simply recorded voltage readings. The new standard requires load or functional testing, with results carefully documented. Technologies like voice evacuation systems and wireless CO detectors will also require more rigorous testing and tracking. Deficiencies must be clearly separated from general notes and tracked in fixed lists.
30 | November 2025
“Operators will also need to make sure their contractors are using the new standardized forms,” said Shereen Gonsalves, Associate Lawyer, Cohen Highley LLP. “For larger portfolios, this could mean implementing new recordkeeping systems or providing staff with training to ensure consistency across all buildings. This will be a huge adjustment for apartment operators and staff.”
As of January 2026, the requirements for locking, latching, and fastening devices will apply to every exit door, not just designated fire exits. If a door is part of the path of egress, it must meet the updated standards. Rental property owners or managers must confirm doors with electromagnetic locks are either approved by the Chief Fire Official or compliant with the Ontario Building Code. Otherwise, every exit door must have a simple release that can be opened from the inside. Access is another critical issue. Supervisory staff must always have ready access to keys or special devices required to operate fire alarm systems or access fire protection equipment. They must also know where these items are stored, and they must be easy to retrieve. “If a fire official asks to see these keys or devices during an inspection and staff can't locate them, this could result in an AMP on the spot,” said Gonsalves. “Taking these steps now will help ensure compliance and avoid any issues when the new rules come into effect.”
Integrated systems and ongoing compliance The new Ontario Fire Code emphasizes the interconnectedness of fire protection systems. Sprinklers, alarms, monitoring stations, and CO
detectors must work together (i.e., they are not standalone systems). Integrated fire protection and life safety systems must be tested according to the CAN/ULC-S1001 standard. Rental property owners or managers should request written confirmation from monitoring companies that they comply with either NFPA 71 or CAN/ULCS561. Taking a collaborative approach will reduce risk, support safer homes, and create better relationships with regulators. “Compliance should be viewed less as a one-time event and more as an ongoing management process, with consistent testing, clear documentation, and open communication between operators, fire officials, and contractors,” said Gonsalves
Conclusion Ontario’s Fire Code update will be coming into effect at the start of the new year. It requires more oversight, more documentation, and more accountability. Fortunately, there is still time to prepare. Rental property owners should begin reviewing doors, updating documentation practices, training staff, and coordinating with contractors now to meet the January 2026 deadline and avoid costly AMPs. For more information on the Ontario Fire Code, visit https://www.ontario.ca/laws/ regulation/070213.
Faster and simpler enforcement of AMPs The new Ontario Fire Code will be introducing administrative monetary penalties (AMPs), which allow fire departments to issue on-the-spot fines for Fire Code violations. Previously, enforcement involved the provincial offences court process, which is a slower, more formal mechanism that often led to gaps between non-compliance and consequences. AMPs remove this buffer from the process. “AMPs are a game changer because they give fire departments a faster, simpler way to enforce compliance,” said Gonsalves. “Even administrative errors or omissions like missing documentation or incomplete logs can now have immediate financial consequences.” Fire safety has always been a legal obligation, but it now carries a more direct financial risk. The shift requires rental property owners and managers to move from reactive compliance to proactive prevention. This makes keeping detailed records even more important.
rentalhousingbusiness.ca | 31