Applications  /  Rental Housing Demolition

Rental housing demolition in Toronto, explained

Toronto controls the demolition and conversion of rental housing under Chapter 667 of the Municipal Code and Section 111 of the City of Toronto Act. The trigger is six dwelling units with one rental, the obligations are replacement and tenant assistance, and the cost belongs in your due diligence rather than your rezoning.

Last updated August 2026. By Matthew Kruger, MCIP, RPP.

What triggers a Section 111 application

Toronto controls the demolition and conversion of rental housing under Chapter 667 of the Municipal Code, passed under Section 111 of the City of Toronto Act, 2006. Where it applies, you cannot demolish or convert without a Rental Housing Demolition and Conversion permit, and no building permit will save you.

The trigger is narrower than people assume and wider than they hope. It applies where a property contains six or more dwelling units and at least one of them is rental. Not six rental units. Six dwelling units, one of which is rented.

The definition of demolition is the part that catches owners. Chapter 667 defines it to include interior renovations or alterations that will result in a change to the number of dwelling units by bedroom type. Converting two one-bedrooms into a three-bedroom is a demolition for these purposes even though nothing comes down.

Conversion is caught as well: turning rental units into condominium, offices or any other non-rental purpose. And severance can trigger it, where each severed parcel would contain six or more rental units.

What the City will ask for

Two things drive every Chapter 667 approval: replacing the units, and looking after the people currently living in them.

Rental replacement. The Official Plan requires demolished rental units to be replaced with the same number of units at similar rents. The rent classifications come from CMHC average market rents for Toronto by unit type, and they matter: units are categorised as affordable, mid-range affordable or mid-range moderate depending on where the current rent sits relative to that average. Replacement is generally required at the same category and the same bedroom mix.

Tenant assistance. You will need a Tenant Assistance Plan covering relocation, compensation and the right to return to the replacement building at similar rent. Staff conduct a site visit and a tenant meeting as part of the process, and what tenants say at that meeting goes into the report to Council.

Both get secured through a Section 111 agreement registered on title. That agreement, not the permit, is what actually binds the replacement obligations to the land.

How it runs alongside the rest of the application

A Chapter 667 application almost never travels alone. It runs concurrently with the rezoning or official plan amendment that enables the redevelopment, and the two are decided together.

The sequence in practice: a Declaration of Use and Screening Form establishes whether Chapter 667 applies at all. If it does, staff encourage a meeting before you file. The application goes in, usually on the same day as the related planning application. Staff attend the site and hold a tenant meeting. A report goes to Community Council and then Council.

What Council gives first is a preliminary approval. That is not the permit. The permit issues only after the conditions are secured, the enabling zoning by-law is final and in force, and the Section 111 agreement is executed and registered.

That structure has a scheduling consequence people underestimate. Your demolition permit is downstream of your zoning being final and binding, which means downstream of the appeal period. Construction financing timed off the Council decision rather than off the by-law coming into force will be early by months.

What it costs you, and where the real number is

The municipal application fee is set by the City and adjusted annually, so check the current schedule. It is not the number that decides this file.

The real cost is the replacement obligation and the tenant assistance package. Rebuilding the same number of units at similar rents inside a new building, then carrying relocation and compensation for existing tenants through construction, is a proforma line item that has killed more redevelopments than any application fee.

Get that costed before you buy. A site with fourteen tenanted units and a favourable zoning envelope is a very different asset once the replacement obligation is priced, and it is a question that belongs in due diligence rather than in the third month of a rezoning.

The penalties for getting it wrong are not nominal either. Contravening the by-law, including providing false or misleading information, carries fines and the disgorgement of any monetary benefit obtained from the offence.

What goes wrong

Counting rental units instead of dwelling units. The six-unit threshold counts dwelling units, and only one of them has to be rental. Owners of small apartment buildings with mostly owner-occupied units get this wrong regularly.

Renovating into the trigger. Reconfiguring bedroom mix is a demolition under Chapter 667. Interior work that changes unit counts by bedroom type needs the same permit as a wrecking ball.

Emptying the building first. Vacancy achieved shortly before an application does not remove the obligation, and the City looks at demolition and conversion activity on the land over preceding years. It reads as avoidance, and it is treated that way.

Timing the demolition permit off the Council decision. Preliminary approval is not a permit. The permit follows the by-law coming into force and the Section 111 agreement being registered.

Leaving the tenant plan to the end. Tenants attend the meeting, staff summarise what they say in the report, and Council reads it. A plan assembled the week before is visible as one.

From $10,000
excl. HST and municipal fees · fixed fee, confirmed before work begins · typically filed with the related planning application
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See the full pricing schedule, or the combined OPA and ZBA this usually runs alongside.

FAQ

Common questions

Where the property contains six or more dwelling units and at least one of them is rental. It is six dwelling units in total, not six rental units. It applies to demolition, to conversion to a non-rental purpose such as condominium or office, and to severances where each severed parcel would contain six or more rental units.
It can. Chapter 667 defines demolition to include interior renovations or alterations that will result in a change to the number of dwelling units by bedroom type. Reconfiguring two one-bedroom units into a single three-bedroom unit is a demolition for the purposes of the by-law even though the building stays standing.
The Official Plan requires demolished rental units to be replaced by the same number of units at similar rents, generally matching the bedroom mix and the rent category. Categories are set against CMHC average market rents for Toronto by unit type, which is why two buildings with the same unit count can carry very different replacement obligations.
Relocation assistance, compensation, and the right to return to the replacement building at similar rent. Staff conduct a site visit and hold a tenant meeting, and what tenants raise at that meeting is summarised in the report that goes to Council.
No. Council's preliminary approval commits to issuing the permit once conditions are met. The permit itself issues after the enabling zoning by-law is final and in force and the Section 111 agreement has been executed and registered on title. Timing a construction schedule off the Council decision rather than off the by-law coming into force will be early.
No, and it is a poor idea. The application asks about demolition and conversion activity on the land over preceding years, and vacancy achieved shortly before an application reads as avoidance. Contravening the by-law carries fines and the disgorgement of any monetary benefit obtained from the offence.
Our planning fee starts at $10,000, fixed and confirmed before work begins. The City's application fee is set separately and adjusted annually. Neither is the number that matters on this file. The replacement obligation and the tenant assistance package are the costs that decide whether the redevelopment works, and they belong in due diligence rather than in month three of a rezoning.
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Tell us the address and the unit count. We will confirm whether Chapter 667 applies, what the replacement obligation looks like, and what it will cost, before it becomes a proforma problem.

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