Toronto’s updated property standards bylaws place significant responsibility on landlords and property owners to provide prompt, effective responses to tenant maintenance issues, particularly those related to essential services like heat and air conditioning.

For real estate professionals advising investor clients or managing rental portfolios, it is important to understand how these regulations impact investor clients, whether they’re buying, selling, or managing income properties.

Heating and cooling failures can result in fines, negative reviews, reputational harm, and avoidable vacancies, each of which impacts cash flow and long-term returns. These factors should be considered when advising clients on buying or selling rental properties. Units with aging or non-compliant HVAC systems, poor maintenance histories, or inadequate documentation practices may carry added risk or require price adjustments. On the other hand, well-maintained properties with clear service records and strong compliance protocols can offer a competitive advantage in both leasing and resale.

Recent Bylaw Changes

As of 2025, all rental units in Toronto must meet specific climate control requirements: heating systems must maintain an indoor temperature of at least 21°C from October 1 to May 15, regardless of the outdoor temperature. This applies even during transitional weather in early fall and late spring, and landlords are prohibited from turning off the heat during this period based on their own assessments of outside conditions. For units equipped with air conditioning, landlords must ensure systems are operational and capable of maintaining a safe indoor environment between June 1 and September 30, especially during heat events that pose health risks.

In addition to meeting these minimum climate control standards, landlords are legally required to respond to urgent service requests, such as loss of heat, air conditioning, or electricity, within 24 hours. Non-urgent repairs, including issues like minor leaks or damaged fixtures, must be addressed within seven days.

Failing to comply with these timelines may lead to enforcement actions by Municipal Licensing and Standards (MLS), including inspection orders, fines, and possible prosecution. Stress the importance of implementing a structured, well-documented process for receiving, responding to, and resolving tenant service requests.

Consider Tighter Bylaws in Transactions

These standards not only affect landlords’ daily operations, but also the way agents evaluate, market, and manage rental listings. Stricter property standards in Toronto may now make service request management a larger factor in evaluating rental properties. For buyer clients, recommend including HVAC inspections during due diligence to confirm that heating and cooling systems meet the city’s requirements. If the property lacks a functional system or clear service records, flag this as a potential compliance risk that may require future upgrades or lower the property’s investment value.

For sellers, highlight any operational systems already in place, such as maintenance logs, digital request platforms, or recent HVAC servicing, to increase buyer confidence and justify stronger pricing. Whether representing buyers or sellers, ensure compliance status is reflected in your client’s negotiation strategy, especially when evaluating risk, pricing, and future maintenance obligations.

Recommend Systems for Compliance

Below are some critical steps to follow that real estate agents can use to guide their investor clients in creating a strong service request system that will help ensure compliance with the new bylaw.

Step 1: Implement a Written Request System

Verbal requests often create ambiguity and lead to disputes. Recommend to landlord clients that they should formalize the process and require all non-emergency service requests to be submitted in writing. Acceptable formats include:

Online forms embedded in a tenant portal
Emails sent to a designated maintenance address
Paper forms with timestamps for small buildings or non-digitized portfolios

Each request should include the following:

Tenant name and unit number
Date and time of submission
Description of the issue, including when it began
Any previous repairs related to the issue
Access permissions and availability for repair visits

For emergency repairs, including total heat or AC failures, major water leaks, or security risks, a 24/7 hotline or app-based reporting tool should be available to tenants, with clear instructions posted in each unit and building lobby.

Step 2: Acknowledge and Log All Requests

Immediately upon receipt, a written acknowledgment should be sent to the tenant, confirming the request has been received and is being processed. Log the request into a centralized maintenance tracking system (either a spreadsheet or property management software) and assign a unique ticket number to prevent confusion.

A properly structured log should include:

Date/time received
Category: Urgent or Non-Urgent
Assigned maintenance staff or contractor
Status updates (e.g., “Scheduled,” “In Progress,” “Completed”)
Completion date and tenant confirmation, if applicable

This record will prove essential if a dispute arises or the City investigates after a tenant files a 311 complaint.

Step 3: Categorize Requests According to Urgency

Toronto bylaws prioritize essential services. The following are considered urgent and require a response within 24 hours:

No heat during the heating season
No air conditioning during the cooling season (where AC is provided)
No hot or cold running water
No electricity
Major leaks, flooding, or severe mould
Broken locks or compromised security

All other repairs, such as cosmetic damage, appliance issues, or minor plumbing problems, are non-urgent but must still be addressed within seven days of receiving the request.

Proper classification is crucial because of the response times expected. Tenants must be informed of their request’s categorization and the expected repair timeline.

Step 4: Schedule and Document the Repair

For urgent requests, aim to dispatch a technician the same day. If a qualified contractor is unavailable within 24 hours, landlords must document all reasonable attempts to secure one and maintain evidence that the delay was beyond their control. This might include:

Screenshots of vendor outreach
Contractor unavailability notices
Invoices or email threads with repair companies

For non-urgent issues that fit within the seven-day window, provide tenants with a scheduled date and estimated time of service. If delays occur due to parts, tenant inaccessibility, or weather conditions, update the maintenance log and notify the tenant in writing.

Once the repair is complete, note the outcome and obtain tenant confirmation when possible through a digital signature, email reply, or written statement.

Step 5: Maintain a Complete Record of All Activity

Toronto MLS officers may request documentation in the event of an inspection or dispute. Advise landlords that they should retain:

The original tenant request
All communication related to the issue
Maintenance logs and work orders
Invoices or service reports from technicians
Final confirmation of issue resolution

Keep these records for at least two years, as required under provincial and municipal landlord-tenant law.

Property Management to Ensure Compliant Documentation

Staying compliant with Toronto’s service request response timelines takes time, organization, and reliable access to dependable maintenance contractors, especially when emergencies occur outside regular hours.

Working with a qualified property management company ensures that all regulatory requirements and tenant communications are handled consistently and efficiently. Marco Property Management collaborates with real estate professionals to enhance the level of service they offer to investor clients, providing operational support that strengthens both compliance and client relationships.

Marco uses a centralized app that lets tenants submit maintenance requests instantly, with all activity tracked in real time. The platform flags urgent issues, notifies landlords of deadlines, and helps ensure timely response. Marco’s team reviews and categorizes each request, dispatching repairs within mandated timelines. Backed by a 24/7 network of licensed contractors, the company handles emergencies, like heating and cooling failures, quickly and in full compliance with municipal law. All service interactions are documented by in-house staff, providing clear records for audits or tenant disputes.