Bill 10 and Toronto's New N13 Renovation Licensing: What Ontario Landlords Need to Know

Intro: The Three Amigos Assemble

Thanks for joining us on this new show, which is yet to be named — please share with us any suggestions. Simply put, we’re going to have a conversation on the last Thursday of every month to keep you, the landlords of Ontario, completely informed about what’s happening in our province. Two of my favorite people are joining me for this conversation.

Mr. Rob Di Lisi of Stonegate Legal Services — say hi. Hey, everyone, thanks for having me.

And Kayla Andrade from Ontario Landlords Watch — why don’t you say hi? Thanks so much, Kevin, for having me back on. They’re not going to be our guests today — this is going to be a conversation between the three of us for all of you, and we may bring on other people depending on what’s going on. But here we are, the three amigos, trying to get you some information.

We’re going to discuss two major changes that have just taken place in the last several weeks: how the N13 and the renovation process has changed in Toronto, and — if you’re watching this on YouTube, apologies for the wrinkled shirt, I spilled some ketchup and mustard on the other one. If you’re listening on Spotify, Amazon, or Apple, you can’t see that, but you can find us there too. Just a few weeks ago, in early June, the province of Ontario introduced Bill 10.

This is in regard to illegal activity on and inside the property, making landlords and property managers accountable for illegal activity, drug production, and everything else going on in and around the properties. Kayla, why don’t we start with you — what are your thoughts on this, and can you explain what’s happening with Bill 10?

Bill 10 Breakdown: Criminal Activity Responsibility

My honest thoughts on this are that it’s smoke and mirrors — I think this is about politicians making it look like they’re cracking down and being tough on crime, but instead they’re making the landlord “big brother,” watching these tenants and their activity. A lot of it comes down to us as landlords trying to dissect what this bill is all about, because it’s very vague about what’s defined as criminal activity and what reasonable actions landlords are supposed to be taking.

Is it inspections every three months? Every six months? Is it about knowing and having evidence the landlord didn’t have, and whether they went to the Landlord and Tenant Board or not? It brings a lot of concerns, Kevin, because when landlords put their information on a lease, they have to put their address on it.

It’s a crazy business to be in — when you’re potentially dealing with high-profile criminal activity in your unit and you’re not sure yet, now you’re going to be the one who “rats them out.” We worry about putting landlords in unsafe positions just because the government can’t get its own police service together to crack down, because landlords aren’t police. And what we’ve been advocating for the last 15 years is that we’re not social workers either. Our landlords feel very strongly about this.

I’m hearing from big landlords in Ontario who are very upset about this — not just landlords, but property managers too. We’re also seeing organizations, like nonprofit housing providers, concerned about this, because their clientele often comes from troubled backgrounds, and they’re wondering where they fall within Bill 10.

24-Hour Notice Problem: How Tenants Hide Evidence

How do you know what’s going on behind closed doors, right? We have to give 24 hours’ notice to enter a property, and tenants can deny that access when the time comes. We had one property where we couldn’t even get in to do an appraisal because they kept denying us — and if they do have something going on, 24 hours is enough time to clean it up. Like you said, we’re not police.

There’s also a question about our screening techniques — are we going to be allowed to do criminal record checks? What footing will landlords be on there?

We sent a written submission to Doug Downey, the minister who put this bill forward. He forwarded our submission to the next level up, who handles the fine print of everything —

I’ll get his name later. He’s the one reaching out to landlord associations and housing associations, so they’re supposedly going to communicate with those organizations before finalizing the bill — but it’s already received royal assent and is coming into effect. Now it’s just a question of what the fine print looks like. But bottom line: they’re going to hold the housing provider responsible for their tenants’ criminal activity. Rob, what does that mean for smaller landlords?

I went through this personally with one of my tenants, Kevin. We’ve talked about this a few times — I had a tenant who was doing prostitution and drugs in my unit. I had video evidence of 60 to 70 men coming in and out of the unit a day. I forwarded the evidence to the police, and they said it was suspicion, and without more evidence they couldn’t do anything. Two weeks later,

there was an investigation, they broke down the door, arrested them — but then let them go, because, believe it or not, and Kayla mentioned this earlier, they told me even people accused of crimes have a right to housing. So I’m confused — they’re trying to bring in a bill that puts the onus on the landlord, but landlords aren’t investigators. They can only pass information to the police, and then the police have to do their jobs.

I don’t agree with the bill, and I agree with everything Kayla mentioned. It’s like a catch-and-release program, and trying to get the Landlord and Tenant Board to validate the evidence — would an adjudicator look at evidence of suspicion and say, “Sorry, it’s just suspicion”? I know a landlord trying to evict a tenant in a one-bedroom unit who’s using it as a drug house, and she’s being protected by community legal services for the last five years, and the drug activity keeps happening with no one doing anything about it. It’s shocking, and I think it’s just another straw that’s breaking the camel’s back in this province, because it’s almost like we’re in the ring, constantly getting punched.

We’ve got to keep going — we just have to survive it, and eventually we’ll come out the other end. I imagine what would happen, Kevin, if we weren’t fighting, if we weren’t being vocal, if we weren’t online, if we weren’t coming together to educate landlords.

I can only imagine what government would implement. We could see full rent control, or a private member’s bill trying to force landlords to provide cooling in their units. It’s one thing after another in Ontario.

I agree with you 100%. I’m telling you as a legal rep and as a landlord, I agree with you 200%.

Three Major Concerns for Landlords

I see three major concerns here for us as landlords, housing providers, and property managers. One is fairness — I don’t understand how they can put this on us. Two is clarity — there are still gray areas about what we’re supposed to do, and they’re already rolling this out. And three is enforcement — how are they actually going to enforce it? Those are the major things still to be determined. Right now, best practice is to start understanding this is happening and what you can do — look at third-party companies, like property managers, who can come in on a routine basis and document their inspections.

If you don’t have a property manager, get a third party to document your inspections, so you have a full report you can show as evidence if anyone questions whether you were aware of something. But you mentioned, Kevin, that tenants can hide an elephant in 24 hours — what gives landlords the right to enter without notice?

It’s not going to happen. Tenants will have time to hide evidence. And unless you have cameras everywhere on the property, making sure they’re not pointed into the tenants’ windows or doors, good luck getting that evidence. Even with cameras pointed outward, that’s not going to show anything happening inside — I don’t see how they can enforce this fairly by making us responsible

for something we can’t see, if it gets fixed before we’re even there to look. No, 24 hours is plenty of time.

Good Tenants vs Bad Tenants Reality Check

You see it on TikTok — people with a bunch of stuffed toys covering holes on their bed, or a dog stuffed in a pillowcase during an inspection, or a picture frame hung over a hole in the wall. But we’re not here to bash all tenants — I want to pause and give a round of applause for the good tenants in this province, because we know we have bad tenants ruining it for the good ones, and that’s what we do at Ontario Landlords Watch — advocate for the good landlords, advocate for the good tenants, and most importantly, advocate for the taxpayers who are paying a lot of money that shouldn’t be necessary because our elected officials have mismanaged this housing crisis. We’ll keep pushing them.

They’ve got some fine-tuning to do, and we’re going to keep pointing that out, but we need everyone’s voice — Rob’s voice, Kevin’s voice, all our voices. And it’s not just landlords, property managers now — we need realtors and insurance companies too. This was a very fast bill,

from first hearing about it, to writing a submission at the last minute, to it receiving royal assent. We have to keep them on their toes and remember who voted for this heading into the next election. Doug Downey has been in that role since 2018,

and I’d like to see some fresh eyes and new ideas — I think it’s time to consider a new Attorney General. A lot of the Residential Tenancies Act was created back in the ’80s,

when it was mostly big REITs and large landlords, whereas now we have a lot more individual investors and couples putting their retirement savings into this — smaller landlords, the ones we normally work with, the ones who need guidance to navigate all this. That’s what this has to be about — all of us understanding and working together so we can make it better for everyone, because it’s still the best investment in the world. We just have to work on making it better.

RTA vs LTB: What’s Really Broken?

I think it’s not the RTA that’s the problem, it’s the LTB — because if there’s an issue, it shouldn’t take four, six, eight months to get in front of the board. I’m not sure if it’s the law that’s the problem, or the fact that the LTB is so far behind, even getting a problem in front of the board. I think it’s a little bit of both. Everything was written so long ago, for the major players, not the Mr. and Mrs. Smiths who now own a property.

I think back then there weren’t as many individual landlords as there are today. One-third of Canadians paid rent back in 2018, when we did the study, and I’d bet the number is closer to 40% today, and it’s going to keep growing. Everybody needs a roof over their head, and landlords are going to be needed more and more.

We need to make sure this is corrected and fair for everybody. Rob, do you know what an adjudicator at the Landlord and Tenant Board earns?

I think it’s around $70,000, if I’m not mistaken. I’ve seen some full-time positions posted at $110,000. Really?

I didn’t know that. I’ve applied four times to be an adjudicator — of course, they never accept me. I’m like a Judge Judy type.

This is where we’re stockpiling the Landlord and Tenant Board into this massive enterprise — look at all the taxpayer money going toward hiring adjudicators to deal with tenants who can’t pay their rent. We’d rather see that money go into a rent-relief program to help tenants pay their rent on time, instead of flooding the Landlord and Tenant Board with non-payment applications, since that’s the number-one application type at the board. Number two is personal-use applications, since landlords know there’s a hefty fine for an unlawful eviction.

Tenants have, correct me if I’m wrong, Rob, up to two years to bring their landlord back to the Landlord and Tenant Board for a bad-faith eviction? One year? I thought it had already changed to two years. It’s definitely within one year of them moving out.

So the protections are already in place, and landlords have to keep their address on file, and I’m hearing tenants can even file a claim without confirming the landlord was properly served. This is where you have to ask — how are we really helping tenants, and where are we helping landlords and taxpayers, when we’re just hiring more adjudicators?

You’re absolutely right. N12s are getting more popular, and just so everyone’s aware, the fine right now is $35,000. As of October 1, it’s changing to $50,000. For an individual — corporations are going up to half a million.

That’s part of the bill that took a while to roll out, in terms of when it would actually take effect. We knew it was coming, we just didn’t know exactly when. I’m sure once people start putting it into practice, there will be amendments, because that’s just how it works —

it’s not until something is put into practice that people see the problems and try to fix them. But by then it might already be too late — the house is already burning.

Toronto’s N13 Changes: New Renovation Rules

Let’s go back to the N13, with the City of Toronto — that’s also just come across. Rob, you’ve been talking a lot about this lately, so why don’t you break it down for everybody.

What’s changed in the City of Toronto around serving an N13? The N13 is what a lot of people call the “renovation notice” — that’s the big term the news has been using. Essentially, an N13 is used when you’re evicting a tenant because of extensive renovations they can’t stay through.

The City of Toronto has decided to get involved and is now saying you need a license to be able to renovate. And it’s not just the license — you still need to file the N13 notice, which costs $198. Then there’s the renovation license.

Then you have to provide compensation to the tenant, which, depending on how many units there are, could be quite extensive. And you must allow them to come back afterward. On top of that, there must be a professional report confirming the need for vacant possession.

The problem is you’re adding more bureaucracy and waiting for a license to be approved. Here’s what I’ve seen in Toronto, having worked there — permits aren’t forever permits. Sometimes it’s a four-month permit, sometimes six months, depending on what it is.

By the time you get to the board on an N13, it could be six to eight months, then two months to get the order, then another month to actually evict. That permit could be invalid by the time you get the tenant out. I see a big problem coming. On top of that, some of the advertising I’ve seen suggests landlords are renovating just to paint or replace flooring.

That’s not accurate. An N13 isn’t used for painting or just removing flooring — it’s for extensive renovations or demolition.

They’re putting their own spin on it to make landlords look bad. The thing is, landlords are investors — if they take over a property, they want to protect their investment and their tenants, and they want to make the property better. How do they do that? They renovate. But to renovate, they need the rent to support that, which means they want to raise the rent —

and the only way to raise the rent is if the unit is vacated, which yes, in the past, some landlords have used the N13 to their advantage to get tenants out and raise the rent.

Why This Isn’t Just About Flooring

When they talk about “just flooring,” they mean any minor renovation of an entire unit — do they really expect us to move tenants’ belongings around every time we do the flooring? What if you’re cutting laminate or vinyl and it gets on the tenants’ belongings, or there’s a drywall repair and dust comes down, and now tenants are complaining about damage from the renovation itself? And we still have to give 24 hours’ notice every time we come back. We’re trying to provide safe and affordable housing, and we know what it’s like just trying to get a permit from the city.

Developers complain it takes three to four years to get shovels in the ground — now you want to load up city staff, who are already maxed out, to handle renovation licensing too, when we have aging infrastructure across the province? And nonprofit housing providers and municipalities do the exact same thing —

they relocate tenants and tear down buildings to build new ones, and it’s easy for them, but the private sector doesn’t get the same treatment. Why is that?

Good point, well said — you get me passionate about this. I’m just warming up.

It’s because we’re all connected to other people in this. We see it on a grander scale — it’s not just our one or two properties, it’s everyone else going through the same thing, and we see more and more of it. There are still a lot of great tenants out there, and a lot of great landlords, but it has to be more balanced, more understanding. Going back to the renovation point —

we try to do upkeep while tenants are still there when we can, but they can still deny us entry. We had a windstorm take off a chunk of roof, causing a water leak we had to fix. When we needed to do the repainting and put in fans, they denied us, delayed it — and then complained to me that it wasn’t getting fixed fast enough, when they were the ones denying entry and only allowing certain dates, even though drywall work sometimes needs one day and a follow-up the next.

Bottom line, Kevin, this isn’t the city’s jurisdiction — this is the province’s. The province already has a process in place. Why are they letting cities implement bylaws and policies that contradict or add extra layers onto what the province is already doing? Municipalities need to stay in their own lane, because the province is already struggling and now cities are impacting the housing supply by introducing these extra rules on housing providers. And it makes us wonder — are they hoping nonprofit housing providers will step in to fill the gap, when it’s unclear whether all nonprofit housing providers are actually doing the job we assume they’re doing? That’s a conversation for another show.

Money Grab Alert: Speed Cameras to Renovation Permits

I personally think it’s about the money — they’re looking for ways to generate revenue. It’s a bit off-topic, but look at the speed cameras they’re using right now.

That has nothing to do with your license or your insurance — it’s just straight monitoring. I was upset about this, because in school zones, they brought the speed limit down from 40 to 30, and then put a camera there — your cruise control can go to 40, but not to 30.

So how many people are looking at their speedometer instead of watching for children? And why are the cameras active all the time, not just during school hours when kids are actually out? Why aren’t we putting that money into educating children about street safety instead?

It’s a hidden tax — they’re broke, and it’s mismanagement on multiple levels. That’s what they’ve been doing, from water billing to speed cameras to renovation bylaws and landlord licensing. It’s not going to stop until we speak up and push back, though I’m still figuring out what that looks like.

Rob and I were talking earlier — because Toronto did this, other municipalities are going to follow suit and see it as another way to grab a few hundred dollars every time someone wants to do something. It’s one hundred percent a money grab. They’re already doing this in Hamilton.

And Toronto looked at it and said, “There’s a way to make more money too.”

Color-Coding Buildings: What’s Next?

And now they want to start color-coding landlords’ buildings in Toronto. Are we going to be able to color-code the tenants too? I’m half joking, but again, this shows that our government doesn’t know the solution — they don’t even know the definition of affordable housing — and this is their attempt to look like they do, throwing landlords and private investors under the bus to make it look like we’re the problem, when we’re not.

It’s our elected officials and the levels of government embedded in this industry, because they benefit off our misfortune too. And they like making realtors look bad along the way — we talked about that with the CBC special that came out. It really trashed the real estate side of this industry.

Real estate agents are next — they’re coming for you too, Kevin. We did try to defend you in that series, though, okay?

No, I know — I’m just saying that’s how CBC portrayed it. They spun it that way, and they had no idea agents weren’t supposed to get involved until Bita sat down and explained it to them. They were trying to throw agents under the bus — wouldn’t be the first time. I’ve seen a few of their specials clump everyone together instead of looking at one specific instance. There are 111,000 real estate agents in the province,

and when we’re talking about landlord and tenant issues, very few of them are actually involved in that side of the business. If you’re a landlord looking to do something like this, talk to someone who’s involved in it daily — don’t just get your cousin who has a license to help you.

Get someone who’s involved full-time. It’s part of why I don’t take cottage listings — people often go to a realtor because they want it listed on MLS, and they don’t realize you can report unpaid rent and unpaid utilities without going to the Landlord and Tenant Board. We have to keep talking about these tools wherever we can, because advocacy alone isn’t going to be enough.

We need different services, different tools, and different professionals to help us in Ontario, because Ontario is the worst in the country for this, with BC a close second. Unfortunately, our elected officials in Ontario seem to be watching what’s happening in BC a lot. I don’t know why, but it’s not going well there either.

Someone should be looking at PEI instead, where landlords can file at the Landlord and Tenant Board for free. Here in Ontario, we’re paying $186 to $201 for that same kind of filing.

I’m not sure why there’s such a big difference for the same type of service. That’s more money for them to grab. It’s sad and unfortunate, but this is where you two are bringing information to the people.

If you know a landlord, a property manager, a realtor, or a contractor working in this industry, please share this podcast with them — let them know there’s much more to this housing industry, and they need to be involved in the conversation.

Advocacy & Taking Action

Kayla, I want to say thank you for being such a strong advocate — I see you in all the groups, and you’re one of the forerunners of this industry. I can’t say too much on public forums, but good job.

It’s sad, because with your background and how many clients come to you with their problems, your voice would carry so much weight, but unfortunately people in certain positions get muzzled. That’s part of why I created a talk show — I’m not saying anyone’s name — it’s on X, formerly Twitter, where you can create your own handle or just listen anonymously. It’s a platform for people to have this conversation and speak from the heart without worrying about it being tied to their name.

I’ve had firefighters, police officers, and lawyers who work for the City of Hamilton on the show — they all want to tell their story, but given their public-sector roles, they can’t do it under their own name. So this is a space for that. The first Thursday of the month at 7 p.m. on X, on the Ontario Landlords Watch handle,

is the Kayla Unfiltered housing call-in show. Come see what it’s about and join the conversation — we usually have about ten people talking at a time,

rotating everyone through so everybody gets a voice, because our voice is what’s needed. Thank you, Rob, for the kind words — I’ve been doing this for 15 years, and I love knowing we have as many people in our corner as possible.

I want to create more people like this, though I probably shouldn’t say that in front of my husband. I don’t think he’d want more of me. But I think it’s great that we’re all here for the landlord, for the industry, for fairness across the entire landlord-tenant landscape,

to make sure this can continue to be a great investment for everyone, something balanced and sustainable. We’ll keep having these conversations, whether on this show — which is going to be released on the last Thursday of every month, as I mentioned — or on Kayla’s show on X, on the first Thursday of every month. Who knows, maybe one day we’ll do this as a live stream so people can call in or type in questions while we’re live.

I think this was a great first show — we covered more than we planned to, but always great information for everybody. Rob, Kayla, thank you so much for being here. Kayla, any last words before we go?

Final Thoughts & Where to Connect

Make sure you’re following Kevin, subscribe to the YouTube channel. If you want to find me, I’m on all platforms — YouTube, Instagram, LinkedIn, since that’s where a lot of my policy contacts and elected officials are. Make sure you’re following Ontario Landlords Watch as well, and send me a follow.

And Rob, what about you? Again, follow Kevin — he’s been very good at advocating for landlords. And you can find us easily too, on Instagram, YouTube, and Facebook. Everyone seems to know my wife more than me these days.

You’re both doing great work. I have both of you on my channel, so we’ll let people decide.

But yeah, thanks so much for the kind words about what we’re doing. Definitely follow, subscribe, and do all those fun things to stay updated with what’s going on, especially if you’re a landlord — share this with other landlords. We’ll be back again next month on the Ontario Landlord Series. Maybe one day I’ll come up with a name for this one too.

Anyway, thanks so much — this was the first one, it was a lot of fun, and we look forward to doing it again. Had a lot of fun, guys.

Bye bye.