Towards Implementing a Maximum Indoor Temperature Requirement for Rental Units and Cooling Rooms

In 2025, staff conducted comprehensive stakeholder engagement and procured C40 Cities to examine this topic in Toronto and other North American cities. Feedback and expertise suggest that a maximum indoor temperature will provide health and safety benefits for tenants. However, implementation costs and burdens to rental housing providers that do not currently provide air conditioning are a significant barrier, and costs are expected to be passed to tenants. Any new indoor temperature requirements must also consider relevant provincial legislation, such as the Building Code Act, 1992. As a result, this report recommends that, in 2026, staff conduct a compliance analysis study of introducing a maximum temperature requirement across different rental unit/building types and the measured impact on tenants (e.g., rent increases). Staff will report back to City Council in 2027 with results of the study. The report back will include recommendations for potential implementation of a maximum indoor temperature requirement in rental units, considering varying building infrastructure, with exceptions to be informed by the compliance analysis study. To help protect tenants from excessive indoor temperature in the short term, staff recommend continuing the City's Air Conditioning Assistance Program to provide free air conditioning to low-income and vulnerable households. Staff also recommend bylaw amendments to require RentSafeTO apartment buildings cool an existing amenity space during the summer months, if they meet the requirements to comply, beginning June 1, 2026. This report and the recommendations therein were developed by Municipal Licensing and Standards (MLS) Division in collaboration with Environment, Climate and Forestry (ECF), with input from Toronto Public Health. Divisions and City agencies that supported the development of this report and that were consulted with include Housing Secretariat, Toronto Emergency Management, Social Development Division, Toronto Employment and Social Services Division, City Planning, Toronto Building, Seniors Services and Long-Term Care Division, People & Equity Division, Toronto Community Housing Corporation, and Toronto Hydro. This report has been prepared in coordination with two other heat-related reports being presented at the same City Council meeting: Progress and Priorities for Enhancing Toronto's Climate Resilience (led by Environment, Climate and Forestry) and Strengthening the Heat Relief Strategy (led by Toronto Emergency Management). Together, these reports contribute to a coordinated approach to enhancing heat resilience across Toronto. [1] Under Ontario's Residential Tenancies Act, 2006, "vital service" means hot and cold water, fuel, electricity, gas or, during the part of each year prescribed by regulations, heat.

include the requirement that the owner and operator of an apartment building, as defined by Toronto Municipal Code, Chapter 354, Apartment Buildings, with an existing indoor amenity space must maintain a temperature of not more than 26 degrees Celsius from June 1 - September 30 of each year in at least one amenity space if cooling is not provided in all dwelling units, unless the owner or operator can establish that the only way to comply with the requirement is to undertake construction or demolition within the meaning of the Building Code Act, 1992. 2. City Council delete clause F from § 629-38 of Toronto Municipal Code, Chapter 629, Property Standards, effective on June 1, 2026. 3. City Council amend § 354-3.2. B(7) of Toronto Municipal Code, Chapter 354, Apartment Buildings to remove the words struck out and include the underlined words to come into effect on June 1, 2026: the location of an air-conditioned place a cooled amenity space, as defined in Chapter 497, Indoor Temperature Standards, in the building, including its daily hours of operation, and of other locations on the property that offer relief from uncomfortably warm indoor temperatures, including any other cooling room or shaded areas, if accessible to all tenants; 4. City Council direct the Executive Director, Municipal Licensing and Standards to report back to Council in 2027 with recommendations for potential implementation of a maximum indoor temperature requirement in rental units, considering varying building infrastructure, with exceptions to be informed by a compliance analysis study that will be conducted by City staff in 2026. 5. City Council direct the Executive Director, Environment, Climate and Forestry or their designates, to continue to deliver an air conditioner assistance program aimed at providing access to air conditioning for low-income and vulnerable households in multi-unit residential buildings in Toronto, subject to the approval of the 2026 budget submission. 6. City Council request the City Manager, in consultation with relevant City Divisions and the Medical Officer of Health, to coordinate engagement with the Government of Ontario including the Ministry of Health to discuss the Government of Ontario's role in creating programs and allocating funding to mitigate the health impacts of extreme heat on vulnerable populations and the health-care system. 7. City Council reiterate its request to the Government of Ontario to amend the Residential Tenancies Act, 2006, to include cooling as a vital service and establish a maximum indoor temperature standard applicable to all rental units to ensure thermal safety protections are available to tenants. 8. City Council reiterate its request to the Government of Ontario to proclaim into force Bill 97, Helping Homebuyers, Protecting Tenants Act, 2023 to strengthen tenants' rights to install and use a window or portable air conditioner in a rental unit in leased residential premises and examine additional measures to support vulnerable and low-income tenants with associated cooling costs such as the Ontario Electricity Support Program and Low-Income Energy Program, and service disconnection bans. 9. City Council authorize the City Solicitor to make any necessary clarifications, refinements, minor modifications, technical amendments, or by-law amendments as may be identified by the City Solicitor and the Executive Director, Municipal Licensing and Standards.