Important milestone reached in building code review process

By Paul De Berardis

Nov. 3, 2026

Ontario’s comprehensive review of the Building Code reached an important milestone recently with release of the Building Code Advisory Body’s interim report.

The Building Code Advisory Body, or BCAB, was established by the minister of municipal affairs and housing to undertake a comprehensive review of the building code and identify opportunities to reduce unnecessary regulatory burden, improve clarity and streamline requirements, while maintaining health, safety, accessibility and building-performance outcomes.

As one of five members appointed to the BCAB, I have had the opportunity over the past several months to hear from builders, designers, building officials and other stakeholders about how the code works in practice. One thing has become increasingly clear: reducing regulatory burden is about much more than simply making the building code shorter.

The greater opportunity is to make the entire building regulatory system clearer, more predictable and more consistent.

That theme is reflected throughout the interim report. Regulatory burden can arise from outdated or unclear technical requirements, but it can also result from inconsistent interpretations, varying permitting requirements across municipalities, and technical regulations that may not be proportionate to the complexity or risk of a building type.

For builders operating across multiple Ontario municipalities, these issues are very real. The same building code applies provincially, yet application requirements, interpretations and administrative processes can vary considerably between jurisdictions. Improving consistency could therefore have just as much impact on housing delivery as changing individual technical provisions.

The interim report identifies several preliminary recommendations that the BCAB believes are sufficiently developed to warrant consideration for earlier action.

On the technical side, these include potential changes affecting minimum room sizes, window requirements, ceiling heights, guard climbability, drain-water heat recovery and certain Part 8 sewage-system provisions.

But some of the potentially most significant recommendations address how the code is administered.

These include establishing regulated timelines for permit resubmissions, creating a province-wide mechanism for issuing written building code interpretations and allowing building permits to proceed where appropriate while outstanding site-plan matters are being finalized.

For the residential construction industry, these recommendations are significant because delays do not always result from the technical requirements themselves. Multiple submission cycles, uncertainty over interpretations and inconsistent administrative expectations can add time, cost and risk long before construction begins.

Greater predictability in the permitting process would allow builders, designers and municipalities to spend more time resolving substantive issues and less time navigating process.

At the same time, the interim report deliberately does not attempt to provide final answers to every issue raised during the consultation. Some of the most consequential questions facing Ontario’s building regulatory system require considerably more analysis.

The next phase will examine opportunities to create more consistent permit application requirements, investigate ways to streamline the building permitting process and consider the future role of digital permitting. The BCAB will also continue examining how Ontario can better accommodate certified models, alternative solutions, innovative products, modular and factory-built construction and other modern construction methods.

Another important area is the missing middle housing typology. Recent planning reforms have expanded opportunities for residential intensification, but the code must work effectively alongside those policies. Technical code requirements need to provide practical pathways for delivering the additional housing Ontario is trying to encourage.

The release of the interim report should not be viewed as the end of the building code review. It is a progress report that establishes some early recommendations while identifying the more complex issues requiring additional work.

The BCAB will continue reviewing the numerous consultation submissions as it works towards developing its final report for the minister. BCAB will further evaluate where unnecessary complexity can be removed, greater provincial consistency can be achieved and requirements can be modernized without compromising the outcomes the building code exists to protect.

The interim report is an encouraging step in that direction.