New National Model Codes were last thing the industry needed

By Paul De Berardis

Feb. 6, 2026

The Canadian Board for Harmonized Construction Codes (CBHCC), which is responsible for the development of Canada’s National Model Codes, delivered an early Christmas present with the release of the 2025 edition of the National Model Codes on Dec. 22, 2025. However, the new and more onerous construction regulations were the last thing the housing sector was wishing for, as Ontario new housing sales continue to slump. 

The National Model Codes are technical documents that, when adopted into regulation by provinces and territories, establish minimum performance levels related to health, safety, accessibility, the protection of buildings from damage, and the protection of the environment. 

The new model codes introduce updates that advance the harmonization of building design and construction requirements across Canada, incorporate forward-looking climatic data in building design to help prepare buildings for future climate conditions while reducing the construction sector’s contribution to climate change, as well as improve the accessibility of homes and buildings for Canadians. 

It may be clear to some, but the priorities addressed in this latest 2025 iteration of the model National Building Code (NBC) are not reflective of the current state of the housing market and economy, or the broader political environment we find ourselves in today. That is for good reason, as the last 2020 and now 2025 NBC updates were developed under the direction of ministerial mandate letters driven by former Prime Minister Justin Trudeau. The caveat being that current Prime Minister Mark Carney has taken a more moderate approach to many previous policies, as evidenced by actions such as the cancellation of the federal consumer carbon tax, pausing Canada's zero-emission vehicle mandate, and rethinking Canada's energy sector under a nation-building lens. 

What does this all mean in a practical sense for builders and other industry partners in Ontario? 

The NBC doesn’t hold any regulatory authority in Ontario, as this province has its own somewhat distinctive set of construction standards, the Ontario Building Code (OBC).  However, the 2019 Reconciliation Agreement on Construction Codes between federal, provincial and territorial governments, aims to harmonize construction codes across Canada. As a result, it is up to the Ontario Ministry of Municipal Affairs and Housing to figure out next steps on how exactly to work towards harmonizing the OBC with the NBC. 

In terms of timeline, the agreement states that each province will bring its new construction codes into force within 18 months following the date on which the 2025 edition of the national codes are published, bringing us to sometime in the summer of 2027. This new deadline for the next OBC is roughly only two years after the latest OBC version last came into force on April 1, 2025, much faster than the typical five-to-seven-year code cycles we are accustomed to in Ontario.  

While the CBHCC states that technical changes were developed through a consensus-based process of code development committees, after having sat through countless committee meetings, I can honestly say it was more directive-based to fulfill the ministerial mandate letter objectives, rather than pragmatic decision making. 

One of the biggest challenges under this approach is that construction standards are often developed devoid of any rational cost-benefit analysis, especially during a time of extreme cost sensitivity due to housing affordability challenges. Furthermore, costing data is only considered as it relates to each individual proposed code change, of which there are hundreds of, so costing is only considered in a siloed approach and never holistically.

However, this is unrealistic when it comes to building a new home or a multi-unit residential building, as these code changes turn into death by a thousand cuts when aggregated. Bottom line? A majority of these new requirements are not changes being made to address problems in previous versions of the code; they are instead implementing the social policy objectives of the government to the detriment of housing affordability. 

Irrespective of what the federal government is attempting to accomplish pertaining to the latest NBC changes, prospective homebuyers make the ultimate decision with their chequebooks as to whether they value what they get with new housing or if resale offerings better suit their budgets. Market forces and consumer sentiment will ultimately prevail, so governments need to tread lightly if they are truly seeking to facilitate more new housing activity. 

To end on a positive note, the CBHCC has identified boosting housing supply and affordability as a priority for consideration in the development of the 2030 NBC, which reminds me of a famous quote, “The nine most terrifying words in the English language are, ‘I’m from the government and I’m here to help.’”