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OHRC Submission on Bill 60 Regarding Proposed Amendments to Shorten the Rent Arrears Eviction Notice Period

Resource Type
submission

November 21, 2025


Context

The Ontario Government has introduced Bill 60: Fighting Delays, Building Faster Act, 2025 and its Schedule 12, which proposes amendments to the Residential Tenancies Act, 2006 (RTA). The government is seeking feedback on four of the thirteen proposed housing regulatory changes: [1] 

  1. Seeking Feedback on Proposed Amendments to the Rules Related to Tenants Raising New Issues at a Landlord and Tenant Board (LTB) Rent Arrears Hearing (due November 22, 2025)
     
  2. Seeking Feedback on Proposed Amendment to the Residential Tenancies Act, 2006 (RTA) to Shorten the Period of Time Available to Request a Review of an LTB order (due November 22, 2025)
     
  3. Seeking Feedback on Proposed Amendments to Shorten the Rent Arrears Eviction Notice Period (due November 22, 2025)
     
  4. Seeking Feedback on Proposed Amendments to the Compensation Requirements for Landlord's Own Use Evictions (due November 22, 2025)

While the Government of Ontario has allowed submissions for some proposed changes, Bill 60 is advancing to its third reading on November 24, 2025.

The OHRC encourages the government to use a human rights based approach to assess how the proposed housing amendments may disproportionately affect tenants and landlords from people historically affected under Code-grounds, including persons with disabilities, Indigenous tenants, racialized communities, lone parents, newcomers with language barriers, and public assistance recipients.
 

Housing and human rights

Under the Code, every person has a right to equal treatment with respect to the occupancy of accommodation, without discrimination because of race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation, gender identity, gender expression, age, marital status, family status, disability or the receipt of public assistance[2]. The Code applies to processes for choosing or evicting tenants, occupancy rules and regulations, repairs, the use of related services and facilities, and the general enjoyment of the premises.

 In its work on housing, the OHRC has repeatedly heard that people who identify with certain Code grounds or combinations of grounds are more likely to be tenants, and are more likely to experience poverty or to have lower average incomes than the general population. The Code may be found to apply when low income is connected to grounds such as age, ancestry, disability, ethnic origin, family status, gender identity, place of origin, race, or being in receipt of public assistance.[3]

Housing is essential to human dignity. The Code, which holds primacy over provincial legislation in Ontario protects the dignity of every person by providing for equal rights and opportunities and freedom from discrimination. Housing has been recognized as a human right in international law and Canadian obligations, including the International Covenant on Economic, Social and Cultural Rights (ICESCR)[4]. Many groups identified under the Code are more likely to face precarious housing, including:

  • Persons with disabilities, including those with mental health and addictions disabilities who may face accessibility challenges and disproportionate eviction risks.
  • Public assistance recipients, who may struggle to meet tight rental deadlines due to administrative delays, are more likely to be denied housing, or only offered housing at higher rents.
  • Racialized individuals and newcomers, who may face systemic bias or discrimination in landlord-tenant interactions.
  • Indigenous peoples, who may encounter culturally insensitive policies and fewer community supports.
  • Students and younger adults, often with lower income and precarious tenancy arrangements.
  • Older adults and seniors, who may have limited income and mobility constraints.
  • Women who may experience sexual harassment in housing.
  • Lone-parent families, who often carry additional caregiving responsibilities that affect housing stability.

Regulatory changes that disproportionately affect these groups, directly or indirectly, may create or contribute to systemic discrimination.

The Landlord Tenant Board falls under the Code as a body providing services that affect housing. It is also required to consider and apply the Code when making decisions.[5] Government legislators, policymakers, planners, program designers, tribunals, and courts must ensure that their activities, strategies, and decisions address discrimination in housing. Organizational rules, policies, procedures, decision-taking processes, and culture should not create barriers or have discriminatory effects.
 

OHRC’s work in Housing

In addition to the OHRC’s policy on human rights and rental housing, the OHRC has previously provided commentary and guidance on housing issues and proposed changes in Ontario:

  1. On May 1, 2024, the OHRC issued a letter to the City of Kingston regarding encampments.
     
  2. On March 28, 2024, the OHRC issued a letter to the Town of Cobourg on their Emergency Care Establishment By-Law.
     
  3. On May 6, 2023, the OHRC provided a submission on: Proposed amendments to clarify and enhance rental rules related to air conditioning.
     
  4. On February 22, 2023, the OHRC issued a letter to the Town of Aurora on proposed emergency and transitional housing project and on March 21, 2025, the OHRC issued a follow-up letter to the Town of Aurora on proposed emergency and transitional housing project at 14452 Yonge St.
     
  5. On February 3, 2023, the OHRC issued a statement: OHRC statement on human rights and access to cold weather services.
     
  6. On November 14 and December 30, 2022, the OHRC filed submissions on several housing regulatory changes proposed in the More Homes Built Faster Act, 2022 (Bill 23).
     
  7. On August 19, 2022, the OHRC issued a statement: OHRC statement on human rights, extreme heat waves and air conditioning that called on the Government of Ontario to include air conditioning as a vital service, as with the provision of heat, under RTA regulations and to establish a provincial maximum temperature to protect the health and safety of vulnerable tenants.
     
  8. On February 17, 2022, the OHRC issued a letter and submission to the Minister of Municipal Affairs and Housing on proposed regulatory amendments under the Housing Services Act.


OHRC Submissions

https://www.regulatoryregistry.gov.on.ca/proposal/52274

The Ontario Human Rights Commission (OHRC) welcomes the opportunity to provide a submission to the proposed legislative amendments to the Residential Tenancies Act, 2006 (RTA) to shorten the amount of time that a landlord can file an N4 (rental arrears) eviction application with the LTB from 14 days to 7 days after the rent is not paid. 

The proposed amendment raises significant concerns for vulnerable tenants. It would further limit the time tenants have to address the reason for the arrears. (i.e., funding resources). 
 

Background / Proposal

When a tenant who pays rent on a monthly or annual basis does not pay their rent on time, the landlord can issue an N4 notice of eviction on the day after the rent is due. The termination date on the notice must be at least 14 days after the date the notice is given to the tenant. If the tenant fails to pay the rent before the termination date, the landlord can file an L1 application (a formal request submitted to the LTB to evict a tenant for non-payment of rent and to collect rent the tenant owes) with the LTB on the day after the termination date.

The proposed change will allow a landlord whose tenant pays rent on a monthly or annual basis to set the termination date in the notice to be 7 days earlier than is currently allowed. If the tenant does not move out, the landlord could file an application with the LTB 7 days earlier than is currently allowed.
 

Concerns regarding proposed changes

For many low-income tenants, social assistance recipients, or those with unstable income, 7 days is not sufficient to gather missing rent or access emergency supports and significantly reduces tenants’ ability to relocate and secure a new home. The proposed amendment would trigger more L1 filings, potentially increasing the backlog experienced at the LTB. 

While some municipalities have programs to assist eligible renters to access emergency financial assistance or other eviction prevention resources, the proposed change limits a renter’s ability to apply for these programs (which often take more than 7 days to receive). Municipalities and other housing support groups have limited resources, and the limited timeframe will impact their ability to manage a surge in applications, particularly emergency cases.

Reducing the rent arrears eviction notice period by 50% disproportionately impacts tenants on the basis of Code grounds. It increases the risk of avoidable evictions, homelessness, or displacement. 
 

The OHRC’s recommendations

  1. The OHRC strongly recommends maintaining the 14-day period and embedding supports and safeguards to prevent discriminatory evictions.  By comparison, under normal circumstances, an insurer must give at least 30 days notice before cancelling one’s automobile insurance policy.
     
  2. Determine whether there is sufficient evidence to reduce the N4 notice period without disproportionately affecting tenants in a discriminatory manner under the Ontario Human Rights Code.
     
  3. Provide procedural safeguards to protect tenants who cannot meet stricter timelines in order to mitigate discriminatory impacts.


 

[1] There are several additional measures proposed in Bill 60 that are currently not receiving submissions:

Evict Persistent late payment cases, Allow the government to prescribe the contents of notices of termination, including the N4 form (Notice to End a Tenancy Early for Non-payment of Rent), Standardize postponement of an Eviction Order, Amend authority on setting aside an Eviction Orde, Increase enforcement resources to reduce wait times to enforce LTB eviction orders once filed and Tribunals Ontario to explore options for increasing access to final Landlord and Tenant Board (LTB) decisions and orders.

[2] Ontario Human Rights Code, R.S.O. 1990, c. H.19 s 2 (1).

[3] Ontario Human Rights Commission, “Poverty POV – What We Are Hearing”. Ontario Human Rights Commission, online: https://www3.ohrc.on.ca/en/poverty-pov-what-we-are-hearing

[4] International Covenant on Economic, Social and Cultural Rights, 1966, art. 11

[5] Tranchemontagne v. Ontario (Director, Disability Support Program), 2006 SCC 14.