A new report from City of Hamilton staff details that the municipality is only recovering approximately one per cent of total program expenses from the Renovation Licence and Relocation By-law.
The city had a cost recovery target of 10 per cent.
Enforcement of the by-law began on Jan. 1, 2025, and was the first of its kind in Ontario.
The by-law is meant to prevent renovictions.
City of Hamilton Housing Services defines renovictions as “when a landlord in bad faith undertakes legal renovations or uses the proposal of renovations to evict a tenant from their unit in order to rent the unit at a higher price with or without improvements.”
Under the Ontario Residential Tenancies Act (RTA), landlords have the right to evict tenants if there are plans for major repairs or renovations that require a building permit and vacant possession.
However, the landlord must allow the tenant to return to their unit at the current rental rate upon completion. That sometimes does not happen.
Under the new by-law, landlords who issue an eviction notice (N-13) to a tenant to demolish, repair, or renovate a unit must apply to the city within seven days for a renovation licence before starting any work.
The renovation licence costs $715 per unit, with an annual renewal fee of $125.
Additionally, landlords will be required to have all building permits already in place and will have to provide an engineer’s report showing that vacant possession is necessary in order for work to be completed.
Also under the bylaw, if a tenant is required to leave their unit during a renovation and has plans to return to the unit, then landlords must secure temporary arrangements for the tenant that are comparable to the tenant’s current unit or provide the tenant with financial compensation.
However, in 2025, only $2,860 was received in licence application fees, with no revenues generated from fines or charges.
The city says that N-13 eviction notices have declined and that the 10 per cent cost recovery target is unlikely to be achieved unless there is a “substantial increase” in the licence fee.
Staff advise against a significant increase in the fee, worried that it would increase the risk of non-compliance and create a financial barrier.
Enforcement of the by-law occurs primarily on a complaint basis.
In 2025, staff completed proactive and reactive investigations.
Proactive investigations resulted in 102 site visits, with 59 landlords and property superintendents provided with education on the by-law.
One violation was found in regard to the bylaw, and compliance was achieved without any fines or penalties.
The city also responded to 11 reactive enforcement complaints, and staff discovered that six N-13 eviction notices were unreported.
Three landlords/operators were issued Notices to Comply with the By-law to apply for a Renovation Licence, and five N-13 eviction notices were withdrawn after staff investigation.
From Jan. 2025 to Dec. 31, 2025, the city says that a total of seven applications for renovation licences were received, with one licence impacting one unit, two applications in progress impacting two units, two applications cancelled impacting five units, and two applications determined to be exempt from the by-law impacting 27 units.
The applications that were exempt from the by-law were because the housing operator was a social housing provider.
Despite the low cost recovery, staff say that the fact there was a decrease in N-13 eviction notices in 2025 “suggests that the by-law may be contributing to a lower number of bad faith renovictions.”
The Renovation Licence and Relocation Bylaw, along with the Safe Apartment Buildings Bylaw, saw Council approve a team of 28 new full-time employees added to the city’s Licensing and Bylaw Services division.
Based in Hamilton, he reaches hundreds of thousands of people monthly on Facebook, Instagram, TikTok, and Twitter. He has been published in The Hamilton Spectator, Stoney Creek News, and Bay Observer. He has also been a segment host with Cable 14 Hamilton. In 2017, he received the Chancellor Full Tuition Scholarship from the University of Ottawa (BA, 2022). He has also received the Governor General’s Academic Medal. He formerly worked in a non-partisan role on Parliament Hill in Ottawa.
