Ontario building permits: owner checklist

In Ontario, no building goes up without a permit from the municipality's chief building official. The owner is usually the applicant, the designer does most of the paperwork, and the contractor carries the permit through construction. When the permit is late, mobilization slips and the owner pays. This lesson gives owners a working checklist for the permit, from applicable law to the final inspection.

Learning outcomes

• Explain what the Building Code Act, 1992 requires before construction starts, and which edition of the Ontario Building Code applies.
• List the applicable law clearances and the parts of a complete application that start the review clock.
• Plan a permit timeline backward from a mobilization date, with an owner trigger date.
• Assign permit tasks among owner, designer, contractor and the City, through to occupancy.

The lesson

The legal frame

Section 8(1) of the Building Code Act, 1992 says no one may build or demolish a building, or have it done, without a permit from the chief building official. Under section 8(2) the official must issue the permit unless the work would break the Act, the Building Code or other applicable law, the application is incomplete, the fees are unpaid, or a required professional design or qualified designer is missing.

The technical rules sit in the Building Code, a regulation under the Act. Ontario's 2024 Building Code (O. Reg. 163/24) took effect on January 1, 2025, replacing the 2012 Code (O. Reg. 332/12). A three-month transition let applications with working drawings substantially complete before 2025 be reviewed under the 2012 Code until March 31, 2025. Any application filed after that date is reviewed under the 2024 Code Older guides citing O. Reg. 332/12 article numbers need checking against the current text.

Who does what

Under CCDC 2-2020, the owner obtains and pays for development approvals and the building permit (GC 10.2). The contractor gets the permits, licences and inspections customarily obtained by contractors after the building permit is issued, such as trade permits. Supplementary Conditions can move these lines.

In practice the prime consultant prepares the application and answers the City's comments. The owner authorizes the application, pays the fees and development charges, and owns the risk of delay. The contractor posts the permit, keeps the stamped drawings on site and books inspections. Figure 3 sets this out for Northgate.

Applicable law comes first

"Applicable law" is a defined list in the Building Code (Division A, Article 1.4.1.3) of other approvals that must be in place before a permit can issue. The common ones for a new industrial building are zoning compliance (Planning Act s. 34), site plan approval (Planning Act s. 41), minor variances (s. 45), conservation authority permits for regulated areas, and Ministry of Transportation permits near provincial highways. If site plan approval is still pending, the permit cannot issue.

Development charges are a separate cash item. In Vaughan they are calculated and payable on the date the building permit is issued, unless an agreement says otherwise, and three sets apply: City, York Region and the school boards. Non-residential City charges are calculated on gross floor area. On a large warehouse that is a significant sum, and finance must be ready to pay it the week the permit is ready.

A complete application starts the clock

The Building Code sets prescribed review periods (Division C, Table 1.3.1.3). A large building such as a 12,000 m² warehouse sits in the 20-day class; houses get 10 days, smaller buildings 15, and post-disaster and certain complex buildings 30. The clock starts the day after a complete application is filed and does not count Saturdays, holidays or days the building office is closed. Within the period, the official either issues the permit or refuses it with written reasons.

"Complete" has a specific meaning: the prescribed form, every applicable field and schedule, the required drawings and information, the fees, and a written declaration that the work will not breach applicable law. If something is missing, the official can decline to start the clock and must tell the applicant in writing within two days.

In Vaughan, applications go through the City's Online Permitting Portal. The applicant registers, starts the application under "My Permits / Services", pays the minimum fee and then uploads drawings through ePlans. The 20 days is the time the City has to decide on each complete application, not a promise that the permit will issue on day 20. Most large permits take at least one round of comments and a resubmission.

Conditional and partial permits

Section 8(3) lets the official issue a conditional permit for any stage before every requirement is met. Three things are needed: zoning compliance must already be in place, the official must believe unreasonable delay would otherwise occur, and the applicant must sign an agreement. In that agreement the owner accepts the risk, commits to getting the outstanding approvals and filing complete plans on time, and agrees to remove the building and restore the site at its own cost if approvals fail. Security can be required. It puts the owner's land and money on the line, so it is an executive decision, not a scheduling trick. Many municipalities also issue partial permits, such as foundations first, under their building by-law.

After the permit is issued

The permit must be posted at the site, and the stamped permit drawings kept there for the inspector. The builder must notify the official at each prescribed stage, such as footings, structural framing, fire separations, plumbing and HVAC rough-in, and final. Toronto, for example, commits to large-building inspections within two business days of the requested date; confirm Vaughan's booking rules before mobilization. An inspector can order that work not be covered until inspected (s. 13) and can stop work if an order is ignored (s. 14). Any change to the permit drawings needs the official's acceptance before it is built.

A permit can also be lost. Under s. 8(10) the official may revoke it if the work is not seriously started within six months of issue or is substantially stopped for more than a year. At the end, section 11 says a new building may not be occupied until the official has been given notice of completion and the building has been inspected (or 10 days have passed), and any outstanding orders are met. Owners should also check whether separate items, such as rack storage systems, need their own permit or engineer review; the 2024 Code calls for professional engineer review of shelf and rack storage systems.

Northgate worked example

Northgate Logistics Inc. (fictional) is building the Northgate Distribution Centre in Vaughan under a CCDC 2-2020 contract with Halvorsen Builders Ltd. (fictional). Ridgeline Architects Inc. (fictional) holds the permit file; Halvorsen books inspections once work starts. The owner's master schedule shows the permit issued (M2) on Friday, February 26, 2027 and mobilization (M3) on Monday, March 1. The details of the Northgate fact sheet apply throughout.

The owner's representative back-schedules the permit from M2 (Figure 2):

• Site plan approval under Planning Act s. 41 is granted on Friday, November 20, 2026, clearing the main applicable law item before the application.
• Complete application is filed on Monday, December 14, 2026. The 20-day clock skips weekends, Christmas Day, the Boxing Day holiday on Monday, December 28, and New Year's Day, so the City's decision is due Thursday, January 14, 2027.
• Deficiency notice. The City refuses with reasons on day 20, listing fire separation and spatial separation comments. Ridgeline resubmits on Friday, January 29, the same day it issues the issued-for-construction set, so the permit drawings and the construction drawings match.
• Owner trigger date. If the permit is not ready by Friday, February 12, the owner's PM decides between holding mobilization, re-sequencing Halvorsen's start to work that needs no building permit, or asking Northgate's executive to consider a conditional permit.
• Fees and development charges are paid on Wednesday, February 24, from funds the owner's finance team released in January against the City's estimate. The permit issues on Friday, February 26 and is posted at the site entrance before Halvorsen moves in on March 1.

Two items go on the risk register: the one-working-day gap between permit and mobilization has no float, and the racking installer starts January 17, 2028, so Ridgeline must confirm with the City whether racking needs its own permit and engineer review.

Owner's move

Demand a permit plan from the prime consultant at the start of design development: applicable law list, target filing date, expected review rounds and the fee and development charge estimate. Ask for a permit status line in every consultant report until issue.

Check that the application is genuinely complete before it is filed, that the owner's authorization is signed, and that the finance team has the development charge cheque or transfer lined up. After issue, check that the permit is posted and the stamped set is on site at mobilization.

Reject any plan that has the contractor starting building work before the permit issues "because the City is close". Reject drawing changes built without the official's acceptance.

Common mistakes

1. Filing before applicable law is cleared. The application sits while site plan approval drags on.
2. Treating 20 days as the permit date. The prescribed period applies to each review. Plan for at least one resubmission.
3. Forgetting development charges. The permit is ready but cannot issue until a large payment clears.
4. Permit drawings that differ from the IFC set. Halvorsen builds to one set, the inspector checks against the other.
5. Ignoring the end of the permit. Racking, occupancy and final inspections are left to the last month.

Quick quiz

1. Under the Building Code Act, 1992, who issues a building permit?

   1. The Ontario Ministry of Municipal Affairs and Housing
   2. The municipality's chief building official
   3. The prime consultant
   4. The constructor

2. A permit application for a new industrial building filed in 2026 is reviewed under:

   1. The 2012 Building Code, O. Reg. 332/12
   2. The 2024 Building Code, O. Reg. 163/24
   3. The National Building Code only
   4. Whichever code the designer prefers

3. The 20-day review period for a large building starts:

   1. On the day the drawings are 90% complete
   2. The day after a complete application is filed
   3. When the City assigns an examiner
   4. When development charges are paid

4. Which is a condition of a conditional permit under s. 8(3)?

   1. The contractor posts a performance bond with the City
   2. Zoning compliance is already achieved and the owner agrees to remove the building and restore the site if approvals fail
   3. The building is under 600 m²
   4. The site plan agreement is waived

5. Under CCDC 2-2020 GC 10.2, who normally obtains and pays for the building permit?

   1. The owner
   2. The contractor
   3. The consultant
   4. The trade subcontractors

Key terms

Chief building official

The municipal official appointed under the Building Code Act, 1992 to issue permits and enforce the Act and Code.

Applicable law

The approvals listed in Division A, Article 1.4.1.3 of the Building Code, such as zoning and site plan approval, that must be met before a permit can issue.

Complete application

An application on the prescribed form with all fields, schedules, drawings, fees and the applicant's declaration, which starts the prescribed review period.

Conditional permit

A permit issued under s. 8(3) before all requirements are met, backed by the applicant's written agreement to carry the risk.

Development charges

Municipal, regional and school board charges for growth-related capital costs, payable in Vaughan when the building permit issues.

Owner trigger date

A BRC term for the date by which the owner decides how to respond if a critical approval is not ready.

References

1. Government of Ontario, 2024 Building Code Compendium: Building Code Act, 1992 (ss. 8, 10, 11, 12, 13, 14).
2. Government of Ontario, 2024 Building Code Compendium: Division C, Part 1, General (Table 1.3.1.3, Section 1.2.2).
3. Government of Ontario, O. Reg. 163/24: Building Code (e-Laws).
4. Ontario Association of Architects, Ontario's 2024 Building Code: End of the Transition Period.
5. City of Toronto, Building permit regulations (applicable law examples).
6. City of Toronto, When to call for inspection of large buildings.
7. City of Vaughan, Online Permitting Portal Applicant User Manual (February 2025).
8. City of Vaughan, Development Charges pamphlet (January 2025).
9. Canadian Construction Documents Committee, CCDC 2-2020 Stipulated Price Contract, GC 10.2.

Verified on November 4, 2026.