The Ontario Building Code gives Toronto between 10 and 30 business days to issue or refuse a building permit. The catch is that the clock doesn't start until your application is complete, and on most commercial and retail projects that is where the time actually goes.
The legislated timeframes
Division C, Table 1.3.1.3 of the Ontario Building Code sets the time a chief building official has to issue a permit or refuse it with reasons. The periods depend on the class of building:
- 10 days for houses, plus certain tents and signs.
- 15 days for smaller buildings (Toronto's Small Building Stream, meaning Part 9 buildings other than houses).
- 20 days for larger buildings (Part 3 buildings) and retirement homes.
- 30 days for complex buildings: post-disaster buildings and buildings caught by Subsection 3.2.6 or Articles 3.2.8.3 to 3.2.8.11 of Division B.
These are business days. The period starts the day after a complete application is submitted, and it excludes Saturdays, holidays and days the office is closed to the public. If one application covers buildings in different classes, the longer period applies.
Most retail fit-outs, commercial base buildings and institutional work fall in the 20-day or 30-day bands. Toronto Building runs its review streams on the same targets, and also offers Express Services for certain small commercial and sign projects, reviewed within 3 business days after the permit is taken in.
What counts as a complete application
Sentence 1.3.1.3(5) of Division C says an application is complete when it is on the Minister's approved form, made by the owner or the owner's authorized agent, has every applicable field and required schedule filled in, has all fees paid, and comes with a written declaration that the proposed work will not contravene any applicable law.
Toronto translates that into a short list: a signed application form, one set of plans and specifications, an issued Zoning Applicable Law Certificate (ZAP), confirmation that every applicable law in the ZAP has been satisfied, and fees. The City is blunt about the consequence: "There is no time frame for review of incomplete permit applications."
Zoning review comes first
The ZAP is a detailed preliminary review of your plans for zoning and other applicable law compliance. It is what lets you file a complete permit application. It includes a maximum of three reviews, and as of January 1, 2026 the fee is $888.14 for non-house work of 300 m² or less and $1,863.82 above that, credited against permit fees when you apply with the ZAP.
The ZAP also tells you which outside approvals apply. Any of those, plus a zoning non-compliance that needs relief, sits on your critical path before the legislated clock even exists.
Where the time actually goes
Toronto's Auditor General looked at this directly in a February 2024 audit of permit intake and plan review. In a sample of 58 applications, 32 (55%) missed legislated or internal service levels. Of 27 complete applications, 17 missed the legislated timeframe, by 1 to 52 business days.
The bigger issue for owners is resubmission. The audit found no service level for reviewing resubmissions. On responded-to notices, getting the resubmission into the City's system took an average of 26 business days, followed by an average of 8 business days of review. In other words, every round of examiner comments can cost more than the original legislated period.
The common causes we see on owner-side programs line up with that: drawings filed before zoning is settled, missing schedules or consultant commitments, unresolved applicable law approvals, and design teams that answer examiner notices slowly or partially.
How to build permit time into the schedule
- Schedule the ZAP as its own activity. Allow for up to three review rounds, and do not show the permit clock starting until the ZAP is issued.
- Carry the applicable law approvals separately. Each outside approval the ZAP flags needs its own line, owner and date.
- Use the legislated period as a floor, not a forecast. 20 or 30 business days is the best case on a clean, complete file.
- Plan at least one resubmission cycle. Give the design team a contractual turnaround for responding to examiner comments.
- Check completeness before you file. Run the application against Sentence 1.3.1.3(5) and the City's checklist, line by line.
- Don't lock construction start or rent commencement to the permit date until the permit is in hand. Tenant and lender commitments should carry float.
An independent owner's rep earns their keep here by holding consultants to these dates and keeping the permit path visible in the owner's schedule, not buried in the architect's.
Frequently asked questions
How long does a commercial building permit take in Toronto?
The legislated review period is 20 business days for large (Part 3) buildings and 30 for complex buildings, starting the day after a complete application. Zoning review and resubmissions come on top of that.
Does the City have to issue my permit within the legislated period?
The Code requires the City to issue or refuse with reasons within the period, but only for a complete application. Confirm any dispute over timelines with your lawyer.
Do I need a ZAP before applying?
In Toronto, an issued ZAP is part of a complete application, so without one the legislated clock does not start.
The bottom line
The legislated 20 or 30 days is the smallest part of a commercial permit timeline. Zoning, outside approvals and resubmissions decide your date, so schedule them as real activities with real owners.
If your permit path is driving your opening date, book a 30-minute call and we'll pressure-test the schedule with you.
Sources: City of Toronto, Building Permit Review Streams; City of Toronto, Zoning Applicable Law Certificate; Auditor General of Toronto, Audit of Intake and Plan Review of Applications for Building Permits (February 2024); Ontario Building Code Compendium, Division C, Article 1.3.1.3 (reprinted by the Town of Bradford West Gwillimbury); City of Belleville, Check Review Periods. This article is general information, not financial or legal advice.