
From the Winter 2025 Issue
Navigating the Shifting Regulatory Landscape
Legal and Regulatory Insights
Condoland is a great place to live and work. This simple fact can quickly and easily be forgotten when managers are confronted with endless regulatory changes, new workplace expectations, and poor support. Those who stay in Condoland as professionally licensed Condominium Managers take pride in their role as servant leaders. Condominium managers are the stewards of Ontario’s most densely populated communities, and the regulatory environment that governs their work is evolving rapidly.
ACMO is your voice in a regulatory wasteland, filled with well-intentioned legislation that suffers from unintended consequences. We champion the pragmatic reality that no additional hours can be added to a day and that priorities must be selected and juggled.
This article outlines key changes and advocacy efforts that are shaping our sector—and what ACMO is doing to ensure managers are informed, protected, and empowered.
1. Clarifying the Role of Managers Under the Ontario Fire Code
One of the most pressing regulatory concerns this year has been the ambiguity surrounding the definition of “owner” under the Ontario Fire Code (OFC). Enforcement officers have increasingly interpreted property managers as “owners” due to their operational presence on-site. This misclassification exposes managers to compliance obligations and legal risks that exceed their contractual authority.
ACMO has submitted a formal advocacy document recommending a regulatory clarification to confirm that condominium managers and management service providers should not be considered “owners” under the OFC. Our position is grounded in the Condominium Act, 1998 and the Condominium Management Services Act, 2015 (CMSA), which clearly define managers as agents of the board—not independent decision-makers.
Ensuring fire and life safety at all times is paramount. In misdirecting communications to the Condominium Manager or Condominium Management Service Provider under the OFC, those seeking compliance may, in fact, make it more difficult.
2. Interprovincial Licensing and Mobility
With Ontario’s commitment to reducing interprovincial barriers for regulated professionals, ACMO has been actively engaged with the Condominium Management Regulatory Authority of Ontario (CMRAO) to ensure that licensing pathways for managers relocating from other provinces are fair and transparent. While British Columbia and Alberta also license condo managers, Ontario’s regulatory framework is distinct, and ACMO is working to ensure equivalencies are clearly and consistently mapped.
3. Legislative Updates: Bill 91 and the Condo Act Modernization
The Less Red Tape, Stronger Economy Act (Bill 91), which came into effect in October 2023, introduced several permanent amendments to the Condominium Act, championed by ACMO. These include:
• Virtual and hybrid meetings now permitted without specific bylaws.
• Electronic voting and notice delivery streamlined for greater accessibility.
• Privacy protections for owner contact information. These changes modernize governance practices and reduce administrative burdens for managers and boards alike.
We continue to leverage our powerful position in Condoland to relieve CMs and CMSP from administrative burdens, enabling them instead to focus on long-term planning.
We believe that the distribution of a Periodic Information Certificate (PIC) should be replaced by the distribution of a blank Status Certificate document. This document is the prospective purchaser’s first introduction to Condoland in general and their community specifically. This document offers all relevant information contained in the PIC.
Moreover, using this familiar format makes it easier for owners to identify important changes.
We further seek to remove all “crystal ball” predictions in the Status Certificate. Condominium Managers are professional administrators. We are not decision makers. We therefore cannot predict the future and obviously ought not be held liable for decisions made by the boards we serve.
4. Reserve Fund Standards and Financial Planning
Ontario now enforces some of the strictest reserve fund requirements in Canada. Condominium corporations must conduct professional reserve fund studies every three years and act on recommendations or explain deviations to owners. This ensures long-term financial stability and transparency, but also places increased pressure on managers to facilitate complex planning and communication processes.
We encourage our members to encourage their clients to participate in the CAO’s next iteration of the Reserve Fund Study research. More participation will equate to better data and more definitive conclusions. Condominium Managers are the conduit to connection for Condoland where we can facilitate better and more financially literate conversations.
5. Advocacy Priorities for 2025
In our recent meetings with the Minister’s Office, ACMO emphasized several urgent priorities:
• Status certificate reform and liability clarity.
• Reduction of administrative burden for managers.
• Licensing reform to address sector attrition.
• Tools for enforcement against bad actors, including problematic boards.
• Mental health and safety protections for managers.
• Unproclaimed regulations that require attention and action.
These priorities reflect the lived realities of our members and the systemic challenges they face. ACMO is committed to ensuring that the regulatory framework supports—not hinders—the professionals who keep Ontario’s condominium communities safe, stable, and thriving.
Looking Ahead
We are not just responding to change—we are shaping it. Through strategic partnerships, member engagement, and policy leadership, ACMO is building a stronger, more resilient future for condominium management in Ontario.
We are excited to look ahead to the new year and the specific mental health supports and mentorship programming for our members. These new offerings will pave the way towards a more sustainable future for Condominium Managers.
We will continue to be your voice to decision makers.
We hope you will continue to share your views, concerns, and wishlists with us as we work together to improve Condoland as our workplace and home or office for nearly 2 million Ontarians.
Sincerely,
Katherine Gow
Executive Director, ACMO

