Evidence Before Expansion: Rethinking Ottawa’s Renoviction Licence Debate
Let’s start with common ground: when renovictions occur in bad faith, they are a problem. Tenants deserve protection under the law.
Ottawa is now contemplating a Rental Renovation Licence By-law to address concerns from some, that some landlords are using renovation as a pretext to remove tenants.
That’s a serious allegation AND it deserves a serious, evidence-based response.
But here’s the question - Are we responding to an ACTUAL widespread systemic issue OR simply reacting to the ‘perception’ of some without fully understanding scale and unintended consequences?
The Consultation Report: Important, But Limited
The City’s own ‘What We Learned Report’ states clearly that participation was voluntary, anonymous and not representative of city-wide opinion.
619 responses in a city of over one million residents is at best ‘potentially useful’, but certainly can not be claimed as decisive (representing less than 0.061% of the population).
The geographic distribution of the respondents is also telling. The highest concentration of responses came from a small cluster of inner-urban neighbourhoods with rural Ottawa showing minimal participation.
That matters.
If concerns are geographically concentrated, is a costly, cumbersome and potentially rental supply damaging city-wide licensing regime the proportionate response?
“Policy should be calibrated to the scale of the problem - not generalized across an entire city if impacts are localized.”
How Widespread Is the Issue?
Among tenant respondents, 42 reported experiencing a renoviction; 330 did not.
Those 42 experiences should not be minimized. Where unlawful conduct occurs, it should be addressed decisively. It is worth noting, however, that the provincial framework already provides avenues for investigation, adjudication and remedy when bad-faith N13 notices are challenged.
But the data in this consultation does not establish any sort of systemic or numerous displacement across the city.
Among landlord respondents, only six reported issuing an eviction for renovation or repair. Before layering a new municipal licensing system on top of the Residential Tenancies Act (RTA), a fair question is: Is the demonstrated incidence high enough to justify a city-wide regulatory overlay?
The Most Important Finding Isn’t About Renovictions
It’s about knowledge.
The report suggests that many Ottawa landlords and tenants do not fully understand their rights, responsibilities and the existing provincial framework that already governs renovation-related evictions. If confusion about process and protections is widespread, strengthening education and enforcement may be a more effective first step than introducing additional regulation.
In fact, over 90% of respondents rated tenant understanding of their rights under the RTA as only “slight” or “not at all”. Similar concerns were raised about landlord understanding.
When asked what would help, respondents overwhelmingly selected:
Plain-language guides
Checklists
Education
If confusion about existing rules is the core issue, shouldn’t education and enforcement come first?
Perhaps put a tad more appropriately “Before we build a new regulatory layer, we should ensure people understand the one already in place.” And yes, you can quote me on that.
The Structural Risk No One Is Talking About
Despite some of the ‘conversations’ in the media and through some councillors offices, Ottawa’s rental market relies heavily on small-scale providers - individuals who own one or two units. That’s supported by census data and consistent with what anyone working in this market sees daily. In fact the Canadian Housing Statistics Program (CHSP) data consistently shows that:
The majority of rental properties in Canada are owned by individuals
Institutional investors represent a minority share of rental properties nationally
Institutional ownership is concentrated in larger purpose-built rental buildings
Licensing regimes adopted in other cities include:
Per-unit fees
Professional certification requirements
Administrative timelines
Penalties
In jurisdictions that have implemented similar regimes, licensing fees, professional certifications and associated compliance costs can add several thousand dollars per application (and in some cases these numbers can climb towards $10,000 per application).
For large institutional operators, that’s compliance overhead.
For small landlords, it can be a deterrent.
As compliance costs and regulatory complexity increase, smaller providers are disproportionately affected. Over time, that reduces rental diversity and gradually shifts market share toward larger institutional operators. The result can be a growing “missing middle” in rental housing,…fewer family-sized homes, duplexes, and mid-sized units limiting options for households whose needs extend beyond small apartment formats.
The Core Policy Question
So the question I ask is if the City proceeds, what verified data is being relied upon beyond this voluntary survey AND a thought by some that it is a large and encompassing issue?
How many N13 notices are issued annually in Ottawa?
How many are adjudicated at the Landlord and Tenant board (something every Tenant has the right to do)?
After adjudication how many N13’s are deemed to have been given in bad faith?
What is the measurable pattern of abuse?
What is the projected cost impact on small-scale providers?
Good housing policy is not about optics. It’s about incentives.
“Good housing policy should be grounded in verified evidence and measured incentives - not solely in perception or pressure.”
Governments routinely use financial and regulatory tools to shape behaviour. When an activity becomes more costly or more complex, participation declines at the margins. Housing is no different. If providing rental housing becomes increasingly expensive or administratively burdensome, supply will adjust accordingly,…often in ways that were not intended.
A Smarter Path Forward
If the goal is tenant protection, start here:
Launch a robust education campaign
Improve coordination with the Landlord and Tenant Board
Collect verified local data on N13 filings and outcomes
Reassess whether licensing is necessary based on actual evidence
Tenant protection and rental supply stability are not opposing goals. But if we make it materially harder to provide rental housing, we should not be surprised when less of it is available.
Ottawa has an opportunity to lead with precision.
Let’s ensure we solve the right problem, in the right way, before adding another regulatory layer to a market already under strain.
A Perspective from the Ground
In my own practice, I don’t doubt for a moment that municipal leaders are trying to solve a real concern. The landlords and tenants I work with, along with the councillors I’ve met with on this very issue, all want the same thing: bad actors should be punished, and no one on either side of the rental equation (Landlord or Tenant) should be taken advantage of.
But what I see just as clearly is this: many landlords and tenants are unfamiliar with the guardrails that already exist under the Residential Tenancies Act. Education, clarity and consistent enforcement of the current framework should be the first and most effective step, before we should even contemplate duplicating rules that are already in place.
