If you are not certain whether your current fire protection setup meets the 2026 requirements, the fastest way to find out is a site assessment by an NFPA-certified technician. We review your alarm system, documentation, CO alarm placement, and inspection records at no charge.
On January 1, 2026, the Ontario Fire Code changed. The changes came through O. Reg. 87/25, filed in June 2025, and a follow-up amendment, O. Reg. 303/25, filed in December 2025. Both took effect on January 1, 2026. They affect fire alarm inspections, CO alarm placement, documentation, hazardous materials storage, and integrated life safety system testing, across commercial, industrial, institutional, and mixed-use properties in the province.
Enforcement has teeth. Under the Fire Protection and Prevention Act, a corporation convicted of a Fire Code offence can be fined up to $500,000 for a first offence and $1.5 million for a subsequent one, and the Act now also allows administrative penalties issued by order, without a court process. The era of "we'll deal with it next inspection" is over.
Here is what changed, who it affects, and what your business needs to do about it.
Change 1: Fire Alarm Inspections Now Governed by CAN/ULC-S536:2019
This is the biggest change for commercial property owners and the one that will cost the most to ignore. Ontario has formally adopted CAN/ULC-S536:2019, the national standard for the inspection and testing of fire alarm systems, replacing the 2004 edition that had been in use for close to two decades.
The 2019 edition tightens how inspections are done and documented. Under CAN/ULC-S536:2019:
- Every device is tested individually and recorded on the inspection report
- Batteries and power supplies must be load-tested, not simply checked with a voltmeter
- Inspections must use the official 2019 ULC forms — custom checklists your contractor may have used previously are no longer acceptable
- Documentation requirements are more rigorous — technician attendance logs, deficiency tracking, and corrective action records must all be maintained
- Expect inspections to take longer than under the previous standard — budget for extended service windows and additional suite access coordination in multi-unit buildings
More thorough testing and paperwork can also mean higher inspection costs for complex, multi-zone, or networked systems. If your current maintenance contract predates 2026, review it now to confirm it explicitly references CAN/ULC-S536:2019 compliance. A contract written against the old standard does not automatically satisfy the new one.
Alongside S536:2019 for existing systems, Ontario also adopted CAN/ULC-S537:2019, the verification standard for new or modified fire alarm installations. If you are building out a new commercial space, adding a floor, or modifying an existing alarm system in 2026, your contractor must verify the installation to S537:2019. A verification certificate must be issued and kept on site.
The follow-up amendment, O. Reg. 303/25, fine-tuned these rules. It confirms that fire alarm systems, including integrated voice communication systems, are inspected and tested to CAN/ULC-S536. It requires the system description called for by S536 to be kept current and stored in the building at an approved location. And it allows a UL-listed smoke detector sensitivity instrument to be used for annual sensitivity testing.
Change 2: Expanded CO Alarm Requirements
Introduced through O. Reg. 87/25 and effective January 1, 2026, the CO alarm requirements in the Ontario Fire Code now align with the 2020 National Fire Code of Canada. The changes primarily affect residential and care occupancies, but commercial property owners with residential units, care facilities, or mixed-use spaces are directly impacted.
Under the updated Section 2.16 of Division B of the Ontario Fire Code, a CO alarm must be installed in any existing home or residential occupancy that has:
- A fuel-burning appliance (furnace, water heater, stove running on natural gas, propane, oil, or wood)
- A fireplace of any type
- An attached garage
- Air for heating sourced from a fuel-burning appliance located outside the living space
If any of those conditions apply, CO alarms must now be installed adjacent to each sleeping area and on every storey of the building, including storeys without sleeping areas. The previous requirement — one CO alarm per unit — no longer satisfies the code. The TSSA summary of the CO alarm changes is a useful plain-language reference.
Property managers of multi-unit residential buildings, mixed-use commercial and residential properties, long-term care facilities, and retirement homes need to audit their CO alarm placement now. The new placement requirements apply to existing buildings, not just new construction. If your units were compliant under the old placement rule, they may not be compliant today.
Change 3: Documentation and Record-Keeping Now Enforceable
The 2026 changes put documentation at the centre of compliance. Fire inspectors check records, not just equipment.
For any building that requires a Fire Safety Plan — which includes multi-residential, assembly, business, mercantile, industrial, and care occupancies — the plan must be updated to reflect 2026 requirements and kept on site. A compliant fire safety binder or documentation system should include:
- Current Fire Safety Plan, updated to include CO devices, revised inspection procedures, and new emergency protocols
- Fire alarm inspection reports on official CAN/ULC-S536:2019 forms, with deficiency tracking and sign-off
- Verification certificate for any new or modified alarm system (CAN/ULC-S537:2019)
- Sprinkler system inspection and testing records (see our NFPA 25 sprinkler inspection schedule)
- Emergency lighting and exit sign testing logs
- Fire drill records and staff training logs
- Integrated system test reports (where applicable)
If a fire inspector arrives and these records are incomplete, missing, or out of date, the building is non-compliant — even if every piece of equipment is working perfectly. Documentation is now as much a compliance item as the hardware itself.
Change 4: Integrated Life Safety System Testing
Buildings with interconnected fire and life safety systems — fire alarms linked to sprinkler monitoring, smoke control, elevators, emergency power, or HVAC shutdown — now have to show that the whole chain works together.
Under the new Section 6.10 of the Fire Code, interconnections between fire protection and life safety systems must be tested and maintained in conformance with CAN/ULC-S1001, and records of integrated tests must be kept. This applies to systems installed on or after January 1, 2020 that the Building Code required to be verified to CAN/ULC-S1001. The one-year integrated test in S1001 is waived for systems installed before January 1, 2026.
This mostly affects newer high-rise towers, hospitals, large assembly spaces, shopping centres, campuses, and any building with significant system interdependency. If your building's systems were installed or verified after 2020, confirm that integrated test records exist and are kept on site.
Change 5: Hazardous Materials Storage Standards Updated
Commercial and industrial buildings that store flammable liquids, chemicals, aerosol products, combustible dust, or dangerous goods must now meet updated requirements aligned with the 2020 National Fire Code of Canada.
Cannabis extraction operations inside farm buildings must now meet specific Fire Code requirements. Large farm buildings, those over 600 square metres or more than three storeys and built on or after January 1, 2025, must also meet parts of the Fire Code for the first time.
What Non-Compliance Can Cost
Fire Code offences are prosecuted under the Fire Protection and Prevention Act. Under section 28, as amended in 2019, an individual can be fined up to $50,000 for a first offence and $100,000 for a subsequent offence, or imprisoned for up to one year. A corporation can be fined up to $500,000 for a first offence and $1.5 million for a subsequent offence. Directors and officers who know their corporation is violating the Fire Code face the same fines as individuals.
A 2024 amendment added administrative penalties (section 30.2): a prescribed official can impose a penalty by written order for prescribed contraventions, without a court prosecution. Ask your municipal fire department whether and how it uses them.
What Commercial Businesses Need to Do Now
If your business operates in a commercial, industrial, or mixed-use property in Ontario, the following checklist reflects the minimum actions required to be compliant under the 2026 Fire Code:
- Confirm your fire alarm inspection contractor is using CAN/ULC-S536:2019 — ask explicitly. If they are still using custom forms or the old 2004 standard, they are not delivering a compliant inspection.
- Review your current maintenance contract — ensure it references S536:2019 and includes the official ULC reporting forms.
- Audit CO alarm placement — if your building has residential units or care facilities, confirm alarms are placed on every storey and adjacent to all sleeping areas, not just one per unit.
- Update your Fire Safety Plan — add CO devices, revised inspection procedures, integrated testing protocols, and current staff training records.
- Build a documentation system — all inspection reports, drill logs, deficiency tracking, and corrective action records must be accessible on site.
- Check integrated testing if your building has interconnected systems installed since 2020 — alarm, sprinklers, elevators, smoke control, or emergency power.
- Check your hazardous materials storage if you store flammable liquids, aerosols, or combustible dust — the governing requirements have changed.
How Boss Fire Is Helping GTA Businesses Transition
Our technicians are trained on the 2026 Ontario Fire Code changes and deliver fire alarm inspections under CAN/ULC-S536:2019 across the GTA. Every fire alarm inspection we perform uses the official 2019 ULC forms, load-tests batteries and power supplies, and produces the documentation package your building needs to satisfy a fire inspector on arrival.
For businesses unsure where to start, we offer a 2026 compliance review — a structured site assessment that maps your current fire protection setup against the new code requirements and identifies any gaps. We cover fire alarms, CO alarm placement, emergency lighting, fire extinguishers, documentation, and Fire Safety Plan currency. You can also run our free compliance checker for a quick first pass.
Sources and references
- Ontario Fire Code, O. Reg. 213/07
- O. Reg. 87/25, amending the Fire Code (filed June 4, 2025; most sections in force January 1, 2026)
- O. Reg. 303/25, amending the Fire Code (filed December 10, 2025; in force January 1, 2026)
- Fire Protection and Prevention Act, 1997, sections 28 (offences and fines) and 30.2 (administrative penalties)
- TSSA: Changes to the Ontario Fire Code, new requirements for CO alarms
- CAN/ULC-S536:2019, Standard for Inspection and Testing of Fire Alarm Systems; CAN/ULC-S537:2019, Standard for Verification of Fire Alarm Systems; CAN/ULC-S1001, Standard for Integrated Systems Testing of Fire Protection and Life Safety Systems
Frequently Asked Questions
What changed in the Ontario Fire Code in 2026? +
Effective January 1, 2026, the Ontario Fire Code adopted CAN/ULC-S536:2019 as the standard for fire alarm inspection and testing, replacing the 2004 edition, and CAN/ULC-S537:2019 for verifying new or modified alarm systems. The amendments (O. Reg. 87/25 and O. Reg. 303/25) also expanded CO alarm requirements, added integrated testing of interconnected life safety systems to CAN/ULC-S1001, and updated rules for hazardous materials, farm buildings and cannabis extraction.
Does the 2026 Ontario Fire Code apply to commercial businesses? +
Yes. The 2026 changes apply to most non-residential occupancies including commercial, industrial, institutional, and mixed-use buildings. The fire alarm inspection changes under CAN/ULC-S536:2019 affect any building with a fire alarm system. Commercial buildings with attached residential units or care facilities are also directly affected by the CO alarm changes.
What is CAN/ULC-S536:2019 and why does it matter? +
CAN/ULC-S536:2019 is the national standard for inspecting and testing fire alarm systems. Ontario adopted it on January 1, 2026, replacing the 2004 edition. Inspections must be recorded on the standard ULC report forms, batteries are load-tested, the system description must be kept current in the building, and documentation is more rigorous, so inspections generally take longer than before.
What are the new CO alarm requirements in Ontario for 2026? +
As of January 1, 2026, CO alarms must be installed adjacent to each sleeping area and on every storey of any existing residential occupancy that has a fuel-burning appliance, a fireplace, or an attached garage. These requirements are set out in Section 2.16 of Division B of the Ontario Fire Code as amended by O. Reg. 87/25. The previous requirement of one CO alarm per unit no longer satisfies the code.
What are the fines for Ontario Fire Code violations? +
Fire Code offences are prosecuted under the Fire Protection and Prevention Act. Individuals face fines of up to $50,000 for a first offence and $100,000 for a subsequent offence, or up to a year in jail. Corporations face fines of up to $500,000 for a first offence and $1.5 million for a subsequent offence. These maximums have applied since 2019, and a 2024 amendment also allows administrative penalties issued by order.
Do I need to update my Fire Safety Plan for 2026? +
Yes. Any building that requires a Fire Safety Plan — including multi-residential, assembly, business, mercantile, industrial, and care occupancies — must review and update it to reflect the 2026 changes. This includes adding CO devices, updated inspection procedures, integrated testing records, and staff training documentation. The updated plan must be kept on site and available to fire officials on request.
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