The Fire Code Says: Add More Alarms – Ontario’s Updated Fire Code

By Stephanie Tambosso

As of January 1, 2026, Ontario strengthened its carbon monoxide safety requirements. O. Reg 87/25 amends O. Reg. 213/07: Fire Code (the Fire Code) by requiring carbon monoxide alarms (CO Alarms) in more locations than ever before. These changes not only address the serious risk posed by carbon monoxide, a colorless, odorless, and potentially deadly gas, but aim to ensure early detection and protection of lives.

What Buildings Require CO Alarms?

The new installation requirements for CO Alarms apply to condominiums, including townhouse condominiums, that:

• Contain a fuel-burning appliance (like a gas furnace, stove, or a water heater), fireplace; or an attached garage; and/or
• Newly, are served by a force-air fuel-burning appliance not contained within the building.

Fire safety consultants advise that the intent of this amendment is to require carbon monoxide alarms wherever there is a potential risk of carbon monoxide entering an occupied space.

Note: These amendments do not apply to condominiums that already have CO Alarms installed according to the Building Code in effect on or after January 1, 2025.

Location of CO Alarms

A CO Alarm must be installed:

1. Where a fuel-burning appliance, flue or a fireplace is installed in a unit:

• Adjacent to each sleeping area in the unit (e.g.: near all bedrooms); and
• New: on every storey (floor) of the unit that does not have a sleeping area.

2. Where a fuel-burning appliance is installed in the building, but not within a unit:

• In the service room or area where the appliance is installed;
• Near each bedroom and, newly, on every storey within each unit that shares a common wall or common floor/ceiling with the service room or area where the appliance is installed; and c. Next to each sleeping room that isn’t part of a dwelling unit (for example, guest suites that lack full facilities such as cooking and sanitary areas).

3. New: where a forced-air fuel-burning appliance provides heated air to a building, but is not located within the building:

• In the service room or area where the appliance is installed, if the appliance is located in the building;
• Where hallways serving the residential units are directly heated by the forced-air fuel burning appliance:
  • At least one CO Alarm should be placed in each portion of a divided hallway;
  • CO Alarms should not be spaced more than 25 meters apart for undivided portions of hallways; c. Near each bedroom and on every floor within each unit that is directly heated by the forced-air fuel burning appliance.

4. Where the building contains a garage:

• Near each bedroom and, newly, on every storey within each unit that shares a common wall or common floor/ceiling with the garage; and
• New: next to each sleeping room that is not part of a dwelling unit.

Who is Responsible for Compliance?

Condominiums are responsible for Fire Code compliance in the common elements and, given the importance of compliance, may also be held responsible for compliance within individual units, regardless of how responsibility is allocated in the governing documents.

The amendments provide greater clarity with respect to rented units. The landlord, newly defined as the person, firm, or corporation that owns the rental unit or the agent acting on the landlord’s behalf, is responsible for installing and maintaining CO Alarms within the rental unit. However, it is not clear how this applies in a condominium setting.

Regardless, condominiums may still face enforcement even where the legislation assigns responsibility to others. In our experience, Fire Inspectors often charge any party they consider responsible for Fire Code violations regardless of what the legislation provides.

Consequences of Non-Compliance

Meeting legal obligations helps protect the condominium. Condominiums that fall short may face fines starting at $500,000 for a first offence, with higher amounts for repeat violations. In rare cases, individual directors who knowingly allow non-compliance could face fines beginning at $50,000, and in exceptional circumstances, more significant penalties for repeated offences.

The good news? These situations can be avoided by staying informed and proactive.

Next Steps

In light of the new amendments, we recommend condominiums do the following:

• If you are unsure whether your condominium’s CO Alarms have been installed in accordance with the Building Code requirements as of January 1, 2025, or whether CO Alarms are required in general, contact a fire and life safety service provider or an engineer to confirm. New builds, for example, may already be in compliance!

• Conduct an audit that identifies all areas (including both common elements and units) where CO Alarms are required under the Fire Code.

• Where CO alarms are required, the best way for condominiums and management to protect themselves is to document all compliance efforts, including situations where a resident does not comply, to demonstrate that all reasonable steps have been taken to comply. Consider circulating a notice or newsletter to owners and residents that highlight these key points:

  o Owners must ensure their units contain properly installed and maintained CO Alarms in accordance with the First Code, and that those alarms remain in good working condition at all times; and

  o Owners and residents must promptly report any CO Alarm for service that they know or believe is not properly functioning, whether the CO Alarm is located within a unit or the common elements.

Should you have questions about the above, consider consulting your legal counsel, fire safety provider, or engineer for assistance.