Ontario Condo Reserve Fund Reforms 2026 — What Didn't Pass | Ontario Condo Guide

When Bill 72, the Buy Ontario Act, 2025 received Royal Assent in December 2025, Ontario condo law entered another year of partial certainty. Some long-pending amendments got more time. Others — including reforms many owners and industry groups considered urgent — expired.

Among the proposals that did not survive: clearer reserve fund adequacy rules, standardized procurement processes, faster budget disclosure, and chargeback transparency requirements.

This guide explains what was proposed, why it mattered to the sector, and what corporations should do now under current law. It draws on public statements from the CAO and advocacy from groups including CCI Toronto, which urged renewed legislative action in early 2026.

What this means

Ontario condos fund major repairs and replacements through reserve funds — separate from operating budgets. Corporations must obtain reserve fund studies on a statutory schedule and contribute based on professional recommendations.

For years, pending PCO Act amendments promised clearer standards for what “adequate” funding means, when a major repair triggers action, and when corporations need an expert opinion on whether to update a study early. Related proposals would have regulated procurement, given owners faster budget copies, and required formal chargeback notice before owners were billed.

Those amendments were never proclaimed. Bill 72 did not extend them. As of December 31, 2025, they are no longer part of the pending legislative package.

That does not mean reserve funds stopped mattering. It means corporations must continue under today’s rules — and many boards still face underfunded reserves, special assessment pressure, and owner mistrust.

What was proposed — and lost

Reserve fund adequacy

Pending amendments would have:

• Defined adequate funding more clearly
• Clarified what counts as a major repair
• Required written expert opinions when funds appear insufficient — potentially forcing earlier reserve fund study updates

Why it mattered: Owners and managers debated reserve adequacy for years without a single legislative standard. Underfunded corporations delay repairs, face special assessments, and struggle with insurance and lender scrutiny.

Current reality: Existing reserve fund study obligations and board duty of care still apply. No new adequacy definition arrived with Bill 72.

Procurement rules

Pending amendments would have opened the door for regulations standardizing how all Ontario condos conduct procurement — from cleaning contracts to major capital projects.

Why it mattered: Inconsistent procurement practices contribute to conflict-of-interest allegations and cost disputes.

Current reality: Boards should follow internal controls and director duties — documented quotes, competitive processes for large contracts, conflict disclosure — without waiting for province-wide rules.

Budget transparency

Pending amendments would have required corporations to give owners budget copies separately and more quickly when budgets change — beyond Periodic Information Certificates.

Why it mattered: Owners often learn about fee increases late, after decisions are effectively made.

Current reality: PICs and AGM financial presentations remain primary disclosure channels. Boards that want trust should proactively communicate budget drivers before notices go out.

Chargeback transparency

Pending amendments would have expanded chargeback scenarios and required mandatory notice and response timelines before owners were billed for common expense recoveries.

Why it mattered: Chargebacks are a perennial source of CAT disputes and owner anger — especially when owners receive bills without understanding the underlying rule violation.

Current reality: Chargebacks remain governed by current Act provisions, your declaration, bylaws, and rules, and existing dispute forums. Document notices and keep consistent enforcement.

Industry reaction

In early 2026, CCI Toronto wrote to Ontario’s Auditor General renewing calls for condo oversight improvements tied to the 2020 Value-for-Money Audit. The letter highlighted that reserve fund, procurement, budget, and chargeback amendments were not preserved in Bill 72 — calling them critical to affordability and governance.

Advocacy groups including CAI Canada similarly noted that financial provisions were among those not extended, while shared-facility and requisition-related items survived the extension.

Whether the government introduces new legislation revisiting these topics is uncertain. Boards should not assume relief is coming — or that current underfunding will be retroactively excused.

When it matters

These expired reforms matter most when:

• Your reserve fund study shows growing shortfalls
• Owners question special assessments or fee increases
• Chargebacks trigger tribunal applications
• Major repair decisions are deferred for cost reasons
• Buyers’ lawyers flag underfunded reserves on status certificate review

They matter less as a “wait and see” strategy. The legislative moment passed for these specific amendments.

What boards and owners should do now

For boards

1. Treat the reserve fund study as mandatory planning, not a shelf document. Update on schedule and when property condition changes.
2. Fund reserves based on professional advice, even without a new “adequacy” definition in law.
3. Present reserve status clearly at the AGM — contributions, major projects, and funding gaps.
4. Document procurement for major contracts — quotes, board votes, conflict disclosures.
5. Standardize chargeback notices internally — rule citation, amount, deadline to respond, payment consequences.
6. Monitor legislative news via Bill 72 explainer and CAO updates — but govern under current law today.

For owners

1. Read reserve fund study summaries in AGM packages.
2. Ask how the board funds upcoming major repairs before approving budgets.
3. Challenge chargebacks through proper channels with written records.
4. Support reasonable fee increases when underfunding threatens property condition — or expect special assessments later.

Connection to meetings and AGMs

Reserve fund status is central AGM content. Owners cannot exercise oversight if financial and reserve reporting is vague or delayed. Strong AGM preparation — see our AGM guide and common AGM mistakes — includes honest reserve discussion even without new budget-disclosure law.

Director elections also hinge on financial credibility. Boards that defer reserve reality often face requisitioned meetings or contested elections.

Bottom line

Bill 72 extended some Condo Act amendments but not the reserve fund, procurement, budget, or chargeback reforms many sector groups prioritized. Those proposals expired at the end of 2025.

Corporations still have legal obligations today. Good governance — funded reserves, transparent AGMs, documented procurement, fair chargeback process — does not require waiting for Queen’s Park.

Related resources

• Bill 72 and pending Condo Act changes explained
• CAO annual return filing guide (2026)
• Ontario condo AGM guide
• Ontario condo director duties