Building Code vs Fire Code: Which One Governs What (Ontario)

Side by side

If you take one thing from this page, take the last row.

One page adopts a code written somewhere else

Ontario's Building Code is O. Reg. 163/24, in force 1 January 2025. It is one page long. Section 1, verbatim:

The code issued by the Canadian Commission on Building and Fire Codes, part of National Research Council Canada, known as CCBFC NRCC-CONST-56435E, "National Building Code of Canada 2020", (First Printing), as amended by the document entitled "Ontario Amendments to the National Building Code of Canada 2020", dated July 17, 2026 and issued by the Ministry of Municipal Affairs and Housing, are together adopted as the building code.

So the Ontario Building Code is now two documents stapled together by a regulation: NBC 2020 First Printing, plus an Ontario amendment document. The old full-length regulation, O. Reg. 332/12, was revoked effective 1 January 2025 by section 3 of O. Reg. 163/24.

The Fire Code did not change shape. O. Reg. 213/07 is still a complete, self-contained regulation you can read start to finish on e-Laws.

Old permits still run on the old Building Code

Section 2 of O. Reg. 163/24 keeps the revoked regulation alive for work already under way. Verbatim:

(1) Subject to subsection (2), Ontario Regulation 332/12 (Building Code) made under the Act, as it read on December 31, 2024, is deemed to continue in force with respect to construction, (a) for which a permit has been issued on or before December 31, 2024; or (b) for which the working drawings, plans and specifications are substantially completed on or before December 31, 2024, and for which an application for a permit is made on or before March 31, 2025 under that regulation, as it read on December 31, 2024.

(2) Subsection (1) does not apply unless the construction is commenced within six months after the permit is issued.

Two things follow. A building permitted in 2024 is still being built to the 2012 regulation, and there is a use-it-or-lose-it condition: construction must start within six months of permit issue or the transition falls away. If you are working on a long-running project, the permit date decides which Building Code text your installation is judged against.

Nothing equivalent applies on the Fire Code side. The Fire Code applies to the building as it is, now.

The free-access asymmetry nobody warns you about

This one matters and it is not a technicality.

The Fire Code is free, complete and public. O. Reg. 213/07 on e-Laws, consolidation period 1 January 2026, e-Laws currency date 12 August 2026. Every article quoted on this page you can open and read yourself in about thirty seconds.

The Building Code is not. MMAH does not publish the Ontario Amendment Document online. From ontario.ca, verbatim:

The full-length version of the Building Code will no longer be available on E-laws. Email us to request a copy of the Ontario Amendment Document.

The request address is Ontario.Amendment.Document@ontario.ca.

What you can get free right now is the 2024 Building Code Compendium — Vol. 1 and Vol. 2, both $0.00 from Publications Ontario. It is the "January 16, 2025 Update," which is four amendment-document versions behind the amendment document currently in force. The underlying NBC 2020 First Printing is free from NRC with no registration.

So: one of Ontario's two codes is fully public and the other is not. When someone quotes the Building Code at you, it is fair to ask which document they are quoting and what date it carries. Building Code quotations on this page are from the Compendium and are marked as such.

What the Building Code says about fire alarms

Two articles carry most of the fire alarm content.

Article 3.2.4.1 sets whether a building needs a fire alarm system at all. The thresholds include buildings more than 3 storeys, a total occupant load more than 300, an occupant load more than 150 above or below the first storey, a school, college or child care facility with an occupant load more than 40, and a residential occupancy with sleeping accommodation for more than 10 persons — among others. The full list is long and conditional; read it in the Compendium rather than working from any summary, including this one.

Article 3.2.4.5, verbatim from the Compendium Vol. 1, printed page 100:

(1) Fire alarm systems, including those with voice communication capability where provided, shall be installed in conformance with CAN/ULC-S524, "Standard for Installation of Fire Alarm Systems."

(2) Fire alarm systems shall be verified in conformance with CAN/ULC-S537, "Verification of Fire Alarm Systems," to ensure satisfactory operation.

That is the whole shape of the Building Code's involvement with your work: is one required, install it to S524, prove it to S537. Then construction ends and the Building Code's job is done.

There is no annual anything in there. There is no maintenance duty, no shutdown procedure, no record retention period. Those are not Building Code subjects.

What the Fire Code says about fire alarms

First, the section title, because it defeats people searching the regulation. Section 6.3 is not called "Fire Alarm Systems." Its real title is "ALARM AND VOICE COMMUNICATION SYSTEMS FOR LIFE SAFETY."

Article 6.3.2.2.(1), verbatim:

Except as provided in Sentence (2), a fire alarm system, with or without voice communication capability, shall be inspected and tested in conformance with CAN/ULC-S536, "Standard for Inspection and Testing of Fire Alarm Systems".

A precision point worth having straight: 6.3.2.2 states no frequency. It delegates the whole question of intervals to S536. The word "annual" enters the Fire Code elsewhere — Division B Article 6.3.2.1 refers to "the annual tests or annual inspections required by this Subsection," and Division C Article 1.2.1.1 applies to a person who "performs annual tests or annual inspections of a fire alarm system required under Article 6.3.2.2. of Division B." Writing "6.3.2.2 requires annual testing" misstates the text. More on that split in verification vs annual inspection.

The rest of the Fire Code's fire alarm content is all operational, and it has no Building Code counterpart:

• 6.3.1.4 — "Fire alarm and voice communication systems shall be maintained in operating condition."
• 6.3.1.8 — "Repair, replacement and alterations of fire alarm system components shall be in accordance with CAN/ULC-S524, 'Standard for the Installation of Fire Alarm Systems'."
• 6.3.1.3.(1) — on a shutdown, "(a) the fire department and building occupants shall be notified in accordance with Article 1.1.1.1., and (b) the supervisory staff shall be notified."
• 6.3.2.3 — "The central alarm and control facility shall be checked daily for indication of trouble in the system."

Note 6.3.1.8 carefully. It is a Fire Code article that points at an installation standard. Changing a device on an in-service system is S524 work, but it is S524 work required by the Fire Code, not the Building Code. This is the single most useful line to know when someone tells you a device swap "falls under the Building Code."

Different tables, different standards

Each code carries its own designation table, and each is adopted independently.

CAN/ULC-S536 does not appear anywhere in either Compendium volume. It is a Fire Code instrument only, which is exactly what you would expect from a standard about testing systems that are already in service.

Fire Code Division B, Article 1.2.1.1.(1), verbatim:

A reference in this Code to a document set out in Table 1.2.1.A. is to the edition designated in the table.

Division B, Article 1.2.1.3 lets the Chief Fire Official permit an earlier edition where compliance with the designated edition is impractical.

Right now both codes land on the 2019 editions of S524 and S537. Say that plainly, because it will not necessarily stay true. The two codes are amended on separate schedules by separate ministries, so they can drift apart. Check both tables, not one. Edition drift is covered in full in which ULC edition actually applies.

Who enforces which

The Fire Code refers throughout to the Chief Fire Official. Enforcement of the Building Code runs through the municipal building department and the permit process. Two different offices, two different files, two different sets of questions.

That is as far as we will take it. This page does not describe how either official is appointed, what powers they hold, how an order is issued, or what happens if you ignore one — none of that was verified against a source, so none of it is here.

The qualification asymmetry — the centrepiece

This is the difference that changes what you are allowed to do, and almost nobody states it correctly.

The Fire Code names a qualification for the person. The Building Code names only the standard.

Fire Code Division C, Article 1.2.1.1, verbatim:

(1) This Subsection applies to every person who (a) performs annual tests or annual inspections of a fire alarm system required under Article 6.3.2.2. of Division B, (b) performs the testing and maintenance of fire alarm system components that interconnect with other fire protection and life safety systems required under Article 6.10.1.1. of Division B, and (c) repairs, replaces or alters components of a fire alarm system.

Division C, Article 1.2.1.2.(1) sets what that person must have. They:

(a) must have successfully completed a program or course acceptable to the Fire Marshal, (b) shall, at the request of the owner or the Chief Fire Official, produce for inspection a copy of a certificate or document attesting to the successful completion of a program or course referred to in Clause (a)

Division C, Article 1.2.1.2.(2) is the supervision allowance. An unqualified person may do the work:

provided that (a) the work is done under the supervision of a person who has successfully completed a program or course required by Clause (1)(a), (b) no more than two persons work under the supervision of the person referred to in Clause (a) at the same time, and (c) the supervision is provided at the work site.

Division C, Article 1.2.1.3.(2): "The owner shall ensure that the requirements of Article 1.2.1.2. are met."

Now look at the Building Code side. Article 3.2.4.5 says systems shall be installed to S524 and verified to S537. It says nothing whatsoever about who may do either.

And note what is not on the Division C 1.2.1.1 list: verification. The hotel-retrofit verification under 9.9.4.12.(2), discussed below, is not named there, and neither is verification generally. So no Ontario provision names a qualification for performing a verification — who is acceptable is an authority-having-jurisdiction determination.

One more thing worth saying, because it is repeated constantly and it is wrong: the requirement is "a program or course acceptable to the Fire Marshal." CFAA is not named anywhere in the regulation. Which programs are accepted is administrative and can change without any amendment to a regulation. Full treatment in who can work on fire alarms in Ontario.

Where the split gets messy: hotel retrofit

The principle is clean. The edges are not.

There is exactly one place where the Fire Code reaches into installation and verification, and it is a retrofit provision for hotels. Article 9.9.4.12, Part 9 Retrofit, Section 9.9 Hotels, verbatim:

(1) Where a fire alarm system is required to be installed, extended or modified by this Section, the installation, extension or modification shall be in conformance with CAN/ULC-S524...

(2) Where a fire alarm system has been installed, extended or modified as required by this Section, the system or portion of the system shall be tested in conformance with CAN/ULC-S537...

(3) Sentences (1) and (2) do not apply to existing fire alarm system components.

Read the trigger. It is work "required by this Section" — the hotel retrofit section. It is not a general Fire Code duty to verify. But it is a real one, and it means the sentence "verification is always a Building Code matter" is not quite true.

Which is the honest version of this whole topic: the split is clean in principle and messy at the edges. Know the principle, then check for the exceptions.

The Fire Code reaches across for records

Record keeping is the other place the two codes visibly interlock.

Fire Code Article 1.1.2.2, verbatim:

(1) Subject to Sentence (2), the original or a copy of any record required by this Code shall be retained at the building to which the record relates (a) for a period of at least two years after being prepared, and (b) so that at least the most recent and the immediately preceding record of a given test or inspection are retained.

(2) The initial verification or test reports for fire protection systems installed after November 21, 2007 shall be retained throughout the life of the systems, regardless of whether the systems are installed in accordance with this Code or the Building Code.

Sentence (2) is the one to notice. The Fire Code is imposing a retention duty on a document produced under the Building Code. The verification report is generated by construction work under Article 3.2.4.5.(2), and then the Fire Code — the operations code — says keep it for the life of the system.

So the practical rule: annual inspection records, two years and at least the last two. Original verification report, forever.

The boundary case: integrated testing

The cleanest illustration of how the two codes interlock is Fire Code Article 6.10.1.1, verbatim in relevant part:

(1) This Section applies to the testing and maintenance of integrated fire protection and life safety systems that are (a) installed on or after January 1, 2020, and (b) required by the Building Code to be verified in conformance with CAN/ULC-S1001...

(4) The one year integrated test required by CAN/ULC-S1001 in Sentence (2) is waived for a fire protection and life safety system installed before January 1, 2026.

Look at clause (1)(b). This is a Fire Code duty whose trigger is defined by the Building Code. Whether you owe ongoing integrated testing depends on whether the Building Code required an S1001 verification on that building in the first place. You cannot answer the Fire Code question without opening the Building Code.

And get the date right. 1 January 2026 is when the one-year integrated test stops being waived — it is not the date S1001 first applied.

Integrated testing is also the second item on the Division C 1.2.1.1 qualification list, so unlike verification, the person doing it does fall under the Fire Marshal's program-or-course requirement.

Which one applies to your job

Run it in this order.

1. Is there a permit, or is this construction? Building Code. Install to S524, verify to S537, and check the permit date against the O. Reg. 163/24 transition rule — a pre-2025 permit may still be running on the revoked O. Reg. 332/12.
2. Is the system in service, with no construction attached? Fire Code. Inspection and testing to S536, maintenance under 6.3.1.4, repairs and alterations to S524 under 6.3.1.8, shutdown notification under 6.3.1.3, and the Division C qualification requirement applies to you.
3. Is it a hotel retrofit under Part 9, Section 9.9? Fire Code, but with S524 and S537 pulled in by 9.9.4.12.
4. Is it integrated systems testing? Fire Code 6.10.1.1 — but check the Building Code to find out whether the section applies at all.
5. Still not sure? Ask which office is going to sign off. Building department, or Chief Fire Official. The answer to that is the answer to everything else.

For how Ontario's amendments differ from the national code underneath them, see Ontario vs National Building Code on fire alarms.

What is not on this page, and why

Anything inside CAN/ULC-S524, S536 or S537 is out of scope here. Those standards are paywalled, and we are not going to paraphrase copyrighted content we cannot show you. If you need the procedures, methods, intervals or report contents, you need the standards themselves.

Also absent: penalties, inspector powers, permit procedure, how an order is issued, and any statute section numbers. Those were not verified against a source, so they are not here.

What is here is what the two regulations say, because the Fire Code half is free to everyone and most people in the trade have never opened it.

Check it yourself, free

1. Ontario Fire Code, O. Reg. 213/07 on e-Laws — read Section 6.3, Article 6.10.1.1, Article 1.1.2.2 and Division C 1.2.1.1 to 1.2.1.3. All of it, no cost.
2. O. Reg. 163/24 on e-Laws — one page. Read sections 1, 2 and 3 to see the adoption, the transition and the revocation.
3. 2024 Building Code Compendium Vol. 1 and Vol. 2 — $0.00. Article 3.2.4.5 is on printed page 100 of Vol. 1.
4. NBC 2020 from NRC — free, no registration.
5. The Ontario amendment document in force, dated 17 July 2026 — by email only, from Ontario.Amendment.Document@ontario.ca.

Last updated: August 2026. Fire Code quotations are from O. Reg. 213/07 on e-Laws, consolidation period 1 January 2026, e-Laws currency date 12 August 2026, last amendment O. Reg. 303/25. Building Code quotations are from the 2024 Building Code Compendium, the January 16, 2025 Update; O. Reg. 163/24 carries a consolidation period of 22 July 2026 against the same e-Laws currency date of 12 August 2026, last amendment O. Reg. 242/26, and the Ontario amendment document in force is dated 17 July 2026 and is not published online.

General information, not compliance advice. Confirm against the code text in force for your project and with your authority having jurisdiction.