The Ontario Fire Code Changes That Took Effect 1 January 2026: For the Technician Doing the Work
O. Reg. 87/25 amended the Ontario Fire Code effective 1 January 2026. It did not replace it, the Fire Code is still O. Reg. 213/07, as amended. For anyone doing fire alarm inspection and testing, four things changed on the ground: the report forms became mandatory in format, battery testing now requires actual load testing with recorded measurements, deficiencies must be documented separately from general notes, and attendance logs need names, dates and times.
Sources checked August 2026
Quick answer
- What it is: an amending regulation, O. Reg. 87/25, made under the Fire Protection and Prevention Act, 1997 (the Fire Code has since been further amended by O. Reg. 303/25)
- What it did: amended the Ontario Fire Code (O. Reg. 213/07) and created the Code's first French edition
- In force: 1 January 2026, with a few exceptions
- Standards adopted (Table 1.2.1.A): CAN/ULC-S524-2019, S536-2019, S537-2019, S531-2019, S552-14, S553-14, S561-13, S1001-11. Note S537 is invoked by the Fire Code only at Article 9.9.4.12.(2) (Part 9 retrofit, hotels), general verification of new systems is a Building Code matter
- Who it hits hardest: the technician filling out the report
First, a correction that a lot of articles get wrong
You will read, in a lot of places, that O. Reg. 87/25 "replaced" the Ontario Fire Code.
It didn't.
The Ontario Fire Marshal's own communiqué, dated 5 June 2025, says:
O. Reg. 87/25 introduces changes to the Ontario Fire Code (O. Reg. 213/07) and creates the first French edition of the Code. The changes to the OFC will come into force on January 1, 2026 with a few exceptions.
The Fire Code is still O. Reg. 213/07, as amended. If a document you are reading says otherwise, treat that as information about how carefully the rest of it was researched.
Worth noting too: OFM says there are exceptions to the 1 January 2026 date. Which provisions those are is not enumerated in the published communiqué. If you are relying on a specific provision being in force, confirm it rather than assuming.
Almost everything written about this was written for building owners
Search "Ontario Fire Code 2026" and you get property management firms, fire protection service companies and landlord associations explaining what building owners must now do.
That is a legitimate audience. It just isn't yours.
Nobody wrote it for the person who has to actually perform the load test, fill out the prescribed form, and decide whether something goes in the deficiency column or the recommendations column. So here it is.
The four changes that affect your day
Sourcing: these four points are reported consistently by Canadian trade sources, but they are not quoted from the regulation or from the standard, neither of which we have been able to verify them against. Treat them as reported rather than settled. The source for each is linked in place below.
1. Report forms are mandatory in format
This is the one that will get your paperwork rejected.
UL briefing material and provincial fire marshal bulletins describe the 2019 editions of S536 and S537 as moving the report forms out of the appendix, where they were a suggested format, and into the body of the standard, changing them from a template into a requirement. That is the consistent account in the trade material; we have not been able to verify it against the standards themselves.
UL's own material and Calgary's fire marshal state the rule identically:
Tests or inspections may not be reworded or revised in order or format.
(BOABC / UL, May 2023 · Calgary Fire Marshal Bulletin 2025-001)
Ontario's own framing, via the Ontario Association of Fire Chiefs: "All reports to follow a standardized format with detailed documentation. Monthly and annual inspections must use prescribed forms." (OAFC)
What this means practically:
- ✅ You may add your company logo
- ✅ You may recreate the form in your own software
- ❌ You may not reword a test description
- ❌ You may not reorder the tests
- ❌ You may not delete rows that don't apply, mark them N/A
- ❌ Your shop's twenty-year-old custom checklist is no longer acceptable
Calgary (Alberta, but the direction of travel is the same) rejects partial reports outright.
If your company still runs a homegrown inspection sheet, that is the first thing to fix. It is also the easiest deficiency for an inspector to spot, because they do not even need to look at the building.
2. Battery testing means an actual load test now
The old habit, put a meter across the terminals, write down 27.2 V, move on, does not satisfy this.
Battery testing must go beyond basic voltage checks to include functional or load testing with recorded results.
(OAFC, corroborated by REMI Network)
The 2019 edition of S536 introduced a silent accelerated battery test method to replace the previous meter-based approach. (Rotaflow)
Two things follow from this. You need the right equipment and the right procedure, not just a multimeter. And you need to record the measurement: an unrecorded test is, for compliance purposes, a test that did not happen.
A related point worth knowing: battery derating appears on the revision topic list for the 2024 edition of S524. (Standards Council of Canada) Battery calculations are an active moving target, don't assume the numbers you learned five years ago still hold.
3. Deficiencies go in their own column
Any deficiencies identified must be documented separately from general notes to create clearer action lists.
(OAFC)
The 2019 editions revised the terminology for recording findings. The current pair is Deficiency and Recommendation. The older third term, Remark, was deleted and replaced with Comments. The free source for that, and the limits on how far it reaches, are set out on that page.
Two limits worth carrying. That sentence names S537, so reading it across to S536 is inference rather than text. And no free source confirms what the replacement block is headed on the printed form, because the forms sit inside the paywalled standards. Legacy forms and older inspection software still in circulation may show a Remarks block.
The distinction matters more than it looks. A deficiency is a compliance failure that creates an obligation on the owner to rectify. A recommendation is your professional advice, which the owner may price and decline.
Burying a genuine deficiency in a paragraph of general notes used to be common, sometimes to keep a client happy. Under the current structure it is a documentation failure in its own right, and it puts you rather than the owner on the wrong side of it.
4. Attendance logs need real detail
Attendance logs must include specific details such as names, dates, and times.
(OAFC)
"Tech attended, Q3" is not a log. Who, when, and for how long.
Isolator testing: new, and worth knowing about
A Canadian trade source reports that the 2026 changes bring a specific protocol for testing fault isolators:
- Document the location and identification of each isolator
- Map isolator and device interaction across fire separations
- Verify that isolated zones operate independently
- Confirm automatic resumption after the fault is cleared and the panel reset
- Record loop performance and control panel response under a simulated fault
- Test each isolator individually, via temporary fault simulation
This is a single trade source rather than a primary one, so treat the specifics as reported rather than settled, but the direction is consistent with everything else in the 2019 standards, and if you work on residential buildings with suite fault isolators it is worth confirming with your AHJ before your next annual.
If you are unclear on what suite fault isolators are and where they go, we cover that in the guide to the four ULC standards, including the detail that catches people out, which is that the isolator is installed outside the suite it protects.
What else is in the amendment
Monitoring documentation. Where a system is monitored by a central station, the owner must obtain documentation confirming compliance with CAN/ULC-S561. (OAFC)
Integrated systems testing. Fire Code Article 6.10.1.1 applies to integrated fire protection and life safety systems installed on or after 1 January 2020, and requires testing to CAN/ULC-S1001. Sentence (4) waives the one-year integrated test required by S1001 for any system installed before 1 January 2026: check the install date before scheduling it. This is the standard that covers the interfaces, fire alarm to fire pump, to dampers, to elevator recall, to door hold-open release. Verifying the fire alarm proves nothing about whether the elevators actually recall.
Carbon monoxide. Buildings heated by forced-air fuel-burning appliances must comply with new CO alarm placement rules effective 1 January 2026. (OAFC · TSSA)
A French edition. The Fire Code now exists in French for the first time. (OFM Communiqué 2025-02)
Which editions did Ontario actually adopt?
This is the part people skip, and it matters.
Ontario adopted CAN/ULC-S536-2019 and CAN/ULC-S537-2019 effective 1 January 2026. Verified directly from the Fire Code's own referenced-documents table on Ontario e-Laws, which also shows S524-2019, S531-2019, S561-13 and S1001-11.
Note those last two: Ontario adopts the 2013 edition of S561 and the 2011 edition of S1001, considerably older than what is currently published.
Those editions were published in 2019. Ontario reached them roughly six and a half years later.
Meanwhile the newest published installation standard is CAN/ULC-524-2024: the 8th edition, published 23 December 2024 (note the "S" has been dropped from the designation). (Accuris)
Owning the newest standard does not mean you may build or test to it. The edition that governs is the one your code has adopted, and the answer differs by province and by instrument. Alberta moved to S536-19 on 1 May 2024. (Calgary Fire Marshal Bulletin 2025-001)
Ask the AHJ. Every time.
What it costs to get this wrong
Penalties under the Fire Protection and Prevention Act, 1997:
| Maximum | |
|---|---|
| Individuals (s.28) | $50,000 and/or up to 1 year imprisonment |
| Corporations (s.29) | $100,000 |
| Continuing offences (s.30) | up to $20,000 per day |
One thing we are not going to tell you: several articles currently claim that Administrative Monetary Penalties for Fire Code violations came into force on 1 January 2026. A proposal for AMPs under the FPPA does appear on Ontario's regulatory registry, but we could not confirm from any source that they were enacted, what they attach to, or what the amounts are. Until that can be verified, the penalties above are the ones we can stand behind.
Your practical checklist
- Are you using the prescribed report forms rather than a company checklist?
- Does every inapplicable row say N/A rather than being deleted or left blank?
- Are you performing an actual battery load test and recording the measurement?
- Are deficiencies in their own section, separate from recommendations and from general notes?
- Does your attendance log carry names, dates and times?
- For monitored systems, has the owner obtained S561 documentation?
- For integrated systems, is S1001 testing scheduled?
- Do you know which edition your AHJ has adopted for this building?
Fire Alarm Academy provides educational content only. It does not confer any certification, licence or credential, and it is not affiliated with, endorsed by, or accredited by the Canadian Fire Alarm Association, the Electrical Contractors Association of Ontario, ULC Standards, UL Standards and Engagement, CSA Group, the Electrical Safety Authority, any authority having jurisdiction, or any manufacturer. Always work from the edition of any standard adopted by your authority having jurisdiction.
Frequently asked questions
Did O. Reg. 87/25 replace the Ontario Fire Code?
No. It amended it. The Ontario Fire Code remains O. Reg. 213/07, as amended. The Ontario Fire Marshal's communiqué says the regulation "introduces changes to" the Fire Code.
When did the changes take effect?
1 January 2026, with a few exceptions that the published communiqué does not enumerate. Confirm before relying on a specific provision.
Can I still use my company's own inspection checklist?
No. Since the 2019 editions the report forms sit in the body of the standard and may not be reworded or revised in order or format. You may add a logo and recreate the form; you may not change its structure.
Is a voltage reading enough for battery testing now?
No. Battery testing must include functional or load testing with recorded results. The 2019 edition of S536 introduced a silent accelerated test method to replace the meter-based approach.
What is the difference between a deficiency and a recommendation?
A deficiency is a compliance failure creating an obligation to rectify. A recommendation is professional advice the owner may price and decline. The two must be documented separately from general notes. Remark was an older third term: UL's own May 2023 briefing to BC building officials says it was deleted in the 2019 edition of S537 and replaced with Comments, so a Remarks block now means a legacy form. That sentence names S537, so reading it across to S536 is inference, and the printed forms sit inside the paywalled standards.
Which editions of the ULC standards does Ontario now use?
S536:2019 and S537:2019 as of 1 January 2026, together with S561 for monitoring and S1001 for integrated testing. Note that the current *published* installation standard is CAN/ULC-524-2024, newer than what the codes reference.
Do these changes apply outside Ontario?
No. This is the Ontario Fire Code. The CAN/ULC standards are national, but each province adopts them on its own schedule, Alberta moved to S536-19 in May 2024, ahead of Ontario.
Sources
- Ontario Fire Marshal Communiqué 2025-02
- Ontario Association of Fire Chiefs: Fire Code updates
- REMI Network
- TSSA: CO alarm requirements
- FireCode.legal: offences and penalties
- BOABC / UL: Changes to ULC Fire Alarm Standards
- Calgary Fire Marshal Bulletin 2025-001
- Rotaflow: changes to ULC-S536
- FSS Canada: 2026 isolator testing requirements
- Standards Council of Canada: S524 revision notice
- Accuris: CAN/ULC 524:2024
Related guides
Building Code vs Fire Code: Which One Governs What (Ontario)
The Building Code governs how a building is designed and constructed. The Fire Code governs how a building is operated and maintained once it is in use. In Ontario they are two separate regulations, O. Reg. 163/24 for the Building Code, O. Reg. 213/07 for the Fire Code, made under two separate statutes, enforced by different people, and each with its own table of referenced standards. The practical test on site is simple: if the work is construction, installation, extension or modification, you are in Building Code territory and the municipal building department and its permits are the enforcement path. If the system is already in service and you are inspecting, testing, maintaining or shutting it down, you are in Fire Code territory and the Chief Fire Official is the enforcement path. That split decides which standard applies, how often something has to be done, and whether Ontario names a qualification for the person doing it.
Fire Alarm Verification vs Annual Inspection and Testing in Ontario (S537 vs S536)
They are two different duties under two different laws, and the trade mixes them up constantly. A verification is a CAN/ULC-S537 check of what was just installed, and in Ontario it is a Building Code requirement, Article 3.2.4.5.(2). Inspection and testing of a system already in service is CAN/ULC-S536 work required by Fire Code Article 6.3.2.2, which states no frequency of its own; "annual" comes from Division B Article 6.3.2.1 and Division C Article 1.2.1.1. The Fire Code names S537 in exactly one article, 9.9.4.12.(2), which applies only to hotel retrofits under Part 9, so there is no general Fire Code duty to verify. The Fire Code sets a qualification requirement for the person doing the annual inspection and none for the person doing the verification. And the annual inspection record has to be kept two years, while the original verification report has to be kept for the life of the system.
Canadian Fire Alarm Code Updates: What Changed and When
Ontario's fire alarm code has changed more in the last twenty months than in the decade before it. The Building Code was revoked and replaced on 1 January 2025, Subsection 3.2.4 was renumbered to match NBC 2020 (a shift of 0, one or two articles depending on where it sits, not a flat two) and low frequency signals in sleeping rooms became a requirement for the first time. The Fire Code moved to the 2019 ULC editions on 1 January 2026. Four Building Code amendments since are not listed on Ontario's own updates page. This is the dated log, newest first, maintained as things change.
Who Can Legally Install, Verify and Test Fire Alarm Systems in Ontario?
Ontario law does name who may work on fire alarm systems, and most articles on this subject get it wrong. Under Division C, Subsection 1.2.1 of the Ontario Fire Code, anyone performing annual tests or inspections, or repairing, replacing or altering fire alarm system components, must have completed a program or course acceptable to the Fire Marshal. The regulation names no program itself; the Fire Marshal's published list currently holds two, the CFAA Fire Alarm Technician Training Program and the ECAO Certi-Fire program. Separately, the electrical installation work itself requires a 309A certificate, because electrician is a compulsory trade.
Which Ontario Building Code Is Actually In Force?
The Ontario Building Code is O. Reg. 163/24, and the regulation does not contain the code. Section 1 adopts the National Building Code of Canada 2020 (First Printing) together with a Ministry document called Ontario Amendments to the National Building Code of Canada 2020, identified in the regulation by its date. That date has been changed four times since the code came into force on 1 January 2025, most recently to 17 July 2026 by O. Reg. 242/26, filed 22 July 2026. Construction permitted on or before 31 December 2024 stays on O. Reg. 332/12 as it read at the end of 2024, provided construction started within six months of the permit being issued.