Reducing building code burden means modernizing how the code is delivered
Ontario is taking a close look at its Building Code.
The Ministry of Municipal Affairs and Housing recently completed the initial phase of its consultation on reducing unnecessary cost, delay, complexity and administrative burden in the Code, while maintaining health, safety, accessibility and performance outcomes.
That review is important. But there is another source of regulatory burden that deserves equal attention: the way the Building Code is delivered. For applicants and municipal reviewers, the Code is experienced not only through its rules, but through the forms, portals, data requirements, submission processes and review workflows used to administer them.
Modernizing the rules without modernizing that machinery leaves a significant part of the problem untouched.
What regulatory fragmentation looks like in practice
Consider a designer working on similar residential projects in three Ontario municipalities.
The provincial Building Code is the same, and many of the technical questions are the same. But the designer may encounter different portals, document conventions, submission requirements, revision processes and ways of receiving review comments in each municipality.
Some local differences are necessary. Zoning, servicing, site conditions and municipal processes vary for legitimate reasons. But not every difference reflects a local policy choice. Much of the underlying administrative and technical infrastructure is solving the same basic problem repeatedly.
How much of that infrastructure truly needs to be recreated hundreds of times?
Ontario has already encountered this problem with e-permitting
Ontario has spent years supporting the modernization of municipal development approvals.
Through the Streamline Development Approval Fund, the Province made more than $45 million available to 39 of Ontario's largest municipalities for initiatives that included e-permitting systems, online application portals and other approval-streamlining projects.
At the same time, the Province has supported work on common data standards for planning and development applications. Those investments helped municipalities move away from paper-based processes. But they also highlight an important lesson: putting a process online does not automatically make the broader system interoperable.
A digital application can still use different terminology, data structures and document conventions from the municipality next door, forcing applicants to re-enter information and technology providers to build multiple integrations.
The Province has acknowledged that municipal planning and building application tracking systems vary significantly and has identified standardization, digitization and technologies such as artificial intelligence as areas for further work. The lesson is that digitization without common foundations eventually creates another interoperability problem.
AI makes the coordination question more urgent
Artificial intelligence is now entering the same environment.
Toronto is advancing an AI-assisted building plan pre-assessment pilot intended to improve the efficiency and speed of permit reviews. Brampton is exploring AI for building permit pre-screening, including identifying incomplete submissions and inconsistent information.
These are practical uses of technology. If a system can flag a missing document, organize information or identify issues before a detailed review begins, Building Officials can spend more time on work that requires professional judgment.
The challenge is what happens if every municipality must independently create the foundations required to make those tools work. Useful AI requires structured, version-controlled Code information, reliable application data and clear boundaries between automated assistance and professional judgment. If municipalities and technology providers construct those foundations independently, Ontario risks solving the same underlying problem many times.
What could actually be shared?
Shared digital infrastructure means standardizing the parts that are common while preserving local processes, statutory responsibilities and professional judgment.
1. A machine-readable Building Code
Ontario has already identified enhanced digitization of the Building Code as an opportunity to support automation. A structured, authoritative digital version could give software reliable access to provisions, definitions, amendments and effective dates, with changes maintained through a controlled source. It would not replace legal interpretation. It would provide a dependable foundation for better digital tools.
2. Common data standards
Permitting systems can remain different while using common definitions for core information such as permit type, building use, project address, applicant information and review status. That would make it easier to exchange information between systems, reduce manual reconciliation and give future digital tools more consistent data to work with.
3. Shared pre-screening tools
Some early-stage permit activities could also be supported by common tools. Technology could help identify missing documents, incomplete information, obvious inconsistencies or potentially applicable Code provisions before detailed review begins. These tools would not determine compliance. They would help ensure a more complete and organized application reaches the professional responsible for review.
4. Local authority remains local
Municipal zoning, servicing requirements, site conditions and other local considerations would remain with local authorities. The objective is not to eliminate local differences. It is to distinguish more clearly between what is provincial, what is municipal and what is project-specific.
What would that mean on an actual permit?
Imagine an architect preparing a residential permit application. Today, information shown on drawings may still be re-entered into forms, missing documents may not be identified until review begins, and revised submissions can trigger repeated administrative work.
With common standards, core project information could move directly from design software into a municipality's existing permitting system. A shared Code service could identify the applicable version of the Code, while pre-screening tools flag missing information or organize changes between submissions. The Building Official would still review the application. The municipality would still issue the permit. Architects and engineers would remain responsible for their professional work. The difference is that less professional time would be spent moving information between systems or resolving avoidable administrative issues.
That is what digital burden reduction can look like.
Solve common problems once
The investment should be in the infrastructure underneath those systems: authoritative digital regulatory information, common data standards, interoperable interfaces, version control and clear governance around automated tools. Ontario has already begun moving in this direction through common data standards, plans to explore enhanced Building Code digitization, and municipal experimentation with AI. The opportunity now is to connect those efforts.
Where something genuinely needs to be local, keep it local. Where professional judgment is required, preserve it. Where municipalities need flexibility, maintain it. But where municipalities, professionals and technology providers are repeatedly solving the same underlying technical problem, Ontario should ask whether that problem can be solved once and shared.
As Ontario considers how to reduce regulatory burden and accelerate housing delivery, building that foundation may prove every bit as important as simplifying the rules themselves.
Sources
https://news.ontario.ca/assets/files/20251023/56f8ae306aaed7abc089126aecdeaffa.pdf
https://news.ontario.ca/assets/files/20250512/19d2a4c35c57a7991c6ed55c42393cd2.pdf
https://ero.ontario.ca/notice/019-6619
https://www.toronto.ca/legdocs/mmis/2025/ex/bgrd/backgroundfile-256284.pdf
https://www.brampton.ca/EN/City-Hall/AI-POC
https://secure.toronto.ca/council/agenda-item.do?item=2026.PH30.12&
