October 21, 2026

Toronto Green Standard in 2026: What Still Applies After Bill 98

The Toronto Green Standard is the City of Toronto’s set of environmental performance requirements for new development, applied through planning applications since 2010. Version 4 still applies to applications received on or after May 1, 2022. What changed is how much of it is mandatory. Since Bill 98 received Royal Assent on June 2, 2026, the City reviews applications against an interim Version 4 checklist: bicycle parking, stormwater, tree soil volume, bird-friendly glazing, waste rooms and pedestrian space are still required, while the energy and greenhouse gas targets, EV charging and green roofs are now voluntary. Tiers 2 and 3 remain voluntary, with a partial development charge refund for projects that achieve them.

Everything below was checked on October 20, 2026 against the City of Toronto’s TGS pages, the interim checklist (dated June 2026, page last modified October 9, 2026) and e-Laws. The City calls these changes interim and has said a broader review of the standard will follow, so confirm with the planner on your file before you lock a design. This is a practical guide for owners and developers, not legal advice.

Where the Toronto Green Standard stands in October 2026

As of October 20, 2026, the position comes down to three points.

The standard still exists and still applies. The City’s Toronto Green Standard page says Version 4 came into effect on May 1, 2022 for new planning applications, that Tier 1 is mandatory and applied through the planning approval process, and that the Development Charge Refund Program still pays for verified Tier 2 and higher projects. Version 3 still governs applications received from May 1, 2018 to April 30, 2022.

The province has narrowed what the City can make mandatory. Bill 98 removed “sustainable design” from the matters site plan control can address, and confirmed that environmental construction standards sit with the Building Code, not with municipal approvals. The City’s response, set out in a June 3, 2026 staff report, was to move some Tier 1 measures from mandatory to voluntary and keep the rest.

The interim position is not the final one. The staff report calls the changes “interim, until a broader review of the TGS program can be undertaken.” A review of Version 4 that began before Bill 98 had been paused and will restart. There is no Version 5 in force.

Sources: City of Toronto, Toronto Green Standard; Overview of Bill 98 Implications with Respect to Planning Matters, June 3, 2026; City of Toronto, How Ontario’s Planning Rules Have Changed, July 2026.

What Bill 17 and Bill 98 changed, and what still applies

Two provincial bills did the work, about a year apart.

Bill 17 (2025): the Building Code comes first

The Protect Ontario by Building Faster and Smarter Act, 2025 (Bill 17, S.O. 2025, c. 9) added a line to section 35 of the Building Code Act, 1992. The Act already said that it and the Building Code “supersede all municipal by-laws respecting the construction or demolition of buildings.” The new subsection 35(1.1), in force June 5, 2025, says the general by-law powers in the Municipal Act and the City of Toronto Act “do not authorize a municipality to pass by-laws respecting the construction or demolition of buildings.”

Then, effective November 3, 2025, the Province removed the City’s authority to require green roofs by Order in Council 1374/2025. The City says the Green Roof By-law (Municipal Code Chapter 492) is “therefore no longer in effect.” Its own green roof pages, last modified in November 2025, still describe the old coverage table, so read them as history. The City will keep putting green roofs on its own new buildings.

Bill 98 (2026): sustainable design leaves site plan

The Building Homes and Improving Transportation Infrastructure Act, 2026 (Bill 98, S.O. 2026, c. 8) received Royal Assent on June 2, 2026. The parts that touch the TGS came into force that day:

1. “Sustainable design” is out of site plan. The Planning Act clause that let municipalities review “matters relating to exterior design, including … sustainable design” was repealed (s. 41(4)(d)), and the City of Toronto Act, 2006 was changed to match (s. 114).
2. Environmental standards are construction standards. Site plan can’t control “the manner of construction and standards for construction,” and the Acts now say that includes “standards for the protection or conservation of the environment” (Planning Act s. 41(4.1.2); City of Toronto Act s. 114(6.2)). The Building Code Act says the same about municipal by-laws (s. 35(4)).
3. No EV charging requirements. An owner can’t be required to provide electric vehicle supply equipment for parking through site plan (Planning Act s. 41(9.2); City of Toronto Act s. 114(13.1)) or through a zoning by-law (Planning Act s. 34(1.1.1)).

So the energy, emissions and green roof parts of Tier 1 were the ones the City could no longer require. Measures tied to zoning, engineering standards, health, safety and neighbouring land are what the interim checklist keeps.

If your site plan application was already in review on June 2, 2026, the City’s checklist page says the interim checklist applies to “all planning applications (and resubmissions)” received on or after May 1, 2022. So expect your next resubmission to use it, and ask your community planner what that means for conditions already in your file, because the answer depends on how far the application has gone.

Is the Toronto Green Standard a by-law, and does it apply to you?

No. The TGS is a City standard that implements the environmental policies of Toronto’s Official Plan and the requirements of several City divisions. The City’s overview says Tier 1 is required through the planning approval process, and the checklist names the three applications it goes in with: rezoning, draft plan of subdivision and, most of all, site plan control. Tier 1 has to be met to get site plan approval.

That is why its reach depends on whether your project goes through those processes. If it needs site plan approval, Tier 1 applies. If it doesn’t, the TGS doesn’t reach it through site plan, and the Building Code, zoning and the City’s engineering standards are what govern.

For private development, Version 4 comes in two forms, chosen by building type:

• Mid to high-rise residential and non-residential: residential apartment buildings of four storeys and more, and all industrial, commercial and institutional development (City of Toronto, Version 4).
• Low-rise residential: development under four storeys where a site plan control application is required. As of October 20, 2026 the City’s low-rise checklist page lists the interim checklist as “coming soon”, so ask the planner which form to file.

When site plan applies is set out in our guide to site plan control in Ontario. In short, the whole of Toronto is a site plan control area, and residential buildings of 10 units or fewer are exempt unless the land is within 300 metres of a rail line or 120 metres of a ravine or other water feature.

Multiplexes, garden suites and small buildings

Usually the TGS doesn’t reach them, because they don’t go through site plan. A fourplex or sixplex has 10 units or fewer, and laneway and garden suites are exempt under Toronto’s site plan by-law (Municipal Code Chapter 415). Our guide to building a multiplex in Toronto covers what does apply: zoning, the Building Code, development charges and the designer you need. A minor variance at the Committee of Adjustment doesn’t bring the checklist with it either. Above 10 units, or on a lot near rail or water, check whether site plan applies before you assume either way; a three-storey, 12-unit building that needs site plan approval uses the low-rise version.

What Tier 1 requires now, mandatory and voluntary

The table follows the interim checklist for mid to high-rise residential and all new non-residential development. “Applies to” is the application type the checklist names: ZBA for a zoning by-law amendment, SPC for site plan control, SUB for a plan of subdivision. The full measures and specifications are on the City’s Version 4 pages; the checklist is linked from the checklists and templates page.

Still mandatory

Source: TGS Version 4.0 Interim Checklist, June 2026. The City lists the bird-friendly measures as “retained, pending further review”, tied to federal and provincial wildlife legislation, so they are the ones most likely to change next.

Now voluntary

Source: interim checklist and Attachment 1 to the June 3, 2026 staff report.

The energy numbers, for anyone still aiming at them

Tier 1 energy targets now matter in two situations: you want the DC refund, whose high-performance standards the City left unchanged by Bill 98, or you have your own reason to model, such as a lender’s energy requirement. The City’s Buildings Energy, Emissions and Resilience page (modified August 24, 2026) sets them out:

TEUI is total energy use, TEDI the heating demand of the envelope and ventilation, GHGI the emissions intensity; mixed-use buildings take a weighted average. The page says the CaGBC Zero Carbon Building Standard or Passive House certification is an accepted alternative route, with the approach agreed in advance with the City’s Environment and Energy Division.

Tiers 2 and 3 and the development charge refund

The voluntary tiers are where the City still pays for performance. The Development Charge Refund Program gives back part of the development charges paid by projects verified at Tier 2 or above. Under Version 4, every Tier 2 or Tier 3 measure is core and third-party verified, on top of Tier 1. The staff report says the high-performance standards for the program are unchanged by Bill 98, so plan on the evaluator looking for the Tier 1 measures that are now voluntary at site plan, energy included, and confirm that with Environmental Planning when you enrol.

How much the refund is

The refund is set by a cap per unit or per square metre in the City’s Tier 2, 3 and 4 cap schedule, effective June 26, 2025, for Version 3 projects and later:

As a worked example, a hypothetical 100-unit apartment building with 60 one-bedroom and 40 two-bedroom units would be capped at $430,414.60 at Tier 2 (60 × $3,627.77 plus 40 × $5,318.71) and $516,497.00 at Tier 3. The City calculates the refund at the cap in effect on the day it processes the refund, and the program page notes the caps can change when the development charges by-law changes. With Toronto’s residential DC reductions still pending, carry the refund in your pro forma at the current cap and treat it as a future receipt, not as money you’ll have during construction. Our article on hard costs vs soft costs explains how DC timing works.

How the program works

1. Tell the City early. Mark Tier 2 or 3 on the TGS checklist with your application and speak to the community planner and the Environmental Planning office (sustainablecity@toronto.ca).
2. Meet Tier 1 at site plan. Tier 1 is verified through site plan approval, so the application has to show all of it.
3. Enrol before NOAC. Submit the High Performance Checklist and the refund application and estimate forms before the City issues the Notice of Approval Conditions. Enrolment is valid for one year from the NOAC: if the DCs aren’t paid and the building permit isn’t issued within that year, the application lapses.
4. Hire a registered evaluator by 50% construction documents. The City keeps a list of third-party evaluators, paid by the owner, who must declare no conflict of interest.
5. Two-stage verification. The evaluator reviews the construction drawings at about 50% and inspects at occupancy.
6. File the verification report. The program page gives the deadline as five years from the first above-grade building permit in one place and five years from when DCs were payable in another, so confirm which applies to your file. The City prefers it within three to six months of occupancy. The refund is paid after the City accepts it.

If you will pay development charges in instalments, which rental buildings can under the Development Charges Act, tell Environmental Planning so the refunds can be scheduled against the instalments.

The refund grows with unit count; the evaluator and modelling fees don’t grow the same way. Whether the higher-performance design pays is a question for your pro forma, with the energy modeller and cost consultant in the room early in design.

The documents, who prepares them and when they’re due

The TGS checklist is part of a complete application. It is not a separate approval. Every resubmission carries an updated checklist and statistics. What the interim checklist asks for:

Sources: the interim checklist and the checklists and templates page. The energy page says an Energy Modelling Report is required for new private buildings over 2,000 m² where the site plan application was received before June 2, 2026; for applications after that date the checklist marks it voluntary.

Files usually slow down over paperwork rather than a missing measure: a checklist that points to plan numbers changed two submissions ago, or statistics that no longer match the drawings. Write ownership of the checklist into the planner’s or architect’s scope rather than assuming it.

Planning and budgeting for the Toronto Green Standard

We won’t give you a TGS cost premium. We know of no current public study of what Tier 1 costs under the interim checklist; the City’s costing work dates from its 2017 Zero Emissions Buildings Framework, before Version 4. Here is where the money goes, so your cost consultant can price it for your building.

What drives the cost of Tier 1

• Soil volume for trees. Thirty cubic metres per tree is a lot of soil. Over a below-grade garage it means deeper planters, soil cells under paving, or garage walls pulled back from the lot line, which can cost parking. Settle it at massing stage, when it’s a drawing change and not a structural one.
• Bird-friendly glazing. Treating 85% of the glazing in the first 16 m adds a fritted, patterned or film-applied glass line to the curtain wall or window package. The cost depends on how much glass the lower floors have and which treatment the architect chooses.
• Stormwater. The Wet Weather Flow targets usually mean a cistern or tank, and on tight urban sites that competes with parking and mechanical space below grade. With green roofs no longer required, the civil engineer may need to find the retention somewhere else, so ask early whether the roof was doing part of that job in your design.
• Area that isn’t sellable or rentable. Bicycle rooms, shower and change rooms, waste rooms, the compactor room and 10 m² for bulky items all take floor area. That’s usually the larger cost, and it lands in the pro forma as lost revenue, not as a construction line.
• Consultant fees. A landscape architect, a civil engineer and an architect who knows the bird-friendly specification are needed anyway. The energy modeller is now optional for Tier 1, but see the next section before you cut the line.

Keep the energy model in the budget if you’re financing through CMHC

CMHC’s MLI Select awards new construction 20, 35 or 50 points for energy performance at least 25%, 50% or 60% better than the 2020 National Energy Code for Buildings (or 20%, 40% or 70% better than the 2020 National Building Code), proven by a qualified professional’s energy simulation. CMHC says it won’t accept modelling against local codes. Those points move amortization and premiums, and our article on construction financing in Ontario covers how. If your lender will want an energy model, the same modeller can tell you how far you are from the TGS tiers.

What to commission, and when

1. Before you buy or at feasibility: confirm whether the project will go through site plan, and which TGS version and checklist apply. If it needs a rezoning first, remember the checklist goes in with that too.
2. At massing: test tree soil volume, the stormwater approach and below-grade space together, with the civil engineer and landscape architect. Decide whether you’ll pursue Tier 2 or 3, and whether your lender needs an energy model.
3. At pre-application consultation: bring a draft checklist and ask the planner how the interim measures will be handled on your file.
4. At first submission: file a complete checklist and statistics template with every plan number filled in.
5. Before NOAC: if you’re pursuing the refund, enrol and submit the High Performance Checklist.
6. By 50% construction documents: retain the third-party evaluator if you’re in the refund program.
7. At occupancy: evaluator’s site inspection, then the verification report within five years of the first above-grade permit.

Frequently asked questions

Is the Toronto Green Standard a bylaw?

No. It’s a City standard applied through planning approvals: site plan control, rezoning and plans of subdivision. Tier 1 has to be met for site plan approval, so in practice it binds any project that needs one. The Green Roof By-law was separate, and the City says it is no longer in effect since the Province removed its authority on November 3, 2025.

When did the Toronto Green Standard start?

The City first introduced it as a voluntary standard in 2006. In 2010 it became two tiers, with Tier 1 mandatory and Tier 2 a voluntary stretch target with financial incentives. Version 2 followed in 2014, Version 3 on May 1, 2018 and Version 4 on May 1, 2022. The City says it has been applied to over 4,000 developments.

What’s the difference between Tier 1 and Tier 2?

Tier 1 is the mandatory minimum, checked at site plan approval, and since June 2026 it covers fewer measures. Tier 2 is a voluntary higher-performance level: lower energy and emissions targets, embodied carbon limits and more, verified by a registered third-party evaluator during design and at occupancy. Tier 2 and Tier 3 projects can apply for a partial development charge refund.

Does it apply to garden or laneway suites?

No. Laneway and garden suites are exempt from site plan control in Toronto, so the TGS checklist isn’t part of their approval. They need a building permit and must meet the Building Code, including its energy efficiency requirements, and the zoning rules for suites.

What to do next

Work through the list above in order, starting with whether your project goes through site plan at all. The two decisions that cost most when they come late are the below-grade layout (soil, stormwater and parking together) and whether to pursue Tier 2. And because the City has said more changes are coming, ask the planner on your file how the interim measures will be treated before each submission.

Our experience was built at PCL Constructors and Oxford Properties, over 20+ years and $3B+ of delivered work. Planners, architects and engineers prepare the TGS submission; we keep that consultant team, the budget and the approvals schedule working together, so the TGS measures are in the design before the first submission goes in. If you’re taking a Toronto site through approvals, our development management service is where to start.