Publications, opinions, and speeches


Submission to the Government of Ontario regarding proposed amendments to O. Reg. 367/11 under the Housing Services Act, 2011

Published on 22/02/2022

Download the submission (PDF)

This submission provides Maytree’s insights and analysis to the Ontario Ministry of Municipal Affairs and Housing regarding proposed amendments to O. Reg. 367/11 under the Housing Services Act, 2011 (HSA).

The proposed regulatory amendments under the HSA are intended to operationalize legislative changes focused on establishing a new Service Agreement framework between service managers and housing providers, changing service level requirements to include other types of housing assistance beyond Rent-Geared-to-Income (RGI) and portable housing benefits, and creating an access system that would act as an inventory of housing assistance.

On the surface, these changes would appear to make the community housing system more streamlined. But in practice, they fail to address supply and affordability challenges. Moreover, the proposed regulatory framework could exacerbate these challenges.

To improve the community housing system, Maytree encourages the Ontario government to consider the following recommendations in its development of the regulatory amendments:

  1. Work closely with service managers and housing providers in the implementation of Service Agreements, keeping the needs of tenants at the forefront of decisions.
  2. Protect the supply of deeply affordable housing provided through RGI and maintain priority systems to ensure that those with the greatest housing needs are served.
  3. Take a more holistic approach to government programs and services related to housing affordability and income security.

We also recommend that the Ontario government uses rights-based principles to develop its approach, recognizing that the human right to adequate housing is a fundamental human right affirmed in Canada’s National Housing Strategy Act. The progressive realization of this right will depend on coordinated responses by all levels of government. The use of rights-based principles in informing policy and regulatory changes ensures that the dignity of people is at the centre of decision-making.

This aligns with the purported spirit of the HSA legislation — it is now time that proposed regulatory amendments match this spirit.

Download the submission (PDF)


Evidence-based policy, Housing and homelessness, Human rights


As the Ontario government makes changes to the community housing system, Maytree has three recommendations for consideration, including keeping tenants’ needs top of mind.