Submission to the Ontario Building Code Short-Term Advisory Body

In August 2026, March of Dimes Canada responded to an open consultation launched by the Ontario Building Code Short-Term Advisory Body for their study on the Ontario Building Code. 

We shared the following insights and recommendations based on our based on our expertise in providing accessibility services and attendant services to people with disabilities across Canada, deeply informed by the lived experience of our service users. 

August 2026 

Plain Language Summary 


March of Dimes Canada (MODC) supports keeping and strengthening accessibility rules in Ontario's Building Code. MODC works with people with disabilities, seniors, families, and caregivers across Canada. Based on this experience, MODC believes homes should be built to be more accessible from the start, so people do not need expensive renovations later. 
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Why Accessible Housing Is Important 


There is not enough accessible and affordable housing in Ontario and across Canada. Many people with disabilities and seniors live in homes that do not meet their needs. Some people cannot safely use important parts of their homes, such as bathrooms or kitchens. 

When people do not have the right housing, their health and well-being can suffer. They may lose their independence, feel isolated, have trouble finding or keeping work, or face homelessness. Some people end up in hospitals or long-term care homes when they could have stayed in their own homes if the housing had been accessible. 

Building Accessible Homes Saves Money 


MODC has seen that changing homes after they are built can be very expensive. Common changes include widening hallways and doorways, renovating bathrooms, and rebuilding kitchens. 

Research shows it costs much less to include accessibility features when a home is first built. For example: ​
  • Building an "accessible-ready" home adds about $3 per square foot to construction costs. 
  • Homes built this way can reduce future renovation costs by about 57 per cent.
  • For every $1 spent on accessible-ready features during construction, about $7 can be saved on future renovations. 

Ontario Should Follow National Accessibility Standards 


MODC recommends that Ontario update its Building Code to match newer national accessibility standards, including: 
  • The 2025 National Model Codes 
  • CSA B652:23, Canada's standard for accessible homes 
  • The Accessible-Ready Housing (ARH) Standard 
​The ARH Standard helps builders create homes that can be easily and affordably adapted as people's needs change over time. This allows people to stay in their homes longer as they age or if they develop a disability. 

Benefits of Using National Standards 


Matching Ontario's Building Code with national standards would: 
  • Increase the number of accessible homes. 
  • Help people stay independent and live in their communities longer. 
  • Reduce future renovation costs. 
  • Lower pressure on hospitals and long-term care homes. 
  • Make it easier for builders, architects, and manufacturers to work across Canada using the same standards. 
  • Support new building methods, such as modular and prefabricated housing. 
  • Encourage more training and expertise in accessible housing design and construction. 

Conclusion 


MODC believes Ontario has an opportunity to increase the supply of accessible housing by adopting national accessibility standards and requiring more accessible-ready features in new homes. Building homes that can adapt to people's changing needs will improve quality of life, help people stay independent, and save money over the long term for families and governments. 


​Introduction 


March of Dimes Canada (MODC) is pleased to present this submission to the Building Code Short-Term Advisory Body. As a national leader, ally, and trusted service provider supporting people with disabilities, their families, caregivers, and communities, MODC brings front-line experience and system-level insight into the critical need for accessible, affordable, and inclusive housing in Ontario, and across the country. We understand the Advisory Body’s task is to consider whether unnecessary burden can be reduced while maintaining or improving the safety and quality of buildings in Ontario. We welcome the Advisory Body’s commitment to maintain (and ideally strengthen) the building code’s core purposes, including the foundational objective of accessibility. 

In preparing this submission, MODC has engaged with and listened to the priorities and lived and living experiences of the people and communities we serve, as well as our broader network of stakeholders. MODC and our service users are directly impacted by the Ontario Building Code (OBC) through the Code’s building accessibility requirements.   

For over 20 years, MODC has administered the Home and Vehicle Modification Program in Ontario, first on behalf of the Ministry of Children, Community and Social Services, and now on behalf of the Ministry of Seniors and Accessibility. Our service users and staff have seen firsthand how important it is that homes be built in easily adaptable ways for people with disabilities and seniors to meet their needs change as they age. Too often, we have seen our service users forced to pay for costly structural changes to their homes (such as widening hallways, comprehensive bathroom conversions, and kitchen rebuilds) to meet their access needs. By prioritizing adaptable, accessible home construction, we can ensure more people can remain independent in their homes and communities and out of long-term care and hospital when they do not need to be there. 

How the lack of accessible housing affects people with disabilities in Canada 


The lack of accessible and affordable housing has far-reaching impacts across society, extending well beyond housing itself. When people cannot access the right housing and supports at the right time, their health and well-being often decline. Many end up in crisis, relying on emergency healthcare services, experiencing homelessness, or, in the most severe cases, facing premature death. Access to appropriate housing is a key social determinant of health, and without it, outcomes across physical and mental health worsen significantly. 

Housing is a foundational need that underpins participation in all aspects of daily life. Without stable, suitable housing, it is extremely difficult for individuals to pursue education, maintain employment, or engage in their communities. In this way, housing acts as a gateway to broader social and economic inclusion; when it is lacking, exclusion is compounded. 

The lack of accessible housing has significant and deeply personal impacts on the people we support, our communities, and our broader systems of care. Many individuals are forced to live in inadequate or unsafe conditions where they cannot fully access essential areas of their home, such as bathrooms or kitchens. This directly affects their health and dignity. For example, the absence of an accessible shower may result in someone receiving a sponge bath in bed, a level of care that falls below what they need and deserve. These circumstances often contribute to worsening health conditions and a diminished quality of life. 

The financial burden of retrofitting homes to meet accessibility needs is also significant, often far exceeding the cost of building accessible housing from the outset. At the same time, individuals must navigate complex and inconsistent funding systems to access supports, which vary widely across jurisdictions. 

Overall, the lack of accessible and affordable housing leads to loss of independence, poorer health outcomes, increased poverty and homelessness, and reduced participation in community life. It also drives systems to operate reactively, spending more on healthcare, shelters, and crisis interventions, rather than investing proactively in inclusive housing solutions that prevent these outcomes. 

Advances in accessibility standards Ontario should emulate 


Ontario has a prime opportunity to improve the availability of accessible and adaptable housing in the province by aligning OBC requirements to the National Model Codes and ASC Accessible Ready Housing Standard.  

During the 2025 code development cycle, the Canadian Board for Harmonized Construction Codes (CBHCC) made significant progress in advancing accessibility within Canada’s building codes. These changes reflect an important commitment to ensuring that homes and buildings are designed to be more accessible, inclusive, and adaptable for people of all ages and abilities, while establishing harmonized minimum standards that can be implemented across the country. 

The 2025 edition of the National Model Codes is significant. It contains updates to the framework that guides building design, construction, alteration, and safety across Canada. Notable updates include expanded accessibility objectives that apply to all types of dwelling units, such as adaptable and visitable featuresi. These changes signal a move toward a more unified and forward-looking model code system that supports more accessible housing and building environments. 

These changes represent an important step toward creating homes that are easier to access, use, and adapt throughout a person's life. By incorporating accessibility features during construction, they reduce the need for costly and disruptive renovations later. They also support aging in place, promote greater independence, and help ensure that Canadians can remain in their homes and communities as their mobility and accessibility needs evolve.  

The 2030 code development cycle is currently underway, and the CBHCC is building on the work undertaken in the previous code cycle related to accessibility. As governments consider future accessibility standards, these measures demonstrate that practical, cost-effective accessibility features can be integrated into housing from the outset, delivering long-term benefits for individuals, families, communities, and the broader housing system. 

Canada has also shown leadership federally in accessibility by developing two landmark standards: 
  • CSA B652:23 or Canada’s Standards for Accessible Dwellings has emerged as a nationally recognized benchmark for accessible residential design. Developed by the Canadian Standards Association (CSA), this voluntary standard outlines technical specifications for building homes that meet a wide range of physical, sensory, and cognitive accessibility needs.

  • The Accessible-Ready Housing (ARH) Standard was developed by Accessibility Standards Canada and approved as a National Standard of Canada. It establishes a framework for designing and constructing homes that are “accessible-ready” at the time they are built. They can be adapted easily and affordably over time to meet the evolving accessibility needs of residents. Rather than requiring all accessibility features at the point of construction, the standard includes specific design elements and reinforcements that reduce physical and financial barriers to future modifications. This Design for Accessible-Ready (DAR) approach anticipates changes of the lifespan and aligns with universal design principles.  

The ARH Standard was created with extensive input from the disability community and grounded in international best practices and promotes independent living. It has been approved as a National Standard of Canada by the Standards Council of Canada (SCC)ii. This recognition means that the standard meets SCC’s rigorous standards development requirements. This includes a full public review and alignment with international best practices. 

Recent Canadian research on the ARH Standard further strengthens the economic case for integrating accessibility at the point of construction. A 2026 costing analysis conducted for Accessibility Standards Canada found that incorporating accessible-ready features adds an average of approximately $3 per square foot to new construction costs, well within the typical margin of error for residential construction estimatesiii.  

The long-term savings are substantial. The study found that when accessibility needs arise, homes built to the ARH Standard reduce retrofit costs by an average of 57 per cent compared to homes built to standard building code requirements. In practical terms, this represents thousands to over $100,000 in avoided renovation costs per unit, depending on housing type. The return on this upfront investment is significant. The analysis estimates that every dollar invested in accessible-ready construction yields approximately seven dollars in avoided future retrofit costs, a return of roughly 700 per cent.iv 

Rather than being overly technical and prescriptive, the ARH Standard provides designers and builders a flexible approach for designing for accessibility and adaptability. The overall practical, flexible approach to the standard enables builders to design and build either adaptable or accessible homes depending on the specific and potential future needs of residents. This approach to accessible design, combined with long-term cost savings makes a strong case for aligning the OBC with the ARH and national model codes to increase the availability of accessible housing in Ontario, improve efficiency and reduce costs to builders and Ontarians.  

Other benefits to alignment with national approaches 


Ontario and other Canadian jurisdictions have a prime opportunity to leverage innovation in construction, including prefabricated, modular, and other modern building methods, to rapidly increase the supply of accessible housing designed from the outset with Universal Design in mind. Supporting builders, architects, and contractors through training and incentives will help build sector-wide expertise and reduce costs, ensuring accessibility is not treated as a niche or prohibitively expensive specialization. 

Overall, harmonized building codes and alignment with national standards improve economies of scale by aligning regulatory requirements across different regions, which reduces administrative costs, streamlines material manufacturing, and allows builders to use repeatable designs. The National Housing Catalogue has included multiple accessible and adaptable designs in its 2025 releasev. This lets developers use the same blueprints, materials, and processes across regions without redesigning projects. 

A key benefit of aligning the OBC with national approaches to accessibility and adaptability is the creation of a larger, more consistent market for accessible housing expertise across Canada. When accessibility requirements are harmonized, architects, planners, engineers, builders, manufacturers, and accessibility consultants can work to a common set of standards rather than navigating different requirements in each jurisdiction. This supports labour mobility, facilitates the transfer of technical knowledge and best practices across provincial boundaries, and enables firms to invest in specialized accessibility expertise with confidence that those skills will be relevant in multiple markets. The National Research Council has identified harmonization as an important objective in advancing accessibility requirements across Canada, noting the need for a coordinated national approach and considerations related to industry capacity.vi 

Greater alignment also helps manufacturers and suppliers scale the production of accessible and adaptable housing components, such as wider doors, barrier-free entrances, adaptable kitchens and bathrooms, and other universal design features. A more consistent regulatory environment encourages innovation, training, and product development, while reducing the inefficiencies associated with designing for multiple code regimes. This can improve the availability of both skilled labour and specialized products needed to deliver accessible housing at scale. 

The importance of building industry capacity has been identified not only by governments and code bodies, but by the housing and accessibility sectors themselves. The Accelerating Accessibility Coalition (AAC), a national network of developers, accessibility advocates, researchers, designers, and industry organizations, was established in part to advance the knowledge, learning, and collaboration necessary to significantly increase the supply of accessible housing across Canada. The coalition has emphasized the need for builders and industry leaders to develop the expertise required to deliver accessible homes as part of the millions of new housing units needed in the coming decade.vii 

Similarly, the Accessible Housing Network, representing dozens of Canadian organizations, has advocated for broader adoption of universal design principles and code reforms that would make accessible housing a standard feature of new residential development. Their work reflects a growing consensus that expanding the supply of accessible housing will require a larger pool of professionals, tradespeople, and manufacturers with direct experience in accessibility and adaptable design. Harmonizing requirements across jurisdictions would help cultivate that capacity by creating a common framework for education, training, and implementation nationwide.viii 

As provinces move toward more consistent accessibility requirements, the result is not only improved housing outcomes for people with disabilities and older adults, but also a stronger and more specialized workforce capable of designing, manufacturing, and delivering accessible housing across Canada. 


About March of Dimes Canada 


March of Dimes Canada (MODC) is a leading national charity committed to championing equity, empowering ability, and creating real change that will help people with disabilities across the country unlock the richness of their lives. 

Together with our partners, we serve, connect, and empower people with disabilities to participate fully in life and in their communities on their own terms. Our work is grounded in the voices of the people we serve, built on a foundation of service, and backed by more than 75 years of success. 

We’ve proven time and again our dedication to serving the needs of people with disabilities. Born in one of the 20th century’s greatest public health crises, we know that seemingly impossible goals can be achieved, and barriers can be broken. In the 1950s, MODC helped fund a vaccine for polio. Now, we are working on creating communities in which people with disabilities can live and thrive nationwide. 

We’re proud to support people with disabilities across Canada, from the early years to seniors. Our services extend beyond the individual to families who feel the impact of disability in different ways. Their collective experiences play a critical role in shaping our work as a service provider, resource, and advocate, which is focused in four areas:  ​
  1. The best start for children, youth, and families. 
  2. Independence at home and in the community. 
  3. Active, healthy, connected lives. 
  4. Financial security.  

These are the things people with disabilities told us they need, want, and expect out of life. 

Our staff and volunteers are allies, supporters, and champions committed to making a difference for people with disabilities. With the guidance of our community, and working together with our donors and partners, we provide the tools and support our service users need to live independently, improve their health and wellness, and thrive in all they aspire to do.



i Canadian Board for Harmonized Construction Codes. How the National Model Codes facilitate the construction of more accessible homes and buildings. https://cbhcc-cchcc.ca/en/how-the-national-model-codes-facilitate-the-construction-of-more-accessible-homes-and-buildings/ . 2025.

ii Accessibility Standards Canada. Accessible Standards Canada – About Us. https://accessible.canada.ca/standards-and-technical-guides/standards-and-technical-guides-database/can-asc-282025-accessible-ready-housing. May 2025.

iii Engineers in Motion. Accessible-Ready Housing Standard Costing for New Construction and Retrofit Comparison. April 2026, p.2

iv Ibid p.2.

v Canadian Mortgage and Housing Catalogue. Housing Design Catalogue. https://www.housingcatalogue.cmhc-schl.gc.ca/

vi National Research Council. Policy Paper: Accessibility in Buildings. https://nrc.canada.ca/en/certifications-evaluations-standards/codes-canada/policy-paper-accessibility-buildings

vii Daniels Homes. https://danielshomes.ca/canadas-top-real-estate-development-and-accessibility-leaders-form-coalition-to-create-a-more-accessible-canada/ November 2022 and the Accelerating Accessibility Coalition.  https://toronto.uli.org/getinvolved/the-accelerating-accessibility-coalition/

viii Accessible Housing Network. https://www.accessiblehousingnetwork.org/. 



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