Fire Safety Plans in Ontario: What Businesses and Property Managers Must Have in 2026

If you manage a commercial building, operate a business with employees, or own a multi-residential property in Ontario, there is a good chance you are legally required to have a Fire Safety Plan. Yet fire safety plans remain one of the most commonly misunderstood and neglected fire protection obligations in the province — not because building owners don't care about safety, but because the requirements are rarely explained clearly.

This guide breaks down exactly what the Ontario Fire Code requires when it comes to fire safety plans, who needs one, what it must contain, what changed in 2026, and what happens if you don't have one when a fire prevention officer comes knocking.

What Is a Fire Safety Plan?

A Fire Safety Plan is a formal, written document that describes how a building's occupants and management will respond in the event of a fire or other emergency. It is not a general evacuation poster or a rough set of instructions — it is a structured, code-compliant document that outlines specific procedures, identifies responsible individuals, and provides detailed information about the building's fire protection systems.

Under the Ontario Fire Code, a Fire Safety Plan is required by law for many buildings across the province. The requirement is found in Division B, Section 2.8 of the Ontario Fire Code, and it places the responsibility for developing, submitting, implementing, and maintaining the plan squarely on the owner of the building.

The Ontario Fire Code defines "owner" broadly — it includes any person, firm, or corporation having control over any portion of a building or property. In practical terms, this means that property managers, long-term lessees, and anyone else in a position of care or control over a building can bear the same responsibility as the registered owner.

Who Is Required to Have a Fire Safety Plan in Ontario?

This is where many building owners get caught out — they assume that fire safety plans are only required for large buildings or high-risk facilities. The reality is broader than that. Under the Ontario Fire Code, a Fire Safety Plan is generally required for buildings that contain any of the following:

• Buildings with a required fire alarm system — any building where the OFC mandates a fire alarm system also requires a fire safety plan.
• Buildings with four or more storeys, including storeys below grade, regardless of occupancy type.
• Buildings with vulnerable occupants — care occupancies, retirement homes, long-term care facilities, and any building housing occupants who may need assistance during evacuation.
• Buildings with large occupant loads — assembly occupancies, places of worship, theatres, arenas, and other gathering spaces.
• Buildings with special hazards — storage of flammable liquids, chemicals, combustible dust, aerosols, or other hazardous materials.

If you are unsure whether your building is required to have a fire safety plan, the safest approach is to consult with your local fire department or a qualified fire protection professional. The consequences of not having a required plan are significantly worse than the effort of finding out.

What Must a Fire Safety Plan Include?

The Ontario Fire Code specifies what a fire safety plan must contain. A compliant plan is not simply an evacuation map — it is a comprehensive document that addresses multiple aspects of emergency response and fire safety management.

Emergency Procedures

The plan must describe the specific actions that building occupants and supervisory staff are expected to take in the event of a fire — activating the fire alarm, notifying the fire department, evacuating occupants, and controlling or containing the fire where safe to do so. Procedures must be tailored to the specific building; generic templates that don't reflect actual layout and systems are not compliant.

Designation and Organization of Supervisory Staff

The plan must identify and organize the supervisory staff responsible for carrying out fire safety duties — naming specific roles such as floor wardens, evacuation coordinators, and fire safety directors, and describing their responsibilities during an emergency.

Staff Training Requirements

The plan must address how supervisory staff will be trained for their roles. Training must be provided to all designated staff, and the plan must describe the nature and frequency of that training. Records of training must be kept and made available to the fire department on request.

Fire Drill Procedures and Schedule

The OFC requires fire drills for supervisory staff, and the plan must describe how those drills will be conducted and how often. Under the 2026 updates, fire departments are now looking for evidence that drills have meaningful objectives, that supervisory staff genuinely understand their roles, and that records demonstrate drills were carried out in accordance with the plan. Simply having a drill occur is no longer sufficient.

Description of Fire Protection Systems

The plan must include a description of the fire protection systems installed in the building — fire alarms, sprinklers, suppression systems, emergency lighting, and any other relevant systems — to help emergency responders understand the building's capabilities on arrival.

Maintenance, Inspection Records, and Hazard Information

The plan must reference the maintenance and inspection requirements for the building's fire protection systems, with records kept on site and available to the fire department at any time. Where applicable, it must also address building-specific hazards — flammable storage, restricted-access areas, hazardous equipment, and any other factors that affect emergency response.

What Changed in 2026

The Ontario Fire Code changes that came into effect on January 1, 2026 under Ontario Regulation 87/25 introduced several updates that directly affect fire safety plans.

• Updated fire alarm inspection requirements — adoption of CAN/ULC-S536:2019 and CAN/ULC-S537:2019 means plans referencing the old standards must be updated.
• Integrated systems testing obligations — buildings with systems installed or modified on or after January 1, 2020 that required CAN/ULC-S1001 verification now have a retroactive obligation to ensure integrated testing has been completed and documented.
• Strengthened drill documentation requirements — greater emphasis on documented, meaningful drills with clear objectives, participation, and recordkeeping.
• Expanded CO alarm requirements under Section 2.16 may require updates for multi-residential buildings with fuel-burning appliances, attached garages, or common areas where CO detection is now required.
• Administrative Monetary Penalties under Ontario Regulation 260/25 give fire departments authority to issue on-the-spot fines — an outdated or missing plan is now a direct financial risk.

Common Fire Safety Plan Problems Found During Inspections

• The plan is outdated — building changes, tenant changes, new fire protection systems, and code updates have rendered it non-compliant.
• The plan is generic — it could apply to any building and is not specific to actual layout, systems, occupancy, and hazards.
• Staff don't know the plan exists — it sits in a filing cabinet and has never been shared, trained on, or drilled.
• The plan has not been submitted to and approved by the local AHJ where required.
• Records are not on site — the plan and supporting drill logs, inspection reports, and training records must be kept at the building premises and immediately accessible.

Who Is Responsible for Developing a Fire Safety Plan?

The Ontario Fire Code places responsibility for the fire safety plan on the owner. In buildings with multiple tenants or complex management structures this can create ambiguity — but the Code is clear that someone must be accountable, and the owner bears ultimate responsibility.

In practice, fire safety plans are often developed by qualified fire protection professionals on behalf of building owners. This ensures the plan is code-compliant, building-specific, and defensible in the event of an inspection or an incident. For larger or more complex buildings, professional development is strongly recommended.

Consequences of Not Having a Compliant Fire Safety Plan

• Compliance orders — a fire prevention officer who finds a missing or non-compliant plan will issue a legally binding order to develop or update it within a specified timeframe.
• Administrative Monetary Penalties — fire departments can now issue on-the-spot fines for fire safety plan deficiencies under the 2026 AMP framework.
• Fines under the FPPA — for serious violations or non-compliance with a compliance order, fines can reach $50,000 for individuals and $500,000 for corporations.
• Insurance implications — after a fire, an investigation that reveals a non-compliant plan or untrained staff can significantly affect coverage and expose the owner to liability.

Keeping Your Fire Safety Plan Current

A fire safety plan is not a one-time document. At a minimum, your plan should be reviewed and updated annually as standard practice, whenever significant changes are made to the building's layout or occupancy, whenever fire protection systems are installed or modified, whenever supervisory staff or their responsibilities change, and whenever the Ontario Fire Code is updated with requirements that affect your building.

Keeping the plan current, keeping staff trained, and keeping records organized are the three things that will ensure your building passes a fire inspection and — more importantly — that your building is actually prepared in the event of an emergency.

First National Fire Protection: Fire Safety Plan Development and Review

We develop, review, and update Fire Safety Plans for commercial buildings, multi-residential properties, institutional facilities, and industrial operations across Toronto, the GTA, and Ontario. Our CFAA-certified team understands the 2026 Ontario Fire Code requirements and ensures every plan is building-specific, code-compliant, and ready for AHJ submission. Call 1-844-TEL-FIRE (835-3473) or locally at 416-591-1393 for a free consultation.