Ontario Fire Code: what your doors actually require

What the Ontario Fire Code is

The Ontario Fire Code is O. Reg. 213/07, made under the Fire Protection and Prevention Act, 1997. It governs how existing buildings must be maintained and operated for fire safety — as distinct from the Ontario Building Code, which governs how buildings are designed and constructed.

That distinction matters. A building can have been built entirely to code and still be in breach of the Fire Code years later, because doors have been modified, closers have failed, labels have been painted over or hold-opens have been fitted.

The Fire Code is enforced locally by municipal fire departments. In practice that means a fire prevention officer from Toronto Fire Services, Hamilton Fire Department, Mississauga Fire or whichever service covers your building. Enforcement culture varies between them.

One definition is worth having in front of you, because it sets what an inspection actually is. The Code defines inspection as a “physical examination to determine that the device or system will apparently perform in accordance with its intended function.” Somebody has to go and look at the door.

Every door duty in the Code

There are seven. This is the complete set — no other provision anywhere in the Fire Code sets a frequency for a door.

• Article 2.2.3.4(4) — a door in a fire separation is inspected monthly. Long-standing.
• Article 2.2.3.4(1) and (2) — a door in a fire separation is kept closed when not in use, and checked as frequently as necessary to confirm it stays closed. Long-standing.
• Article 2.2.3.4(5) — the door opening and the area around it are kept clear of anything that would obstruct or interfere with the free operation of the door. Long-standing.
• Article 2.2.3.5 — fire dampers and fire stop flaps are inspected annually, or on an approved schedule. Long-standing.
• Article 2.7.2.3(1) — every door forming part of a means of egress is checked at intervals not greater than one month to confirm it is operable. New on 1 January 2026.
• Article 2.7.2.3(2), (3) and (4) — revolving door safety features, sliding doors required to swing on their vertical axes in the direction of egress, and electromagnetic locks are each tested at intervals not greater than 12 months. New on 1 January 2026.
• Article 2.7.2.4 — records of those three 12-month tests are made and retained. New on 1 January 2026.

Note the verbs. The Code treats checking, inspection and testing as three different things, and the distinction decides what has to be written down. Doors in fire separations are inspected. Egress doors are checked. Mag locks, revolving doors and those sliding doors are tested — and tests are what the Code requires records of.

What actually changed on 1 January 2026

O. Reg. 87/25 amended the Fire Code, with sections 1 to 67 in force from 1 January 2026. For doors, the substance is section 18 of the amendment, which inserted Articles 2.7.2.3 and 2.7.2.4 — the egress door, revolving door, sliding door and electromagnetic lock duties listed above.

Sections 10 and 11 also struck the words “in fire separations” from Articles 2.2.3.2(1) and 2.2.3.3. Those are the duties to keep closures maintained and operable, and unobstructed and not wedged open. Removing that qualifier widens both beyond fire separations to closures generally. Section 12 added Subsection 2.2.4, on damaged or removed encapsulation materials in mass timber construction.

Electromagnetic locks

This is the change most likely to catch a secured building, because almost every commercial building in the GTA has mag locks and almost nobody is testing them on a 12-month cycle with a record.

One point is widely misstated, so it is worth being precise. The Fire Code permits an electromagnetic locking device on an access to exit or an exit door only where it is approved or complies with the Building Code — Article 2.7.2.2(2). The release behaviour is set by that approval, not by the Fire Code. What the Fire Code requires of you is that the lock be tested on a 12-month cycle and the result recorded. A lock that no longer does what it was approved to do is both a hazard and a failed test.

That same Article prohibits electromagnetic locking devices outright in two places: on a door in an elementary or secondary school, and on an egress or exit door serving a high-hazard industrial occupancy.

What did not change: monthly inspection

A great deal of commentary published in early 2026 — including, for a time, our own — said that O. Reg. 87/25 moved fire door inspection from annual to monthly. It did not.

The monthly duty sits at Division B, Article 2.2.3.4(4), and it reads, in full:

A door in a fire separation shall be inspected monthly.

O. Reg. 87/25 does not amend Article 2.2.3.4. The requirement predates it. If a contractor or consultant tells you this is a new 2026 obligation, they have read a summary rather than the regulation.

There is no exemption from it. Article 2.2.3.4(3) does provide exceptions — for a door designed to close automatically in a fire emergency, and for a door covered by an approved fire safety plan — but read what they exempt. They apply to sentences (1) and (2), the duties to keep the door closed and check that it stays closed. They do not reach sentence (4). Every door in a fire separation is inspected monthly, without exception.

Undocumented compliance is unprovable compliance

Most of this industry, ourselves included until recently, states the record requirement incorrectly. Here is what the Code actually says.

The Fire Code does not require you to keep a record of the monthly fire door inspection. Article 1.1.2.1 requires records where the Code requires tests, corrective measures or operational procedures. Inspection records are mandatory only in a supported group living residence or an intensive support residence. Records of the 12-month tests at Article 2.7.2.3 are required, by Article 2.7.2.4 — but the monthly door inspection itself carries no express record duty in an ordinary commercial building.

Where records are required, Article 1.1.2.2 sets the retention: at least two years, with at least the most recent and the immediately preceding record kept at the building. Electronic records that can be produced for the Chief Fire Official on request are expressly deemed to comply. Initial verification reports for fire protection systems installed after 21 November 2007 are kept for the life of the system.

That is the law. The practical reality points the other way, and it is the reason we keep records on every visit regardless.

If a fire prevention officer asks whether your fire doors were inspected last month, an undocumented inspection is indistinguishable from one that never happened. Your approved fire safety plan may require the record in its own terms. Your insurer will ask for it after a loss. And if a door fails in a fire, nobody will be asking whether the Code compelled a record — they will be asking what you can produce.

A defensible record should show, for each door:

• A unique identifier for the opening, so the record refers to a specific door
• The date of inspection and who carried it out
• What was checked and what was found
• Photographic evidence of any deficiency
• What corrective action was taken, and when
• A retained history, so the pattern over time is visible

Confirm with your local fire service what they expect to see — practice varies, and your fire prevention officer will tell you directly if you ask.