What Ontario Regulation 87/25 changed on 1 January 2026

O. Reg. 87/25 came into force on 1 January 2026 and did change the rules for doors — just not the rule most people think. If you own or manage a commercial building in Ontario, there are new obligations to pick up, and one very old one that a lot of buildings have never met.

This is a plain-language explanation of what changed, what did not, who it applies to, and what a sensible response looks like. It is general information rather than legal advice, and your local fire prevention officer is the authority on what applies to your specific building.

What 87/25 actually added

Ontario Regulation 87/25 amended the Ontario Fire Code — O. Reg. 213/07, made under the Fire Protection and Prevention Act, 1997 — with sections 1 to 67 coming into force on 1 January 2026.

For doors, the substance sits in one place: section 18 of the amendment, which inserted two new Articles into Subsection 2.7.2.

Article 2.7.2.3 — egress doors, revolving doors, sliding doors and electromagnetic locks

Four new duties, all of them genuinely new as of 1 January 2026:

• Every door forming part of a means of egress is checked at intervals not greater than one month, to confirm it is operable.
• Revolving door safety features are tested at intervals not greater than 12 months.
• Sliding doors required to swing on their vertical axes in the direction of egress are tested at intervals not greater than 12 months.
• Electromagnetic locks are tested at intervals not greater than 12 months.

Note the verbs. Egress doors are checked, and what is being confirmed is that the door is operable. The other three are tested. The Code treats checking, inspection and testing as three different things, and the distinction decides what has to be written down.

Article 2.7.2.4 — records of those tests

Records of the tests required by Article 2.7.2.3 sentences (2), (3) and (4) — revolving doors, those sliding doors, and electromagnetic locks — must be made and retained. Under Article 1.1.2.2 they stay at the building for at least two years, with at least the most recent and the immediately preceding record kept. Electronic records that can be produced for the Chief Fire Official on request are expressly deemed to comply.

On electromagnetic locks specifically

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 worth getting right, because it is widely misstated. 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.

The same Article also 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 changed in Section 2.2

Less than people assume, and not what they assume. Sections 10 and 11 of the amendment 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 to keep them unobstructed and not wedged open. Removing that qualifier widens both duties beyond fire separations to closures generally.

Section 12 added a new Subsection 2.2.4 covering damaged or removed encapsulation materials in mass timber construction.

Beyond doors, 87/25 is a substantial amendment covering National Fire Code harmonisation for flammable liquids, dangerous goods, aerosols and combustible dusts, carbon monoxide alarms, integrated life safety systems testing, and boarding, lodging and rooming houses.

What did not change: monthly fire door inspection

This is the part we got wrong, and it is worth stating plainly because a great deal of commentary published in early 2026 made the same mistake.

A door in a fire separation must be inspected monthly. That requirement sits at Division B, Article 2.2.3.4(4) of the Fire Code, 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 monthly duty predates it. If a contractor or a consultant tells you this is a new 2026 obligation, they have read a summary rather than the regulation.

Two details matter more than the date.

It applies whether or not the door is in regular use. A fire door on an electrical room nobody opens from one month to the next carries the same obligation as a busy corridor door. This catches people out, because the doors nobody uses are exactly the doors nobody looks at.

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 to check that it stays closed. They do not reach sentence (4). Every door in a fire separation is inspected monthly, without exception.

One neighbouring article is worth knowing, because it is the source of most confusion: Article 2.2.3.5 puts fire dampers and fire stop flaps on an annual cycle, or an approved schedule. Doors are monthly; dampers are annual. Anyone who tells you fire doors are an annual item has run two adjacent articles together.

We set out the full picture, article by article, in our plain-language guide to the Ontario Fire Code.

Who this applies to

The Fire Code places obligations on the “owner”, and defines that term more broadly than most people expect. Division A, Article 1.4.1.2 defines an owner as:

any person, firm or corporation having control over any portion of the building or property under consideration and includes the persons in the building or property.

Article 1.2.1.1 then states that, unless otherwise specified, the owner is responsible for carrying out the provisions of the Code.

“Control over any portion” is the operative phrase. It is not limited to the registered titleholder. In practice responsibility usually sits with whoever controls building maintenance — in a managed office building that is the property manager, and in a triple-net lease it may well be the tenant.

If your lease is ambiguous on this point, the time to resolve it is now. The worst moment to discover that nobody was clear on who inspects the fire doors is when a fire prevention officer asks to see the records.

Records: less than the Code demands, more than you can afford to skip

Here is something most people in this industry state incorrectly, ourselves included until recently.

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 new 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 for an ordinary commercial building.

That is the law. Here is the practical reality, which points the other way.

If a Chief Fire Official 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.

So keep one anyway. A defensible record should show, for each door: a unique identifier for that opening, 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, and a retained history so the pattern over time is visible.

Can building staff do the monthly inspection?

This is the question we are asked most often, and the honest answer is more permissive than you might expect.

The Fire Code does not require a licensed or certified inspector for this work. Ontario does not license fire door inspectors at all — there is no provincial credential for it. The Code places the duty on the owner, and Division C provides that tests for compliance are carried out by the owner or the owner’s agent. Your staff can do it.

Which makes the real question a practical one rather than a legal one: can the person doing it recognise a failure when they are looking at it? A door that closes and latches can still be non-compliant — a painted-over label, a substituted hinge that is not listed for the assembly, a gap at the meeting stile that is out of tolerance, a closer that no longer brings the door to a latched position from a small opening angle. None of that is obvious to someone who has not been shown what to look for.

Many buildings use trained in-house staff for the routine monthly check and bring in an external inspector for a detailed annual assessment. That is a sensible arrangement. Confirm it with your fire prevention officer before relying on it rather than after — practice varies between fire services, and Toronto, Hamilton and the Halton municipalities do not all approach it identically.

What a sensible response looks like

Count the doors. Most buildings genuinely do not know how many fire separation doors they have. You cannot schedule an obligation you have not quantified. This is a walk-through, not a project.

Establish a baseline. A first full fire door inspection tells you the condition of the stock. Expect a long deficiency list — that is normal for a building that has never been formally assessed, and it is not evidence that something has gone badly wrong.

Correct the genuine failures. Separate code failures from wear and cosmetic issues, and deal with the first group. Most failures are minor: a misaligned strike, a tired closer, a painted label, a missing seal. Few require a new door.

Put the recurring schedule in place. Monthly for doors in fire separations, monthly operability checks on egress doors, and a 12-month cycle for mag locks, revolving doors and those sliding doors — with records captured for the tests. Build it into the maintenance calendar rather than reacting when an inspector arrives.

If you are already behind

Most buildings we look at are. If you are not sure what you have, a door contractor who works to the Code can walk the building and count the openings before anything is committed. Fire services generally respond well to owners who have identified the gap and are demonstrably working through it. Having a baseline inspection and a dated remediation plan puts you in a materially better position than having nothing at all.

Both regulations are published on Ontario’s e-Laws site — the Fire Code as O. Reg. 213/07, and the amendment as O. Reg. 87/25. We would encourage you to read the articles that apply to your building rather than take anyone’s summary at face value, including ours. That is, after all, how the error at the top of this page came to be corrected.

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This article is general information, not legal advice. Fire Code obligations depend on your building, its classification and its use. Your local fire prevention officer is the authority on what applies to you.