By Dinesh Sharma, Principal Architect OAA, Sharma Office of Design + Architecture Inc. (SODA)

You don’t need to become an expert in building permits or environmental law. But understanding the basics will protect you from some very expensive surprises.

If you’ve started looking at commercial spaces for your childcare centre, you’ve probably heard someone mention “the building code” or “getting a permit.” It sounds bureaucratic — and honestly, parts of it are. But it has a very direct impact on your budget, your timeline, and in some cases, whether a specific space can become a daycare at all.

This article breaks it all down in plain language.

What is the Ontario Building Code?

The Ontario Building Code is the province’s rulebook for how buildings are designed and constructed. It covers everything from wall thickness to exit requirements to ventilation. It exists to keep buildings safe for the people who use them.

When you renovate a commercial space to become a childcare centre, your renovation has to comply with the Building Code. An architect prepares the drawings, the municipality reviews them, and a building permit is issued before construction begins. Once the work is done, an inspector signs off. That final sign-off — called an Occupancy Permit — is what allows you to open.

The short version: You cannot legally open a childcare centre in a renovated space without going through this process. It is not optional.

What triggers a building permit?

Not every change to a space requires a permit. Painting walls or replacing flooring generally don’t. But the following almost always do:

• Changing what the space is used for (converting a retail store into a childcare centre)
• Moving or adding walls — especially load-bearing ones
• Adding or relocating washrooms
• Upgrading the HVAC system beyond basic maintenance
• Modifying exits or adding doors to the exterior

For most childcare operators taking over a new commercial space, at least a few of these will apply. Budget for a permit as a standard part of your project from day one.

What does a permit cost — and how long does it take?

Permit fees in Ontario are typically calculated based on the value of the construction. For a mid-size childcare renovation, expect roughly $2,000 to $8,000 in permit fees, sometimes more depending on the municipality and scope.

Timeline is where people get caught off guard. After submitting a complete permit application, most Ontario municipalities take 8 to 16 weeks to review and approve it. Some are faster. Some are slower. This is before any construction begins.

What this means for you: If you sign a lease and assume you’ll be open in three months, you may be in a very difficult position. Build the permit timeline into your lease negotiations — specifically, try to negotiate a rent-free period that covers the time between signing and opening.

The Record of Site Condition — the requirement most operators don’t see coming

As of October 2025, this is one of the most consistently enforced requirements in Ontario for new childcare projects, and it’s something every prospective operator needs to understand before signing a lease.

What is a Record of Site Condition?

A Record of Site Condition (RSC) is an environmental document filed with Ontario’s Ministry of the Environment, Conservation and Parks (MECP). It confirms that a property has been assessed and is safe for a sensitive use.

Childcare centres are classified as a sensitive use under provincial law — because children are vulnerable people who will spend significant time in that space. When a property changes from a non-sensitive use (retail, office, industrial) to a sensitive use like a daycare, the province requires that the land and building be environmentally cleared before that change is permitted.

The RSC gets registered on the property’s title — permanently. This means it shows up on the landlord’s ownership record.

Why this can stop a project cold

Not every landlord is willing to have something registered on their title. Some refuse outright — and if they do, the childcare project cannot proceed in that space, no matter how otherwise suitable it is.

This is not a negotiation point or a technicality. It is a hard stop.

Ask the landlord about this before you go any further. If they are not willing to allow an RSC on title, the space is not viable for childcare. It is better to find this out before you’ve spent money on architectural drawings or environmental studies.

What does the RSC process involve?

ESA Phase 1 — Environmental Site Assessment The starting point. A qualified environmental consultant researches the history of the property — previous uses, neighbouring properties, known contamination in the area. This is a desktop and visual review; no digging or sampling. Typical cost: $2,000 to $5,000.

ESA Phase 2 — If Phase 1 raises flags If the Phase 1 review identifies potential contamination — for example, if the building previously housed a dry cleaner, auto repair shop, or industrial operation — a Phase 2 may be required. This involves physical testing of soil and potentially groundwater. It costs more and takes longer. Not every site requires this, but it’s a real possibility depending on the property’s history.

Are there exemptions to the RSC requirement?

Yes — but they come with significant conditions. An RSC may not be required if, for example, the childcare centre is located on the second floor or higher of a building that is at least six storeys, the exterior of the building is not being changed, and the space has no history of uses that could cause contamination.

However — and this is important — these exemptions are not something you can simply claim and move on. They require coordination between your architect, the MECP, and the local municipality. Historical research has to be done. Documentation has to be prepared. A formal determination has to be made by the authorities before you can proceed without an RSC.

The exemption is real, but it is not a shortcut. It is a different path through the same process — one that still requires professional guidance and still takes time.

Other studies and approvals that may be required

Depending on where your space is located, additional requirements may come up. These are not universal, but they are common enough that you should know about them before you start spending money on a specific site.

Land Use Compatibility Study If your prospective space is near industrial properties, busy roads, or other uses that generate noise, vibration, or odour, the municipality may require a land use compatibility study. This is done by a professional planner and assesses whether the location is genuinely appropriate for a childcare use. Cost and timeline vary depending on the scope.

Metrolinx Review If your site is near a Metrolinx corridor — a GO rail line, LRT, or other transit infrastructure — Metrolinx may need to review and approve the project independently of the municipal permit process. This adds time to your timeline. If you are looking at a space anywhere near a rail or rapid transit corridor in the GTHA, flag this with your architect early.

Traffic Study In high-traffic areas, or where the childcare centre will generate significant vehicle movement for drop-off and pick-up, the municipality may require a traffic study. The focus is on ensuring children can be safely dropped off and picked up.

None of these are guaranteed requirements for every project — but each one adds cost and time when they do apply.

The three renovation surprises that blow budgets

1. Washrooms Adding or relocating washrooms means moving plumbing — which means opening floors and walls. If the space doesn’t already have washrooms in the right locations, this can add $15,000 to $40,000 or more to your renovation budget. The best-case scenario is a space where plumbing is already close to where you need it.

2. Fire separations If your childcare centre is in a multi-tenant building, provincial code requires that your space be physically separated from the rest of the building in a way that contains a fire for a defined period of time. In older buildings not designed with this in mind, bringing the space up to code can require significant wall work.

3. Accessibility Ontario’s accessibility legislation requires that spaces open to the public meet standards for people with disabilities — accessible entrance doors, barrier-free washrooms, clear paths of travel. If the space doesn’t already meet these standards, bringing it into compliance is part of the renovation scope.

A realistic budget framework

Every project is different. These are rough ranges to frame your thinking — not quotes.

Item	Typical Range
Architect and engineering fees	$30,000 – $45,000+
Building permit fees	$2,000 – $8,000
Environmental studies (ESA Phase 1)	$2,000 – $5,000
ESA Phase 2 (if required)	$5,000 – $20,000+
Land use compatibility / traffic study (if required)	$3,000 – $10,000+
Construction (mid-level finish)	$150 – $250 per sq ft
Contingency (always include this)	10–15% of construction cost
Furnishings and equipment	Varies widely

The only way to get accurate numbers for your specific project is to have an architect review the space and scope the work properly.

What does an architect actually do in all of this?

An architect prepares the drawings required for your permit application, coordinates with structural and mechanical engineers, and acts as your guide through the municipal process. But for a childcare project in Ontario, a good architect also helps you navigate the environmental and planning requirements described above — identifying early which studies are likely required, coordinating with the MECP where needed, and making sure your permit application is complete and accurate before it’s submitted.

Think of the architect as the person who connects all the pieces — the building code, the environmental requirements, the licensing rules, and what you actually want your centre to look like — and translates all of it into a project that can be built and opened.

Where to go from here

If you’re evaluating a space and want to understand what it will actually take to get it open, the best first step is a conversation. At SODA, we work directly with childcare operators through every stage of this process — from initial site review through to permit and construction.

Reach out at sodainc.ca — we’re happy to talk through what you’re looking at.