If you own rental property in St. Thomas, you operate in a different regulatory environment than London landlords just 30 minutes to the north.
The City of St. Thomas does not require a rental housing licence. You don't go through an annual licensing process, pay a per-unit fee, or schedule a licensing inspection every year. That is a meaningful difference from London, where the Rental Housing Licensing program adds a layer of municipal compliance on top of the provincial rules.
But St. Thomas landlords are not off the hook for municipal rules entirely.
The city has its own Property Standards By-law. It sets minimum maintenance and habitability standards for all residential properties in the municipality. It is enforced by Property Standards Officers who have authority to enter your property, issue Orders to Comply, and levy fines. And it operates alongside — not instead of — the provincial Residential Tenancies Act.
This guide covers what the City of St. Thomas property standards require, how enforcement works, how the bylaw intersects with your RTA obligations, and what to do if you receive an Order to Comply.
No Rental Licensing — But Property Standards Still Apply
St. Thomas does not have a Rental Housing Licensing program. This stands in contrast to the City of London, which requires landlords to hold a valid licence for every residential rental unit. If you want to understand how licensing works in London — and confirm that St. Thomas does not follow the same model — the City of London Rental Unit Licence guide explains the London program in full.
In St. Thomas, you do not need to apply for a licence, pay annual fees, or pass an initial city inspection before renting. This removes a significant administrative layer.
What remains is the Property Standards By-law. It applies to every residential property in the city — not just rentals. Owner-occupied homes are subject to the same minimum standards. But for landlords, the bylaw has real enforcement teeth because tenants can trigger an inspection with a single complaint.
What the Property Standards By-law Covers
The City of St. Thomas Property Standards By-law sets minimum conditions for the physical state of residential properties. Here are the main categories.
Structural Condition
- Foundations, walls, floors, ceilings, and roofs must be structurally sound and free from significant deterioration
- Stairs, handrails, balconies, and decks must be secure and in good repair
- Doors and windows must close properly, seal against weather, and function as intended
- Exterior cladding, eavestroughs, and downspouts must be maintained
If you have a unit where a door doesn't close properly, a step is loose, or a window doesn't seal, fix it before a tenant has a reason to complain.
Heating
You must provide heating capable of keeping interior living spaces at a minimum of 21°C during the heating season. The heating season in St. Thomas runs from September 1 through June 15.
Heating is one of the most commonly cited violations at property standards offices across Ontario. If a tenant is cold in November and the heat isn't working, two things can happen at the same time: they file a property standards complaint with the city, and they file a T2 application at the Landlord and Tenant Board for interference with their right to quiet enjoyment. Both processes move independently.
Maintain your heating equipment. Schedule annual inspections of furnaces and boilers before the heating season starts. Keep records of maintenance work. This protects you on both fronts.
Plumbing and Water Supply
- Hot and cold running water must be available continuously
- Drains, waste pipes, toilets, and fixtures must function properly
- Leaks must be repaired without unreasonable delay
- Water heaters must produce hot water at an adequate and consistent temperature
Electrical Systems
- Wiring, outlets, switches, panels, and fixtures must be in safe working condition
- No exposed wiring, overloaded circuits, or unsafe conditions
- Outlets in bathrooms and kitchens must meet applicable electrical code requirements
Ventilation
- Kitchens and bathrooms must have adequate ventilation — either windows that open or mechanical exhaust
- Basements and storage areas must have sufficient air movement to prevent moisture buildup and mould
Mould is a significant liability. If there is a moisture problem in a unit, fix the source and remediate the mould. Do not paint over it. The city can order remediation, and the LTB can award rent abatement for units with unresolved mould conditions.
Pest Control
- Properties must be kept free of insects, rodents, and other pests
- If a tenant reports a pest problem, you are responsible for inspection and treatment
The pest control landlord guide covers your responsibilities under the RTA in more detail. The city's property standards bylaw adds a parallel obligation.
Fire Safety
- Working smoke alarms on every floor and outside every sleeping area
- Working carbon monoxide detectors where required by the Fire Code (homes with attached garages or fuel-burning appliances)
- Exits and egress must be clear and unobstructed
The fire safety guide for Ontario landlords covers the provincial Fire Code requirements in detail. The city's property standards incorporate these same baseline fire safety expectations.
Exterior and Yards
- Yards, driveways, and walkways must be maintained and kept clear of debris
- Overgrown vegetation, garbage accumulation, and unsightly conditions can trigger a bylaw complaint
- Snow and ice must be cleared from walkways and building entrances
How Enforcement Works
Complaint-Driven Model
Most property standards investigations in St. Thomas start with a complaint. A tenant calls the city's Property Standards department, or submits a complaint online, describing the problem. The city logs it and assigns an officer.
Unlike a licensing program (where the city schedules routine inspections), St. Thomas property standards enforcement is primarily reactive. Officers generally come to your property because someone reported a problem.
Inspection Process
A Property Standards Officer has the authority to enter your property to investigate a complaint. They must give you 24 hours' written notice before entering, except in an emergency (such as a gas leak or imminent structural collapse).
During an inspection, the officer assesses the property against the standards in the bylaw. They may photograph conditions, measure room temperatures, or test fixtures.
Orders to Comply
If the officer finds a violation, they issue an Order to Comply. The order:
- Describes the specific deficiency
- Cites the section of the bylaw it violates
- Sets a deadline by which you must fix it
Deadlines vary by severity. A structural hazard may get 48 hours. A cosmetic issue may get 60–90 days.
You must complete the required work by the deadline. After the deadline passes, the officer can return, inspect, and if the problem persists, issue fines.
Fines and Penalties
Fines for property standards violations in Ontario municipalities are set under the Municipal Act. For individual property owners, fines per violation can reach several thousand dollars. Repeat violations and failure to comply with an Order attract higher penalties.
In serious cases — where a building is unsafe or conditions are dangerous — the city can order the unit vacated until repairs are made.
Second Units and Basement Apartments in St. Thomas
St. Thomas does not have a second unit registration program equivalent to London's formal registration process. However, second units in St. Thomas must still comply with:
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- Ontario Zoning By-law and local zoning: The property must be in a zone that permits a second unit. Not every residential zone allows basement apartments.
- Ontario Building Code: A second unit must meet minimum ceiling height requirements, egress window specifications, fire separation standards, and smoke/CO alarm placement. If the unit was created without a permit, that's a problem.
- Fire Code: Second units require their own separate smoke alarm systems and must have proper fire separations from the principal unit.
- Property Standards By-law: Everything above applies. The second unit is inspected to the same standards as the primary unit.
If you are renting a basement apartment that was finished without a building permit, you carry significant risk. A property standards complaint can trigger an investigation that uncovers unpermitted work, leading to an order to legalize or decommission the unit.
The landlord maintenance responsibilities guide covers your baseline obligations for all units under the RTA.
How the Bylaw Interacts with the RTA
The City of St. Thomas Property Standards By-law and the provincial Residential Tenancies Act operate in parallel. They are not the same thing. They do not replace each other.
Under the RTA:
- A tenant can file a T6 Maintenance Application at the LTB if you fail to maintain the unit in a good state of repair. The LTB can order repairs and award rent abatement.
- A tenant can file a T2 Application if your failure to maintain constitutes interference with their reasonable enjoyment of the unit.
Under the Property Standards By-law:
- The city investigates the physical condition of the building
- The city issues Orders to Comply
- The city levies fines
A tenant can pursue both at the same time. Getting an Order to Comply from the city does not close the LTB file. Settling a T6 application at the LTB does not eliminate an outstanding Order to Comply.
More importantly: an outstanding Order to Comply can be used as evidence at an LTB hearing. If a T6 is filed and there is an open order for the same deficiency, that order is strong support for the tenant's position.
The practical implication: fix problems before they become Orders. Your landlord maintenance responsibilities under the RTA already require you to maintain units in good repair. Meeting that standard consistently means property standards complaints rarely escalate to orders.
What to Do If You Receive an Order to Comply
- Read the order carefully. Understand exactly what is required and when the deadline falls.
- Respond immediately. If the deadline is tight, start the repairs now — don't wait until the day before.
- Hire qualified contractors. For anything electrical, structural, or involving the Building Code, hire licensed professionals. Keep the invoices and any permits pulled.
- Document the completed work. Photographs of the repaired condition, contractor invoices, and permits are your evidence that you complied.
- Contact the Property Standards Officer. Notify them that the work is complete. In some cases, the officer will schedule a follow-up inspection; in others, documentation is sufficient.
- If you disagree with the order, you have the right to appeal to the city's Property Standards Committee. The order will state the deadline and process for appeal. Seek legal advice before filing an appeal if the issue is significant.
Common Mistakes St. Thomas Landlords Make
Ignoring a complaint, hoping it goes away. Property standards complaints don't expire. The city follows up. The longer you wait, the more likely a complaint becomes an order, and an order becomes a fine.
Not keeping maintenance records. If you can show dated records of furnace servicing, plumbing repairs, and regular inspections, you have a defence when something goes wrong. Without records, it's your word against the tenant's. See the landlord record-keeping guide for how to set this up properly.
Renting a basement unit without verifying zoning and code compliance. Second units need to comply with zoning, the Building Code, and the Fire Code. A property standards inspection can expose unpermitted work and lead to an order to decommission the unit — eliminating your rental income.
Delaying repairs to pressure a tenant. Under the RTA, deliberately failing to repair a unit to influence a tenant is retaliatory. Under the bylaw, it generates an Order to Comply. It is a losing strategy on every front.
Assuming no licensing means no oversight. St. Thomas landlords don't need a licence, but they are not operating in a compliance-free environment. The Property Standards By-law applies to every rental property in the city. A single tenant complaint puts a Property Standards Officer at your door.
Frequently Asked Questions
Does St. Thomas require a rental housing licence? No. Unlike the City of London, St. Thomas does not have a Rental Housing Licensing program. You do not need a licence to rent property in St. Thomas. However, property standards still apply.
Can a tenant contact Property Standards without telling me? Yes. A tenant can file a property standards complaint with the city at any time, without notifying you first. You will typically receive notice once the city assigns an officer and schedules an inspection.
What temperature am I required to maintain in the unit? A minimum of 21°C in all habitable rooms during the heating season (September 1 to June 15). If your heating system cannot achieve this, you need to repair or replace it.
Can the city enter my property without permission? With 24 hours' written notice, yes. Property Standards Officers have the legal authority to enter and inspect. In emergencies — a gas leak, fire, or imminent structural danger — they can enter without advance notice.
What happens if I don't fix the problem by the deadline on the Order? The officer returns to inspect. If the problem persists, you face fines. Repeat failure to comply can escalate to higher fines and, in serious cases, an order to vacate the unit.
Does a property standards order affect my ability to evict a tenant? An outstanding Order to Comply can complicate LTB proceedings. If a tenant raises the same deficiency at an LTB hearing — for example, via a Section 82 claim at an eviction hearing — the order is direct evidence against you. Resolve outstanding orders before heading to the LTB.
Managing Compliance Without the Headaches
Keeping a rental property in St. Thomas compliant isn't complicated. It comes down to maintaining the property consistently, fixing problems promptly, keeping records, and not letting complaints fester.
The landlords who end up with Orders to Comply are typically the ones who deferred maintenance too long, ignored a tenant's first request, or didn't realize a basement unit was unpermitted. The property standards system doesn't set a high bar — it sets a minimum floor. Most landlords who take the work seriously never interact with it.
If you own rental property in St. Thomas and want consistent maintenance management, documented repairs, and someone who handles tenant requests without you having to be on call — that's exactly what Prospera Properties does for small landlords across London, St. Thomas, and Strathroy. Get in touch to talk through what management looks like for your property.
This guide covers general property standards requirements for St. Thomas, Ontario landlords. Municipal bylaws are updated periodically — verify current bylaw provisions directly with the City of St. Thomas Property Standards department before relying on specific details for compliance decisions.
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St. Thomas landlords: no rental licence required — but property standards still apply. Here's what the city actually requires, how enforcement works, and the most common mistakes landlords make. [Link in bio]
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