Condo Records Requests in Ontario: How Your Board Must Respond in 30 Days, and When You Can Refuse

A condo records request in Ontario gives your board 30 days, and those 30 days are to answer, not to deliver. You answer on a mandatory government form, record by record: whether the owner is entitled to each record, whether it is core, how and where you will give access, and what it will cost. The records themselves move later, on separate clocks, after the owner confirms your response and pays. One exception sits inside the 30 days: core records asked for in electronic form go out with your response, and they are free.

Four questions decide how the next month goes: who may ask, what is core, what you may lawfully charge, and which records an owner cannot reach. The form, the clock, the classification and the fee estimate are the machinery, and running them without drama is a large part of what day-to-day condo management services are for.

What Counts as a Condo Records Request in Ontario, and Who Can Make One

This process is deliberately mechanical. A government form comes in, a government form goes out, and a fixed clock sits between them. For a board, that is good news: a mechanical process is one you can actually run, with no judgment call about tone and no argument about whether to engage. The only real question is what the clock attaches to.

The Two Mandatory Forms This Process Runs On

The requester uses the Request for Records form and names each record, the date range, and the format wanted: electronic or paper, delivered, picked up, or examined in person. The regulator states that obligation in mandatory terms, so the form is not a courtesy. Your board answers on its own form and deals with each requested record separately: entitlement, core or non-core, how and where access will be given, and an itemized fee estimate.

A helpful email instead of the response form is still a breach. The Tribunal has treated a reply off the form as non-compliance on its own, even where the board engaged with the substance. So the mandatory Board’s Response to Request for Records form is the only safe way to answer, in every case and for every record.

Only Owners, Purchasers and Mortgagees Can Ask

The right of access belongs to owners, purchasers and mortgagees, and to an agent acting for one of them, in which case the form treats the agent’s request as the principal’s. Boards field requests from tenants, from a resident’s adult child, and occasionally from a reporter. None of those three carries the right.

The practical half is about the form in front of you. Your response is where the reasons go, record by record, so an entitlement question that arrives on the form gets answered on the form, with the reason written down rather than delivered in a phone call. The right itself, and the limits on it, come from the Condominium Act, 1998.

What Starts the 30 Days, and What Does Not

The 30 days belongs to the mandatory Request for Records form. An email, a phone call or a conversation at the mailboxes does not start it, and Ontario’s condo regulator tells owners who skipped the form to fill it in and begin again. That is not a reason to leave the owner waiting. Send the form the same week, answer the person in writing, and write down the date their first ask arrived. Boards get into trouble for going quiet, not for paperwork.

The arithmetic favours the fast reply. An off-form ask answered the same week, with the form attached, costs the corporation nothing and ends there. The one that gets filed away is the one that comes back months later as an application, with a director trying to remember who said what in the lobby.

How a Request Reaches You, and Why a Long Weekend Costs You

A Request for Records can arrive by mail, by courier, in the corporation’s mailbox, or by fax or email where the corporation accepts requests that way. It can be addressed to the corporation’s address for service, to the condo manager, or to the management provider. So a board cannot argue that the form went to the manager instead of to the board. Hold on to one distinction: an email can carry the form, and an email on its own is not the form.

Then the arithmetic. The count runs in plain days, not business days. A request that lands the Friday before a long weekend uses up the weekend and the holiday with it, so treat the 30 days as four working weeks at best. Diarize the date it was received, not the date someone noticed it.

Core Records and Non-Core Records: The Fork That Sets Price and Speed

Every other decision in a records request hangs off one fork. Core records are cheap and fast by design, because they are the documents an owner needs in order to vote, sell or question the board. Everything else the corporation has to keep is non-core, and non-core is where the labour, the fees and the longer clock live.

What Sits on the Core List

The core list is short enough to read in one go:

• the declaration, the description and the schedules
• the by-laws
• the rules
• shared-facilities agreements
• the budget for the current fiscal year and its amendments
• the most recent board-approved financial statements
• the most recent auditor’s report
• the current plan for funding the reserve fund
• the record of owners and mortgagees, and the summary of leased units
• information certificates issued in the last 12 months
• minutes of owners’ and board meetings held in the 12 months before the request
• anything a by-law of the corporation designates as core

Two limits in that list do most of the work. Several of those documents are core only in their most recent version, and minutes and information certificates reach back only 12 months. Minutes appear here as a class of record, not as meeting procedure: what a compliant condo AGM requires is a different question from how that meeting’s minutes get classified a year later.

The Non-Core Side, and the Three Records Boards Misfile

Non-core is everything else the corporation must keep, and three misclassifications produce most of the trouble. Minutes of a meeting held more than 12 months before the request are non-core, so the same minute book sits on both sides of the line at once. Previous budgets, previous financial statements, previous auditor’s reports and previous funding plans are all non-core. And the reserve fund study itself is non-core even though the plan for funding the reserve is core, which catches owners and boards in equal numbers.

The rest of the non-core side is one long run: invoices, contracts and management agreements current or expired, insurance policies, claims and insurance investigation records, performance audits, ballots and proxies, records about specific units or owners, previously issued status certificates, director disclosures and training records, and the corporate seal. A previously issued status certificate is non-core, which surprises people, and releasing an old one is easier when you already know what buyers look for in a status certificate.

What Age Does to a Record, and What It Does Not

Age moves a record from one bucket to the other only where the core list is written in terms of time, which means minutes, information certificates, and the financial documents that are core only in their most recent version. Outside those, age changes nothing. A 1987 declaration, the by-laws and the rules are core at any age.

And age never makes a record refusable. An 18-month-old set of minutes is a non-core record the owner is entitled to, at a lawful fee, on the non-core timeline. When age is the reason a record sits on the non-core side, say that in your response as a classification and price it accordingly.

The Record of Owners and Mortgagees: Core, Free Electronically, and Priced Wrongly

This is the most requested record on the list and the one boards price wrongly. It is core, it is kept indefinitely, and it has to carry owners’ and mortgagees’ addresses for service. An electronic copy of it goes out free. A manager who quotes a per-page charge to edit the list before releasing it has created a breach rather than a negotiation, and that exact charge was found unlawful at the Tribunal.

There is a reason these lists go stale. Owners add and update their own name, unit type and address for service on the regulator’s notice form within 30 days of buying, and many never do. So the list you are about to release is only as current as the owners made it.

Why Nobody Has to Tell You Why They Want It

Boards act on this myth more often than any other. There is no separate step in this process where an owner explains their reasons. The form does ask them to put their name to one thing, and this is it: the owner signs an affirmation that the request relates only to their interest as an owner, purchaser or mortgagee. That is the limit on what the list may be used for, and it is signed before you hand anything over.

There is one dated qualification. The province has consulted on a change that would require an owner to give the purpose of a request when it covers records containing other owners’ emails and addresses. It is a proposal, it would take effect 31 December 2026 if approved, and it is not the rule today.

The Clocks: What Has to Happen, and By When

Four deadlines sit inside a records request, and only the first one is yours alone. You answer in 30 days. The owner then has 60 days to confirm and pay. Paper copies of core records follow within 7 days, and non-core records within 30 days of the payment. Core records in electronic form skip the middle entirely.

Days 1 to 30: Answer on the Form, Record by Record

A compliant response names each requested record and says four things about it: whether the owner is entitled to it, whether it is core, how and where access will be given, and what it will cost. Boards blow this in three ways, usually in this order. They reply by email rather than on the form. They answer the request as a bundle instead of record by record. They give a fee number with nothing behind it.

Where a core record was asked for in electronic form, the record itself goes out with the response, inside the same 30 days, together with the written statement that accompanies it. No payment. No confirmation step.

The Owner’s 60 Days to Confirm and Pay

Once your response is out, the clock is the requester’s. They sign the confirmation portion of your response form, return it with the fee, and they have 60 days to do that. Nothing except free electronic core delivery moves before the estimate is paid.

The practical point matters more than the deadline. A request that goes quiet after your response has not been abandoned, so keep the file open and keep the estimate exactly as quoted. The owner can come back on day 58 and hold you to the number you gave.

Then 7 Days for Core Paper, and 30 Days From the Payment for Non-Core

Once the owner signs the response back and pays, paper copies of core records go out within 7 days, and non-core records within 30 days of the payment. Two different clocks, one trigger. Diarize both the day the signed confirmation arrives and the day the money clears, because they are not always the same day and the non-core count runs from the payment.

Keep the CAO’s step-by-step guide for core records open beside the form while you work, since it walks the sequence in the same order the form does. It is a PDF.

Examining the Records in Person

In-person examination is one of the four formats on the request form, and it prices differently from every other route. Name the examination location in your response, record by record, because that is where the owner is entitled to find it. Then book the date as soon as the signed confirmation and any fee arrive, and work to the same 7 days that core paper copies run on. Put the appointment in writing and keep the room booked.

The money works differently too. For an examination of core records you may charge reasonable labour for the time the examination actually takes, plus up to 20 cents a page for anything printed or copied while the owner is there. So send someone who can find the file: labour you bill for time spent hunting is labour you cannot bill at all.

When the Request Is on the Form but Too Broad to Answer

Sometimes the form arrives and what it asks for is vague, incomplete or sweeping. Once the form is in, asking the owner to narrow the request does not pause anything. Answer on the form inside the 30 days, say in writing exactly what you need spelled out, and deal with the narrowed request as a fresh one.

A board that wrote asking for clarification, got no reply, and then did nothing was still found in breach, though the Tribunal softened the penalty for it. The requester does not get a free pass either. The Tribunal has said an owner cannot blame the layout of the request form for a vague request, and cannot wait until a hearing to say what they actually wanted.

What You May Charge, and What Gets Read as a Refusal

A fee is reimbursement for work actually done, not a price the corporation sets. Boards lose records cases on fees more often than on outright refusals, because an inflated number does the same damage as a no and is far easier to justify to yourself at the time.

Fees Pay for Actual Labour, Not Your Manager’s Hourly Rate

A requester pays actual labour costs, not whatever the management provider bills. In a 2025 decision, Jalbout v. Carleton Condominium Corporation No. 272, 2025 ONCAT 70, the Tribunal found a manager’s $125 an hour too high for records work and allowed $50 an hour instead, held that redaction should take no more than two minutes a page, and refused to allow any charge for the time spent locating and identifying the records. That was one adjudicator on one set of facts, not a published rate card.

The durable part is the method. Itemize the estimate by task and by minutes, price the person who will actually do the work, and never bill the search.

Electronic Copies of Core Records Are Free, Even When You Only Hold Paper

This is the most expensive mistake available to a board, and one sentence avoids it. If an owner asks for an electronic copy of a core record and the corporation keeps that record only on paper, you may hand over a paper copy, but you must hand it over at no cost whatsoever, printing included.

The same facts run the other way for non-core records. There, if the owner wants electronic and you hold only paper, you may supply paper and charge the associated costs. Same request, same gap in your filing, opposite answer, and the only thing that changed is the classification.

An Inflated or Unexplained Estimate Is Treated as a Refusal

Boards think of a fee quote as a negotiating position. The Tribunal reads it as an answer. A fee demand that was never explained, and that no owner could reasonably meet, has been found to amount to a refusal with no reasonable excuse, and penalized as one.

So put one test in front of a director before the estimate goes out: could you hand this number to a stranger and have them see the work in it. If the honest answer is that the figure was chosen to make the request go away, it is a refusal, and it will be treated as one.

After the Records Go Out: Refunds and the 10 Per Cent Cap

Almost every board skips this step. A written statement goes out with the records saying what the work actually cost. If it cost less than the owner paid, you refund the difference. If it cost more, the owner pays the least of three amounts: the difference, 10 per cent of what the work cost the corporation, or 10 per cent of the fee already paid.

Read that last rule from the board’s side of the table. An estimate that came in low is mostly your problem, not the owner’s, and that is the real argument for estimating carefully rather than optimistically.

What the owner asked for is what sets your price and your deadline, so the format named on the form decides more than the record itself does.

What You May Charge, and When the Records Have to Go Out

What Was Requested	What You May Charge	When It Has to Be Delivered	The Mistake to Avoid
Core record, electronic copy, held electronically	Nothing	With your response, inside the 30 days	Waiting for a payment that is not owed
Core record, electronic copy, but you hold only paper	Nothing at all, printing included	With your response, inside the 30 days	Quoting a printing charge on the one path that is free
Core record, paper copy	Up to 20 cents per page, and nothing for labour	Within 7 days of the signed confirmation and the fee	Adding an administration or labour fee on top of the per-page cap
Core record, examined in person	Reasonable labour for the time the examination takes, plus up to 20 cents a page for anything printed or copied	At the location you named in your response, booked as soon as the confirmation and fee arrive	Leaving the location out of your response, or treating the examination like a paper copy order and charging per page for the whole file
Non-core record, any format	A reasonable estimate of actual labour, printing or copying at up to 20 cents per page, and delivery	Within 30 days of receiving the payment	Quoting your management provider’s hourly rate instead of the actual labour cost
Non-core record, electronic copy wanted, you hold only paper	You may supply paper and charge the associated costs	Within 30 days of receiving the payment	Assuming the free electronic rule for core records applies here too

When You Can Refuse, and How to Refuse So It Holds Up

Refusal is narrow, and it is procedural. The grounds are short, they are not a matter of mood, and how you say no matters as much as whether you were entitled to. Almost every refusal that fails at the Tribunal fails on the how rather than the whether.

The Four Kinds of Records an Owner Cannot Reach

The Act keeps four kinds of records out of an owner’s reach: records about the corporation’s employees, apart from their employment contracts; records about actual or contemplated litigation and insurance investigations; records about other units and other owners; and a short further list set out in the regulation.

Each one has a shape a director will recognize. The employee category covers the performance file on your superintendent, but not his employment contract. The litigation category covers the file on the window contractor you are about to sue. Other units and other owners covers the arrears ledger for unit 804 and the complaint letter the owner in 1102 wrote about her neighbour. The prescribed list is where a handful of narrower items sit, and it is the one to check rather than guess at.

When You May Refuse but Do Not Have To

Almost no board knows the next part. Litigation records and insurance investigation records are records the corporation is allowed to withhold, not records it is required to withhold. You can choose to release them.

That turns a reflex into a decision. Sometimes handing over the file is what ends the dispute, and sometimes it is the last thing you would do. Make the call deliberately, minute the reason, and get advice before releasing anything that touches live litigation.

Redact the Record, Do Not Refuse the Whole File

In a real dispute the answer is usually yes, with names and unit numbers blacked out. Where only part of a record is protected, you release the rest. And the obligation that makes a redaction defensible is the written statement that goes out with the records: it has to say that something was taken out, and give the reasons.

That is what turns a judgment call into a position you can stand on months later. A board that redacts silently has produced an incomplete record with no explanation, which reads exactly like concealment.

Fishing Expeditions, and the Reason You Have to Give at the Time

A board may decline a request that casts a wide and imprecise net, hoping to turn up problems that might not exist. It is judged on how broad the description is and how long a period it covers. Forty years of every approved alteration qualified. Five years of all board emails qualified.

Here is the catch. In that same case the corporation was still found liable, because at the time it had offered to supply the records for a fee instead of saying the request was too broad. A reason you never gave when you answered does not save you later. If you are going to refuse, refuse on the form, inside the 30 days, for the reason you actually hold.

Records You No Longer Have, and Records You Should Have Kept

Boards say we do not have it more often than they say anything else, and examine it least. The retention shape is plain enough. Governing documents, minutes, the record of owners and mortgagees, reserve fund plans and studies, drawings and current agreements are kept indefinitely. Records tied to a financial period are kept at least seven years after the end of the last period they relate to. Ballots and proxies need only be kept 90 days after the meeting, unless written notice of actual or contemplated litigation arrives inside that window.

Then the distinction that decides the case. A record you destroyed lawfully is a complete answer. A record you never kept is not. Answer on the form either way and say which of the two it is. The usual practical cause is a record still sitting with a former provider, which is why the records handover when you change management companies deserves more attention than it gets.

Excuses That Have Already Failed

The fastest way to stop a board repeating a mistake is to show that it has already lost. The Tribunal has rejected each of these:

1. Board members were unavailable. A volunteer board is still the corporation, and the corporation answers.
2. Unforeseen circumstances got in the way. The clock ran anyway.
3. The requester already has the records, or we believe they do. Your belief about what an owner already holds is not an answer on the form.
4. The owner can get the records on their own. Pointing someone elsewhere is not giving access.
5. We asked the owner for clarification and never heard back. Silence from the owner does not excuse silence from the board.

None of them is a reason to skip answering on the form inside the 30 days. Whatever is true about the requester, or about the month your board was having, the duty is the same: put your answer, your fee estimate and your reasons on the form, and send it.

What a Records Refusal Has Cost Other Corporations

Records disputes reach a tribunal because filing one starts at $25, which is why owners file over records and argue about roofs in the lobby. If you are an owner reading over a director’s shoulder, and you were ignored or quoted a fee you cannot meet, your filing route and its deadlines are part of what the Condominium Authority Tribunal covers now. For a board, the narrower question is what these cases have actually cost.

Up to $5,000, and What Moves the Number

The Tribunal can order the corporation to pay the owner a penalty where it refused without a reasonable excuse, and the ceiling is $5,000. Up to $5,000 is the honest construction, because the amount is calibrated: the length of the delay, how many records were withheld, what kind of records they were, and whether the corporation has done this before.

In Balasubramaniam v. Metropolitan Toronto Condominium Corporation No. 812, 2023 ONCAT 152, a Toronto corporation missed the 30 days, did not use the mandatory form, and had already been penalized $2,000 for the same conduct. It was ordered to pay the full $5,000. A 2025 case with both flat refusals and fees that masked refusals drew $1,200.

The Penalty Is Not the Whole Bill

The penalty is rarely what a director actually feels. In that Toronto case the corporation also paid the owner’s $200 in Tribunal fees and $1,582 in legal costs, and every sitting director was ordered to take or retake the mandatory director training within 30 days.

There is also a mechanism boards never expect. The owner can set unpaid penalties and costs off against the common expenses charged to their unit, so the corporation ends up funding the dispute from the ledger it was trying to protect. And in an earlier round of the same dispute the corporation ignored a Tribunal order, the owner went to the Superior Court of Justice to enforce it, and the court ordered the corporation to pay $14,000 in costs.

The Order Lands on the Corporation, Not on Your Manager

The Tribunal’s order lands on the corporation, not on the manager. A manager’s conduct is a licensing question and goes to the CMRAO instead, which is small comfort to a board that has just been fined.

This changes how a board supervises the work, not whether it owns it. Hiring a competent manager does not move the liability. It makes the breach less likely. The board still signs for the outcome, which is why the board should be able to see the clock at any point in the month.

Four Things to Do Before the Next Request Arrives

Everything above is easier if four things are already true on the day the form arrives. Treat them as work for this quarter rather than as a warning.

1. Pass the board resolution on electronic delivery, and publish the method. Where the corporation keeps a record electronically, the board has to decide by resolution the method of electronic communication it will use to deliver records, and that method has to be stated in the corporation’s most recent Periodic Information Certificate or Information Certificate Update. Many boards have never passed it, and without it the free electronic path is awkward to operate on the day you need it.
2. Hold your core records in electronic form. The cheapest and fastest route through a request is the electronic core path, so make it the path of least resistance before anyone asks. Scanning a minute book in a quiet month costs a fraction of what it costs in week three of a request.
3. Give the 30-day clock one owner and one diary entry. Date of receipt in writing, a named person responsible, and a response drafted by day 20 rather than day 29. A clock with two owners has none.
4. Reconcile the record of owners and mortgagees now. Addresses for service, current names, and the summary of leased units, so the record owners ask for most often is not also the one you would be embarrassed to release.

Who Owns the 30-Day Clock in Your Corporation

A records request is administrative work on a statutory clock, and it goes wrong quietly: in a busy month, in a corporation where nobody owned the date. At CPO Management we have spent more than 15 years managing GTA residential and commercial condominium corporations, we hold CMRAO licensing for condominium management, and our portfolio runs from condominiums and co-ops to commercial and community buildings. That is most of what condominium management services do for a board on this topic: own the date, classify the records, price the labour honestly, and put the reasons in writing.

If you want that work off a director’s kitchen table, request a proposal and we will tell you plainly what we would change first. The smartest step today is a smaller one: find out whether your corporation could answer a records request on the form, record by record, inside 30 days.

Frequently Asked Questions