More Neighbours Toronto is tracking the milestones that the City of Toronto committed to in its Housing Accelerator Fund (HAF) agreement with the federal government. We review the progress that the City has made on policy decisions to earn these funds and update this page to reflect what the City has accomplished, and what more needs to be done. This page explains our methods, sources, and some additional evaluation of Toronto’s HAF initiatives.
Is the City of Toronto hitting its milestones?
As of December 31, 2024, Toronto has completed 15 of the 23 milestones that were scheduled to be completed by this date. Another 12 milestones have later due dates and one of these is already completed. Only 12 milestones have been completed on time.
There is some nuance. The City went beyond its initial plans in some areas (eg. increased the unit cap for apartments on Major Streets from 30 to 60 for milestone 7.1, or completing the first call for applications for the rental incentive program ahead of schedule for milestone 6.2). However, other milestones for reports were completed with disappointing outcomes that are unlikely to result in more housing (eg. dismissiveness of BC-style permissions for transit-oriented development in milestone 4.4, or the apparent lack of formal review of shadow policies for milestone 7.5).
Several milestones (notably those in Initiatives 2 and 4) are dependent on the successful delivery of a small number of projects, meaning that delays in these milestones will have a large impact on Toronto’s ability to deliver new units.
In addition to the summary chart below, you can find a detailed breakdown of individual milestones with links on our detailed tracker spreadsheet, which has separate tabs for tracking the milestones and summarizing the initiatives.
| HAF Initiative Description | Est. additional permitted units (3Yr) | Milestones completed | Milestones due Dec 31, 2024 | Total Milestones in Initiative | Milestones completed on time |
|---|---|---|---|---|---|
| 1. Transforming the City of Toronto's administrative structure and increasing capacity to expedite the approval of new development applications | 700 | 4 | 4 | 6 | 4 |
| 2. Revitalizing Toronto Community Housing Buildings and Creating Net New Rent-Geared-to-income and Affordable Rental Homes within inclusive, equitable and complete communities | 2600 | 2 | 3 | 3 | 1 |
| 3. Protecting Rental Homes and Increasing Affordability for more renters | 0 | 2 | 3 | 5 | 1 |
| 4. Enhancing the Housing Now Initiative and expediting delivery of new permanent affordable rental and RGI homes within transit-oriented and complete communities | 3200 | 2 | 3 | 6 | 1 |
| 5. Transforming Toronto's Waterfront as a catalyst for social, economic and cultural growth | 880 | 2 | 2 | 3 | 2 |
| 6. Implementing a new 'Rental Housing Supply Incentives' Program to increase purpose-built rental housing supply | 3100 | 2 | 1 | 2 | 2 |
| 7. Expanding missing middle housing options and allowing increased density | 700 | 2 | 5 | 8 | 1 |
| 8. Optimizing land use and simplifying the planning approvals process to increase purpose-built rental supply in Apartment Neighbourhood zones | 600 | 0 | 2 | 2 | 0 |
| Totals | 11780 | 16 | 23 | 35 | 12 |
These milestone numbers provide an overall summary of Toronto's progress. For those interested in the nitty-gritty, there are more details on how Toronto's initiatives relate to the HAF goals below.
What is the Housing Accelerator Fund?
The Housing Accelerator Fund (HAF) is a federal government program where municipalities applied for a portion of $4 billion in exchange for commitments to change their housing systems. The pre-application guide summarizes the program this way:
Through the provision of incentive funding, the HAF is intended to drive transformational change within the sphere of control of the local government regarding land use planning and development approvals with the overall objective to ‘accelerate supply’ of housing.
Objectives, targets and evaluation criteria are laid out in the pre-application guide. Key points:
- Initiatives should produce new housing supply. Funding was awarded based on predictions for additional building permits issued above historic averages. There were bonus funds for multi-unit transit-oriented housing, missing middle housing, and affordable housing, but the focus was on making changes that would permit more new housing.
- Initiatives should have an impact on the housing system, not just individual projects. In general, the changes that municipalities proposed were to be broad reforms or long-term commitments that would continue to accelerate housing and/or increase housing supply after the HAF program ended.
This differs from many other federal government programs, where funds are provided to subsidize units in a specific project. Many of those projects have run into delays and cost overruns due to the ways that municipalities currently plan and approve housing and their long processing times. The federal government is not able to change these rules and processes directly. The goal of this program was to incentivize municipalities to make those changes. - The program was competitive. Not every municipality that applied was awarded funding. Furthermore, the amount of funding was not based on need or population, but on the strength of the application and how likely it was to transform the housing system and produce more housing. This was evaluated by the Canada Mortgage and Housing Corporation (CMHC), who administered the program. Municipalities interested in more funding would therefore need to propose bigger, more sweeping changes.
Successful HAF applicants will receive funds in four installments and are required to release annual public reports within 30 days of the anniversary of the effective agreement date. (Toronto passed a motion for HAF commitments at City Council on December 13, 2023 and the agreement was signed on December 20, 2023.) The second and third installments are likely to be based on meeting the milestones in the signed agreement. The final installment is intended to be based on building permit data that would indicate that more permits were issued by the end of the HAF program.
All of these aspects are important for the success of the Housing Accelerator Fund, but they are more complex than evaluating milestones and timelines. The next sections are therefore more detailed.
Are Toronto’s initiatives new?
The pre-application guide stated that initiatives should be new, meaning that they had not started prior to the 2022 federal budget. This requirement appears to have been relaxed.
Toronto’s application includes a number of complex projects that have been underway for years, with the assumption that changes could expedite or expand those projects to produce additional housing. In evaluating whether initiatives were new, we therefore note both what milestones were planned - or even completed - prior to HAF, as well as whether new units are likely to be added or timelines reduced, but we put more focus on new or additional units.
A breakdown by initiative:
- Expedite Approvals - Yes. Toronto has made several previous attempts to re-evaluate and speed up their approval process (eg. Concept 2 Keys). The Development and Growth Division was a restructuring first announced in October 2022 by former Mayor John Tory. It is not clear whether new digital tools were part of the initial plan or were added for HAF.
If successful, faster approvals would reduce costs during construction and reduce uncertainty. This helps to make more projects viable and would produce an increase in new housing supply. - TCHC Revitalization - Mixed. The TCHC revitalization projects at Regent Park, Firgrove, and Lawrence Heights, are major projects that the City has been working on for years, but one stated justification for their inclusion in HAF is that the money could expedite these projects, allowing them to start construction sooner. Unfortunately, Regent Park and Lawrence Heights have already encountered delays.
The Regent Park rezoning in July 2023 added 273 new units on top of existing plans. It was later discovered that these plans conflicted with City infrastructure and a new rezoning was passed in December 2024. This will delay the project but the City also added 98 more market units and somewhat fewer units of affordable/RGI housing (the exact number was not specified. The gross floor area is similar to the market rate addition, but the RGI/affordable units will include more 4- and 5-bedroom apartments).
The Firgrove rezoning and Plan of Subdivision was passed with conditions by Council in July 2022 with delegated authority for reviewing the conditions and final approval given to the Chief Planner. This final approval appears to have been granted in early 2023 with few details publicly available, but the delegated authority is unlikely to include the ability to approve additional units so it is not clear how this project was expanded or expedited by HAF.
The Lawrence Heights revitalization project started in October 2015. The City states that its initial plans don't meet the minimum density required under the Protected Major Transit Station Area (PMTSA) plans, so they are looking at a redesign to meet that minimum. It is not clear how many units this might add at this time. The highest minimum density in the PMTSA plans in this area is a floor space index of 3. The project is also behind schedule and a request for proposal has not yet been issued. - Protecting Rental Homes - No. This initiative is not planned to produce any new units and, as a result, Toronto did not receive any funding based on it, although it did commit to several milestones.
The milestones themselves are a mix of things that were already underway and new plans. The pre-development fund is a new idea, possibly developed in response to feedback from small and non-profit developers who attempted to apply to Housing Now but found the cost and time of applying for City programs was too great to be worthwhile. The Multi-Unit Residential Acquisition program is an existing program passed in 2021.PH28.3. The housing at-risk table appears to be new, although the City has several existing programs for eviction prevention (eg. EPIC and the Toronto Rent Bank). The renoviction by-law was initiated in July 2022 and the by-law proposal and implementation plan were originally intended to come back before HAF application submission in Q2 2023, but were delayed. The rental protection and supply team is new, intended to create a database of at-risk properties and track them. - Housing Now and Transit-Oriented Communities - Mixed. The Housing Now program was adopted in 2018.CC1.3 and shovels were intended to be in the ground on multiple City-owned sites within a few years, but the program has faced numerous obstacles and delays. As a result, the City passed several program enhancements in 2023.PH3.6 to look at height, density, unit mix and tenure, particularly adding flexibility for suburban sites where the market might not be strong enough to support the cross-subsidy needed for the program.
It is not clear how much HAF influenced these changes, but it is likely that a number of these Housing Now projects would have been further delayed without additional funds. In addition, the City has added units on many sites.
However, delays continue. Bloor-Kipling broke ground on its post-HAF schedule in Q3 2023, but 50 Wilson Heights broke ground in November 2024, a year behind the planned Q4 2023 start. And 140 Merton has not yet broken ground despite a plan to start construction in Q3 2024. This is not a promising sign for the 14 Housing Now sites that the City had hoped to expedite with HAF to reach the permitting stage by September 2026.
The report on BC's transit-oriented housing permissions (Milestone 4.4) was novel and had the potential to lead to more new units but the City seems reluctant to pursue it. The zoning amendments for Major Transit Station Areas (MTSAs) have been held up by a lack of provincial approval, but the City's submissions also would not have allowed more housing as-of-right on most sites without intervention by the province. So, unfortunately, these milestones are not likely to add much new housing during the HAF timeframe. You can read more about our disappointment with the City's approach to MTSAs in our response to PH17.14. - Quayside - Yes. Quayside was planned prior to HAF but the City added new units to the plans after they submitted their application. The initial proposal in July 2022 was for 3500 units and the latest update estimates 4700 units. That is the number for both phases of the project and Phase 1, which makes up about half of the units, is aiming to start during HAF.
- Rental Housing Supply Incentives - Mixed. This program replaces the previous Open Door program, but it accounts for provincial changes from Bill 23 and goes beyond the development charge reductions required by the province. Also, many of these projects were "stuck" and might not have been able to move forward during the HAF period without extra funding. However, in 2024, the City increased development charges, including an increase of about 20% for rental apartments. Many rental projects have therefore seen an increase in charges since HAF submission, but those selected for the Rental Housing Supply Incentive program will see a reduction, which makes the net effect on new rental supply more complicated.
- Missing Middle - Mixed. Many of these milestones were part of the 2022-2026 Housing Action Plan (2023.EX3.1) and had initial completion deadlines that fell before HAF. For example, the post-secondary housing strategy was part of the Housing Action Plan initially due in Q4 2023, but HAF altered that deadline to March 30, 2025. However, the 6-unit/4-storey, how-to guide, simplified design guidelines and built-form concepts and the availability of the missing middle pilot designs appear to be new.
In addition, the City has taken steps to add units to some existing plans. The Major Streets milestone was scheduled for a final report in Q4 2023 but delays meant that the by-law passed in May 2024 with a 60-unit cap that exceeded the initial plans for a 30-unit cap. The as-of-right zoning along Avenues was also part of the Housing Action Plan and has been split into parts, some of which have been delayed, but the City is examining opportunities for additional height.
The initial report for 6-units/4-storeys was delayed until December 2024 and a proposals report was then planned for December 2025, which likely would not have produced new units during HAF, but an amendment now aims for a final report in December 2025. The angular plane re-examination was in progress before HAF but the "no net new shadow" review is new. Unfortunately, these have been delayed and the City's apparent reluctance to move forward with a review of the "no net new shadow" policy and skepticism about allowing heights that would permit four storeys in more Neighbourhoods mean that this initiative will likely result in less additional housing than was hoped for under HAF. In addition, a motion to consider how the new mid-rise design guidelines that replaced angular planes would affect financial feasibility and housing construction was voted down at committee. - Apartment Infill - Mixed. The apartment infill initiative was part of the Housing Action Plan that pre-dated HAF and did not meet the initial deadline in that Work Plan, but it is possible that HAF may incentivize broader reforms for this Work Plan item. If completed, this initiative could simplify some forms of infill in Apartment Neighbourhoods. Any building over 10 units would need site plan approval, but zoning could be as-of-right, which would facilitate more housing in these areas. However, given that this initiative is behind schedule, it seems unlikely that 600 new, additional units will be completed during the HAF timeframe.
Will Toronto’s initiatives change the housing system?
The system impact of an initiative was evaluated by how much it would increase the stability and predictability in the housing system. A more predictable housing system has clear rules and processes, which reduce uncertainty and risk, making it easier to plan and complete homes. This differs from the stability that is created for tenants who are selected to live in a particular building that might have been subsidized by HAF funds; for it to be systemic, the impact should go beyond those who live in the specific units created. Of course, any time that net new homes are created, the increased supply improves the overall stability of the housing system, but this is true of any homes (whether subsidized or not), so it seems likely that the federal government was interested in effects beyond this.
An interesting aspect of HAF is that the funds did not necessarily have to be spent only on the proposed initiatives. A municipality might propose broad zoning changes to make the construction of market housing easier, with a small part of the funds going toward staff to make those changes, but the bulk of the funds could be spent on other projects entirely. These might include deepening affordability on planned housing, repairing existing social housing, new wastewater infrastructure, etc., even if none of those projects were part of a proposed initiative (see Section 8 of the pre-application guide for more).
The HAF Initiatives that Toronto chose include several big, pre-existing projects (the TCHC revitalization projects, the Housing Now sites and Quayside) that the City has struggled to get off the ground. A large amount of City-owned affordable housing would transform the housing system, but this will not happen if these projects are not completed or if delays and cost overruns make future subsidized housing projects politically toxic. The City has often struggled with its own processes, highlighting the need for system-level change because "business as usual" is creating delays and adding costs. A change in the housing system would fix the underlying problems rather than using funds to unstick projects caught up in these lengthy processes.
For example, rather than creating a fast-track process for selected affordable housing projects, HAF might incentivize a city to review the list of required studies and urban design guidelines to determine whether they actually result in better communities or housing outcomes. Rather than using HAF money to buy a relatively small number of aging apartments, a city could consider whether concentrating growth into a few apartment-rich areas contributes to the demolition of older, more affordable buildings. Rather than adding subsidy for one Housing Now project, consider places where a one-time investment could reduce time on bespoke site-specific evaluations for future projects.
There are some initiatives where the City committed to broader, long-term changes, but there are others where the City placed limitations on itself by being unwilling to reconsider how its current system has contributed to the housing crisis:
- Expedite Approvals - Yes. More rapid approvals would decrease uncertainty and reduce costs, making more projects viable and allowing shovels to get in the ground sooner.
- TCHC Revitalization - No. CMHC stated that specific capital projects were not an eligible initiative. HAF initiatives should offer system-level change beyond adding units on specific projects. The TCHC revitalization initiative will make many of these sites mixed-income, which is a shift from how they have operated previously and may allow these buildings to be more easily maintained.
- Protecting Rental Homes - Mixed. The pre-development fund will more easily allow small and non-profit developers to apply to City programs. The City could have considered whether its wide array of programs with separate application requirements could be simplified to lower these barriers for everyone, but a pre-development fund is still an improvement in changing who can easily access and navigate the housing system.
The MURA and eviction prevention programs are largely signs of the growing problems further upstream in the housing system. The increasing demand for these last-resort measures is a sign of the failure to fix that system. These programs help the tenants who can access them but, with low vacancy rates and limited housing supply, new tenants will still struggle to find suitable places to live. A housing system approach would consider how the City's existing Official Plan excludes new apartments from most of Toronto's residential land, forcing new apartments into existing apartment neighbourhoods and contributing to the precarious situation of tenants there. In addition, previous municipal efforts to protect tenants have been well-intentioned but lacked enforcement, limiting their effectiveness. - Housing Now and Transit-Oriented Communities - Mixed. "Unsticking" projects that are in trouble because of interest rate and construction cost increases will contribute to housing supply and is worthwhile, but doing this through additional funding is not a systemic fix. Given that the initial Housing Now delays led projects to run into a period of higher interest rates, a systemic fix might re-examine the way that the City initially put sites out for bid. Some of this reflection, including revisiting the height and density of sites, was part of 2023.PH3.6, but it would be good to have a public accounting that could facilitate a system-level examination. The fact that two of the three sites that were planned for ground-breaking within a year of HAF are behind may indicate that little has changed.
That said, the scale of Housing Now (along with the TCHC revitalization in Initiative 2 and Quayside in Initiative 5) does have some transformative potential. Firstly, the City is examining its current use of public land, particularly near transit, and recognizing that dense, affordable housing is a good use of this land. This is a change in mindset from just a few years ago where land was being used for low-rise libraries with no housing on top.
In addition, a large amount of non-market housing would help to apply downward pressure on prices. Also, a properly-funded public builder model could allow labour retention and continued housing supply during economic downturns. If the City retains some ownership or control over the land and units, these projects could even provide returns to the City that could be invested in future new affordable housing initiatives. This would be a fundamental change from how homebuilding currently operates. - Quayside - No. The Quayside initiative is, again, more of a specific capital project than a change to the housing system. This project includes plans for new infrastructure, but this is a reflection of the City's current growth strategy, which puts most new density into a few small areas. This necessitates infrastructure upgrades while many low-rise neighbourhoods, including some near Danforth subway stations, limit new housing and decrease in population. Although the City included some measures to increase missing middle and mid-rise forms in its HAF application (Initiative 7), some of the struggles to fund and expedite the larger high-rise initiatives reflect the challenges of Toronto's existing housing system. The City could have put more emphasis in its HAF application on transforming its previous plans and growth patterns that concentrate new residents within a few high-density areas.
- Rental Housing Supply Incentives - Yes. This specific rental incentive program only lasts as long as the funding. However, it is intended as a demonstration for an expanded program with provincial and federal contributions. In addition, the City has created a new multi-residential property class that applies to all new purpose-built rental buildings, which could shift the balance between rental and condo buildings, as well as adding to supply.
Finally, this initiative demonstrates the barrier that development charges create for housing viability. With a long-term funding agreement, this program might turn into a more general reform to development charges rather than an application-based program. The Mayor seemed open to such a possibility during the debate for 2024.CC24.16 at Council. - Missing Middle - Yes. If carried out as described, this initiative represents a series of broad reforms that could change where and how Toronto builds housing. This would allow more missing middle homes as-of-right in existing Neighbourhoods and make more mid-rise homes on Avenues feasible. It would make better use of existing infrastructure, make more land available for denser housing forms, and diversify the types of housing in Toronto. In addition, ground-related housing that can be built more quickly would be less subject to interest rate and market fluctuations, adding predictability to the housing system.
However, the City's responses to Minister Fraser's letter were reluctant to go beyond the existing Housing Action Plan. In response to a request to permit four storeys in more areas of the city, the City talked about its Major Transit Station Areas, which did not change existing low-rise land use designations and which are reliant on provincial approval. This would also apply to selected land near some subway and LRT stations but would not include any of the low-rise Neighbourhood areas that lie outside of City-delineated MTSAs.
An unwillingness to rethink the underlying system and growth patterns limits the City's ability to address other requests in the Minister's letter. For example, the City's response to a request to "commit to reducing restrictions...and rules regarding the 'no net new shadow' policy..." stated that the shadow policies are important because 89% of new units will be in buildings of 5 storeys or greater. In fact, most new units will be in high-rises, but this is itself a result of existing land use designations and design guidelines that make other housing forms less feasible: since 2010, there have been fewer than 10 residential mid-rises built per year, on average. Putting a large proportion of new units into high rises in a few designated growth centres is itself a part of the Official Plan that could be reconsidered under HAF. And one stated aim of the shadow policy - creating high quality parks near residents of dense developments - is at odds with the very fact that dense developments near parks are limited by that shadow policy!
Similarly, the City proposed very few system-level changes for high-rises despite the fact that they make up the majority of new housing under the existing system. In recent plans for Downsview and a few affordable housing proposals, the City has shown some flexibility in its 750 square metre floor plate and podium guidelines for tall buildings. HAF could have incentivized these changes in more places. The greatest potential for more streamlined approval of high-rises was likely in Major Transit Station Areas, but the limited changes proposed by the City in its submissions to the province are unlikely to result in a significant number of additional units without provincial amendments. - Apartment Infill - Yes. The initial description of this initiative in Attachment 2 of MM13.27 includes both a process to identify existing under-utilized sites that could permit more housing under the current by-law or with a site-specific rezoning, as well as an overall review of the existing Zoning By-laws. The latter has more potential for systemic change that could reduce the need for future zoning by-law amendments; site-specific rezonings for apartment infill already occur under the current system. The preliminary report suggested that the variety of existing apartment sites could make as-of-right permissions challenging, but several potential strategies are discussed. It is difficult to say how transformative the changes might be until the proposals report is available.
Is Toronto’s HAF progress competitive with other cities?
As Canada’s largest City with an increasing affordability problem, Toronto should be expected to lead the way in reforms, whether incentivized by HAF or not. Toronto’s EHON program and Housing Action Plan 2022-2026, both of which pre-dated HAF, were important steps to legalizing more housing and changing Toronto’s current approach to growth. However, many of these ideas missed their initial deadlines and then were recycled for HAF, rather than the program incentivizing new ideas. Meanwhile other, smaller cities across Canada committed to changes that were similar to what Toronto has recently done.
GTA cities like Hamilton, Burlington and Guelph committed to allowing four units per lot. Waterloo moved to allow four storeys city-wide, while Regina is allowing four storeys near frequent transit and Charlottetown is allowing four storeys near UPEI. None of those proposals appear to have been on the table before HAF, but the funding incentivized these cities to change. The exception might be Edmonton, who should be considered a leader for proactive housing policy in Canada, allowing up to three storeys and eight units in its small-scale residential zone, the culmination of a process that began in 2018 when the city recognized the need to be more flexible to accommodate new growth and a variety of housing types.
In this context, Toronto’s HAF submission appears somewhat weak, composed of a number of existing initiatives that do not appear to have been incentivized by HAF, although some initiatives were expanded. The delays and apparent reluctance to allow up to four storeys in Neighbourhood residential areas, to consider BC-style transit rezoning or to revisit shadow policies calls into question the City’s true willingness to meet the requests in Minister Fraser’s letter.
Statements from some Toronto city councillors also suggest that some parts of Council think that existing City processes are sufficient, even good, that they have not contributed to the housing crisis or worsened affordability. In particular, Councillor Perks, the Chair of Toronto’s Planning and Housing Committee stated that the idea “that the barrier to housing was in zoning by-laws and fees and fines and so on has been proven false. It has been proven utterly, utterly false.” Ultimately, all that matters for funding is that the City hits its milestones and this results in additional building permits. However, these types of statements suggest that HAF reforms may not be a priority, which could explain the delays in hitting some milestones.
If HAF is to encourage municipalities to reform their policies, then any city that declares that its long-standing processes are not to blame calls into question why they would be receiving HAF funds. A competitive HAF program must evaluate whether a good-faith effort is being made to accelerate housing, especially compared to other, smaller cities that have committed to new, broad reforms.
Where is this information from?
The information on initiatives, milestones and timelines was obtained through an Access to Information request to the federal government and a Freedom of Information request to the City of Toronto. Some important documents include:
- The final signed Housing Accelerator Fund agreement
- A copy of the HAF application submitted to CMHC on Aug 25, 2023. Note that this application was still under discussion with CMHC and does not represent final commitments. However, many milestones match those in the signed agreement but more detail is included here, which helps to identify intentions.
- The City’s description of initiatives in Attachment 2 of the item that it passed at Council, committing to the agreement
- The public letter from then-Housing Minister Sean Fraser outlining requested changes to the City’s submission
- The Work Plan from Attachment 1 of the pre-HAF Housing Action Plan 2022-2026 for comparison to HAF initiatives and milestones
Information on progress was typically obtained through searches of the City’s website and the most relevant sources are linked alongside each milestone in the detailed spreadsheet.
This is a volunteer effort to track progress on Toronto’s Housing Accelerator Fund milestones. It was limited by publicly available information and may not reflect internal progress within City of Toronto Departments that has not yet been publicly reported or that was missed in our searches. If you believe that we have missed or misinterpreted something, please contact us at volunteer@moreneighbours.ca.