Ontario Bill 98: What Developers Need to Know

Ontario’s Building Homes and Improving Transportation Infrastructure Act (Bill 98) is the latest step in the Province’s push to accelerate housing and infrastructure delivery.

On paper, the goal is simple:
➡️ faster approvals, better coordination, and fewer delays

But from a development engineering perspective, the real impact is more nuanced.

What Bill 98 Is Trying to Do

Bill 98 builds on previous legislation aimed at:

  • Reducing approval timelines

  • Streamlining municipal review processes

  • Aligning housing with infrastructure delivery

For developers, this signals a continued shift toward faster decision-making environments.

What It Will NOT Change

Despite the focus on speed, Bill 98 does not remove:

  • Sewer capacity constraints

  • Water supply limitations

  • Stormwater management requirements

  • Environmental and regulatory controls

👉 In other words:
approvals may move faster, but infrastructure limitations still govern what can be built

How Municipalities Are Already Responding

Even before the legislation is finalized, municipalities are adjusting internally.

Key trends include:

1. Stronger Upfront Scoping (PAC Stage)

Municipal teams are placing more emphasis on early-stage meetings to:

  • Define requirements clearly

  • Reduce ambiguity in submissions

  • Avoid rework later

2. Fewer Review Cycles

There is increasing pressure to:

  • Limit applications to 2 circulation rounds or less

  • Escalate files that stall

👉 This means less tolerance for incomplete or evolving submissions.

3. More Targeted Comments

Review comments are shifting toward:

  • Clear, actionable requirements

  • Reduced advisory or “nice-to-have” feedback

4. Reduced Pre-Approval Conditions

Municipalities are focusing on:

  • Essential approvals only (agreements, securities, conveyances)

  • Deferring non-critical items

What This Means for Developers

Bill 98 does not eliminate risk — it repositions it.

Before:

  • Issues could be resolved gradually through multiple review cycles

Now:

  • The burden shifts earlier in the process

How to Stay Ahead

Developers who move efficiently under this new environment will:

  • Confirm servicing capacity early

  • Identify constraints before design

  • Submit complete and coordinated packages

  • Reduce reliance on iterative review

Final Insight

The projects that move fastest under Bill 98 will not be the ones relying on faster approvals —
they will be the ones best prepared from the start.