An accessibility request from a tenant is the start of a process you have to run, not a favour you grant or refuse. The tenant does not have to use the word accommodation, put the request in writing, or name a law. Once you know a tenant has a disability-related need, the duty to accommodate is live, and how you handle the next two weeks matters as much as what you install.
The requests look like this: a grab bar in a bathroom, a buzzer a tenant cannot hear, a parking spot too far from the entrance, a round door knob an arthritic hand cannot turn.
This duty sits above your repair obligations
Human rights law and tenancy law are separate systems, and the first one wins. Section 2(1) of Ontario's Human Rights Code gives every person the right to equal treatment with respect to the occupancy of accommodation, with disability as a protected ground, and section 47(2) gives the Code primacy over other Ontario Acts. In British Columbia, section 10 of the Human Rights Code reaches the terms and conditions of a tenancy, and the Human Rights Tribunal describes the duty as taking all reasonable steps to avoid a negative effect based on a protected ground.
A repair schedule that meets your provincial maintenance standard can still leave you on the wrong side of a human rights complaint. Clearing the maintenance queue is not a reply to this request.
Step 1: Log the request the day it arrives
Write down the date, who made the request, what the tenant said in their own words, and what they asked for. The Ontario Human Rights Commission tells housing providers to keep a record of requests and the actions taken, and to accept a request in good faith unless there is a legitimate reason not to. Going quiet is its own problem: delay in responding can breach the Code even where you eventually say yes.
Put a reply date in the file: three business days to acknowledge is a reasonable internal standard and it costs nothing.
Step 2: Ask about function, not diagnosis
This is where most requests go wrong. You may ask for confirmation that the person has a disability, the limitations or needs that come with it, whether they can meet the essential requirements of the tenancy with or without accommodation, and what kind of accommodation is needed. You may not demand the diagnosis, the cause, the symptoms or the treatment. The OHRC's position on medical documentation puts the focus on functional limitations rather than the label, and any request for more has to be the least intrusive one that still lets you decide.
A line that works: "I do not need your diagnosis. I need to know what you cannot do in the unit as it stands and what would change that, and a note from your health care provider confirming the need is enough."
One detail that catches managers out: the housing provider carries the cost of the documentation it asks for. If you require a letter, you pay for the letter.
Step 3: Bring three options, then consult
There is no formula for this. The OHRC treats accommodation as individualized, which means you assess this tenant's need rather than apply a building policy. The workable version is to develop three options before you meet: the ideal fix, an interim fix you can do this week, and the next-best permanent option if the ideal one turns out to be unreachable.
For the round door knob, that might be lever handles in the unit and on the common doors of that floor, a clip-on lever adapter in the meantime, and the entrance hardware added to the next capital cycle. Bring the options and then consult on them. The OHRC is explicit that the process counts as much as the accommodation itself, so the consultation is not a formality.
Transferring the tenant to a different unit is a real option when the tenant wants it, and a poor default when they do not.
Step 4: Price it against the only three factors that count
If you want to refuse, you are held to the undue hardship test, and section 11(2) of the Code names the entire list: "the cost, outside sources of funding, if any, and health and safety requirements, if any." Nothing else is on it.
That rules out most of the reasons refusals get written. Inconvenience is not a factor. The preferences of other tenants are not a factor. A building budget already committed for the year is not a factor either, because cost is weighed across your whole operation and net of savings, not against one property's remaining line item. The burden also sits with you: the OHRC requires evidence that is objective, real, direct and, in the case of cost, quantifiable. A quote beats an opinion.
Note the middle factor, outside sources of funding. Before you argue a modification is too expensive, check whether a provincial or municipal home modification program would cover part of it. Not having looked is a weak position to defend.
Step 5: Write the decision down with four things in it
Whatever you land on, the file needs four items: what was requested, what you are doing and by what date, who pays for the work and who maintains it afterward, and what happens to the modification when the tenancy ends. That last item heads off an argument two years later about whether a ramp or a bar comes back out.
If the ideal fix would genuinely cause undue hardship, the duty does not stop there. You record the next-best measure you are putting in place instead, and the date you will revisit it.
Step 6: Split the file
Health information belongs in a separate, access-restricted file, not the tenancy file your leasing staff open every day. The contractor needs a work order and an entry notice, not the reason for the work.
The three ways this goes wrong
- Asking for a diagnosis, which turns a hardware conversation into a privacy complaint.
- Going silent, which is the easiest failure to prove, because the gap sits on the record in your own timestamps.
- A flat refusal priced on a feeling, with no quote, no funding check and no next-best offer attached.
None of those are hard to avoid. They happen because the request lands in a busy week and gets handled as a maintenance ticket rather than a decision that has to hold up later. Run it as a decision and the file defends itself.