The Smoke and CO Alarm Playbook for Ontario Rentals

Count the alarms before you test anything

Most alarm failures found by an inspector are a counting problem, not a testing problem. Work out how many devices each unit is required to have, then go and test what should be there instead of what happens to be on the ceiling.

Smoke alarms are the settled half. Ontario requires a working smoke alarm on every storey and outside all sleeping areas, and that has not moved.

Carbon monoxide alarms moved this year. Under O. Reg. 87/25, which amended the Fire Code effective January 1, 2026, a residential occupancy containing a fuel-burning appliance, a fireplace or an attached garage needs a CO alarm adjacent to each sleeping area and a CO alarm on every storey, including storeys with no bedrooms on them. Run that against a townhouse with a basement, a main floor, a second floor and a gas furnace. It used to need one alarm, outside the bedrooms. It now needs three.

Two groups get missed because the tenant has no fuel-burning appliance of their own. Ontario's guidance also captures units sitting directly above, below or beside a service room or a garage, and units heated by air drawn from a fuel-burning appliance located elsewhere in the building. The genuine exemption is narrow: a unit running entirely on electricity, with no fuel-burning appliance and no attached or adjacent garage.

The penalty side is not small. Ontario fire services describe fines reaching $50,000 and up to a year in jail for an individual under the Fire Protection and Prevention Act. The more common cost is quieter: an inspector asks for last year's records and you have a working alarm with nothing behind it.

Four moments that require a test

The Fire Code names the triggers, and only one of them lives on a calendar. A landlord tests:

• Once a year, in every unit.
• On every change in tenancy, before the incoming resident takes possession.
• After the battery is replaced in a battery-operated alarm.
• After any change is made to an electrical circuit an alarm is connected to.

The last two are the ones that vanish, because they happen inside somebody else's job. A turnover crew swaps batteries on their way out. An electrician replaces a breaker and goes home. Both leave you with untested alarms and no record, and neither person thought they were doing alarm work. Put the test on the work order rather than on your memory, and make the trade sign the same line your own staff sign.

Run the test the same way every time

1. Read the replace-by or manufacture date on the back of the device before you touch the button. Alarms carry a service life set by the manufacturer, and an expired unit does not meet the requirement even when it beeps.
2. Check the mounting. Painted over, taped over, hanging off one screw or sitting in a kitchen drawer all count as not installed.
3. Hold the test button until the horn sounds properly. A single chirp is not a pass.
4. Step outside the closed bedroom door and confirm you can hear it from there. That is the whole point of the device, and it is the step nobody performs.
5. On interconnected alarms, confirm the others sound too. If one stays silent, the fault is in the interconnection, not in the alarm you pressed.
6. If you changed the battery, test again afterwards. A test taken before the battery change does not cover the battery change.

The log line to copy

Records are the part people improvise, and improvised records are the ones that come apart under questioning. Use identical fields every time, one row per device, not one row per unit:

• Date and time of the test
• Unit, and the specific position of the device: second floor hall, basement stair, kitchen ceiling
• Device type: smoke, CO, or combination
• Replace-by date printed on the device
• Reason for the test: annual, change of tenancy, battery, electrical work
• Result, and where it failed, what you did and on what date
• Name of the person who ran it

Keep the records at the building they relate to. The Fire Code's general records rule sets a floor of two years, and requires you to hold at least the most recent and the immediately preceding record of a given test. In practice that means you never bin last year's log until this year's is complete for the whole property, including the units you had to chase.

Two entries your log has to handle

Nobody was home. An attempted test is still an entry. Record the date, the notice you served, the outcome, and the date of the next attempt. In Ontario you need 24 hours written notice to enter and the entry has to fall between 8 a.m. and 8 p.m. A unit you could not get into is a scheduling problem you can evidence. A unit with no row at all reads as a unit you skipped.

The alarm was gone. Removed devices and pulled batteries are common, and the Fire Code makes it an offence for an occupant to disable an alarm. That does not move the duty off you. Replace it the same day, log the replacement, and hand the instructions back to the resident in writing. Where it happens twice in one unit, the fix is usually a sealed long-life battery or moving the device off the cooking path, not a third letter about tampering.

What the resident gets

Give every resident a copy of the manufacturer's maintenance instructions for each alarm in their unit, and keep proof you handed them over. It costs nothing at move-in and it is awkward to reconstruct two years later. Pair it with the only instruction that matters between your visits: tell us the day it starts chirping, and do not take it down.

Once the counting is right and the log has the same seven fields in it every time, this stops being an annual scramble and becomes twenty minutes per unit. The alarm keeps people alive. The log is the only thing that proves you did your part.