Bill 16 and Bill 122
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Bill 16 and Bill 122
Two separate obligations apply to buildings in Quebec. Bill 16 is aimed at condo associations (syndicates of co-owners): a maintenance log and a contingency fund study. Bill 122 covers facades of 5 storeys or more and multi-level parking structures, whoever owns the building.
The same building can fall under both. Choose the law that applies to you, or write to us and we'll sort it out with you.
Where to start
Which law applies to your building?
Three questions are enough to find out. A building can answer yes to more than one.
- Bill 16
Your building is held in divided co-ownership
There is a syndicate of co-owners and a declaration of co-ownership. The syndicate must obtain a maintenance log and a contingency fund study, whatever the size of the building.
- Bill 122: facades
One facade has 5 or more storeys above ground
A single facade is enough. The owner, whether a syndicate or not, must have the facades inspected by an engineer or an architect: first report no later than the building's 10th anniversary, then every 5 years.
- Bill 122: parking
Your building has a multi-level parking structure
That means an underground or above-ground parking structure where at least one driving deck does not rest on the ground. The owner checks it every year, and an engineer produces a report every 5 years.
A six-storey condominium with a multi-level parking structure checks all three boxes. The obligations add up and each one has its own document, but the site visits can be coordinated.
The two laws side by side
| Bill 16 | Bill 122 | |
|---|---|---|
| Who it applies to | Every syndicate of a divided co-ownership, whatever the size of the building | The owner of a building with a facade of 5 or more storeys above ground, or of a multi-level parking structure, whether the building is a condominium, rental or commercial |
| What you need to obtain | A maintenance log and a contingency fund study | An inspection report for the facades and, where applicable, the parking structure |
| Frequency | Study every 5 years, log reviewed every 5 years (every 10 years for some small buildings) | Report every 5 years, plus a yearly check of the parking structure by the owner |
| Who can produce it | Engineer, architect, professional technologist or chartered appraiser, plus a CPA for the study | Engineer or architect for facades, engineer for parking structures |
| Deadline | August 15, 2028 for existing syndicates | First facade report no later than the building's 10th anniversary |
| Purpose | Plan maintenance and fund major work | Keep occupants and the public safe |
Still not sure? Write to us with the address, the year of construction and the number of storeys, and we'll tell you what applies to your building.
Bill 16Condominiums
Bill 16: maintenance log and contingency fund study
For every syndicate of a divided co-ownership, whatever the size of the building.
- August 14, 2025Regulation comes into force
- August 15, 2028Deadline for existing syndicates
- 25 yearsMinimum horizon of the study, reviewed every 5 years
What the law requires
Passed in 2019, Bill 16 overhauled the rules for divided co-ownership in Quebec. Its implementing regulation, published in the Gazette officielle on July 30, 2025, has been in force since August 14, 2025. It sets out what each syndicate must obtain, who can produce it and how often.
Three documents follow from it, and they don't answer the same questions.
| Document | What it contains | Frequency |
|---|---|---|
| Maintenance log | An inventory of the common components, their actual condition, their remaining service life and the maintenance program to follow. | Reviewed every 5 years |
| Contingency fund study | A projection of major work and replacements over at least 25 years, and the contributions the fund needs to pay for them. | Reviewed every 5 years |
| Syndicate's certificate | The legal and financial status of the co-ownership, given to the buyer when a unit is sold. | On request, within 15 days |
Deadlines
Syndicates whose building was already under the co-owners' control on July 15, 2025 have until August 15, 2028 to obtain their first log and their first study. In a new condominium, it's the developer who must provide them: within 30 days of the transition meeting, or within six months if that meeting took place between July 15 and November 12, 2025.
The board of directors then updates the log every year and records the work carried out. Once the study is in hand, it sets the contributions to the contingency fund within 30 days of the annual meeting. If the fund is behind, the shortfall can be made up over a period of up to 10 years.
A lighter regime for small buildings
The professional review of the log moves to every 10 years if the condominium has 8 private portions or fewer (not counting parking and storage spaces), if its common portions are not inside a building, or if the building has no more than 3 storeys fully above ground. The obligation to hold the log and the study does not change.
Who can produce these documents
The log and the study must come from a member of a designated professional order whose practice focuses mainly on the management, construction, renovation, valuation or inspection of buildings.
| Profession | Maintenance log | Fund study |
|---|---|---|
| Engineer | Yes | Yes |
| Architect | Yes | Yes |
| Professional technologist | Yes | Yes |
| Chartered appraiser | Yes | Yes |
| Chartered professional accountant | No | Yes |
The second condition is often overlooked: the professional must have no connection to the building. Neither a co-owner nor an occupant. An engineer who lives in the building cannot sign the study for their own syndicate, even as a volunteer. A document produced outside this framework does not make the syndicate compliant.
Our Bill 16 services
Contingency fund study
Inventory of components, remaining service life, indexed replacement costs and a contribution scenario over at least twenty-five years.
Maintenance log
The building's technical record: what it's made of, what condition it's in, and what needs to be done to make it last. It's what the study is built on.
Inspection and diagnosis
An on-site survey of the common portions: structure, building envelope, roof, balconies, parking, drainage. Without it, the study rests on assumptions.
Support for the syndicate
Presentation of the results to the board and at the general meeting, explanation of the contribution scenarios, answers to co-owners' questions.
What you receive
- The contingency fund study meeting the content required by the regulation, with a projection over at least twenty-five years.
- The complete maintenance log, organized so the board can update it every year without calling us back.
- Contribution scenarios, showing the effect of each one on condo fees and on the fund balance, year by year.
- A summary for the general meeting, written for co-owners, not for engineers.
Bill 16 FAQ
I'm a co-owner: what does this change for me?
Your monthly fees are likely to go up, and that's the point. The study sets out what needs to be put aside each year so that major work is paid for when it comes due. A well-funded reserve lowers the risk of a special assessment at the worst possible time, and an informed buyer looks at the state of the fund before making an offer.
I sit on the board of directors: what are my responsibilities?
Have the documents produced on time, keep the log up to date every year and adjust the budget to the path set by the study. A board that neglects these obligations can be held liable by the co-owners. A study that is ordered and then filed away, with no effect on contributions, protects no one.
I manage several buildings: where should I start?
With the oldest buildings and those with the thinnest records, because they will need the most survey time. We can scope several buildings together and spread out the visits, which simplifies logistics and keeps the same method from one file to the next. The worst-case scenario is ordering everything in the same year, in 2028.
I'm buying a unit: what documents should I ask for?
The syndicate's certificate, which the syndicate must provide within fifteen days of the request. Also ask for the contingency fund study and the maintenance log if they already exist. What you're looking for is the gap between the fund's current balance and what the study recommends. A large gap means higher fees or a special assessment is coming, and that is something you can negotiate.
If the building has 5 or more storeys, also ask for the latest facade inspection report (Bill 122).
Our building is small. Does this still apply to us?
Yes. The obligation to hold a maintenance log and a study applies to every divided co-ownership, whatever its size. What changes for the smallest ones is the frequency: condominiums with 8 private portions or fewer, those whose common portions are not inside a building, and those with no more than 3 storeys fully above ground have their log reviewed every 10 years instead of every 5.
What exactly goes into the maintenance log?
An inventory of each common component with its actual quantity, its observed condition, its remaining service life and the maintenance needed to reach it. It also includes the history of work done, which the board adds to over the years. It isn't a cleaning schedule: it's the building's technical reference document, and it's what the fund study rests on.
Does your syndicate need to comply with Bill 16? Tell us the year of construction, the number of units and the documents you already have. We'll get back to you with a proposal suited to your building.
Bill 122Facades and parking structures
Bill 122: facade and parking structure inspections
For any owner, whether a syndicate or not, of a building with a facade of 5 or more storeys above ground, or of a multi-level parking structure.
- 5 storeysHeight above ground that triggers the facade inspection
- 5 yearsFrequency of the inspection report
- Every yearParking structure check by the owner
What the law requires
The name “Bill 122” stuck, but the requirements are found in the Building chapter of Quebec's Safety Code, which the Régie du bâtiment du Québec (RBQ) enforces. Unlike Bill 16, they don't stop at condominiums: every owner of a covered building must comply, whether the building is rental, commercial or held in co-ownership.
They cover two specific structures, under two separate regimes.
| Facades | Multi-level parking structure | |
|---|---|---|
| Buildings covered | At least one facade of 5 or more storeys above ground | Underground or above-ground parking structure with at least one driving deck that does not rest on the ground |
| Yearly check | Not required as such | Yes, by the owner, with photos |
| Professional report | Every 5 years, by an engineer or an architect | Every 5 years, by an engineer |
| First report | No later than the building's 10th anniversary | According to the applicable schedule |
| Register | Mandatory: reports and work carried out | Mandatory: yearly checks and reports |
Facades: counting storeys
The test is applied by counting the storeys above ground level. The basement doesn't count, and a single facade is enough for the whole building to be covered. On a sloping lot, the tallest facade decides, which is common in Montreal.
The report states whether the facades show an unsafe condition and recommends the work to be done, with a schedule. It goes into the register, along with a description of all work done on the facades. Projecting balconies and guardrails are among the elements examined.
Parking structures: two obligations, not one
The first falls to the owner: every year, a visual check of the slabs, walls, beams, columns and joints, with any anomalies noted and photographed in the register. The second requires an engineer, who inspects the parking structure and produces an inspection report every 5 years. Many syndicates only discover the second one after taking care of the first.
Between two reports, an anomaly found during the yearly check (spalled concrete, exposed rebar, water infiltration) is reason enough to call an engineer without waiting for the deadline.
If an unsafe condition is found
An unsafe condition can't wait
When a professional finds an element likely to come loose, or a part of the structure whose capacity is no longer assured, two obligations apply immediately: secure the area and report the situation to the Régie du bâtiment without delay. That can mean protective scaffolding or a closed-off parking area while the corrective work is done.
Our Bill 122 services
Inspection of facades, 5 storeys and up
The inspection report required by the Safety Code, with a close-up examination of the risk areas. First report no later than the building's tenth anniversary, then every five years.
Multi-level parking structure inspection
The engineer's report required every five years: examination of the driving decks, beams, columns and joints, with the recommended work and its schedule.
A six-storey building with a multi-level parking structure is covered twice, with two schedules and two reports. Whenever possible, we coordinate these inspections, along with the maintenance log visit if the building is a condominium.
What you receive
- The facade inspection report, signed and sealed, with located observations and recommended work.
- The parking structure inspection report, with the condition of the driving decks and the schedule for the recommended repairs.
Bill 122 FAQ
Our building has five storeys: are we subject to the facade inspection?
Yes, as soon as a single facade has five or more storeys above ground level. The basement isn't counted. On a sloping lot, the tallest facade decides, and that's a common situation in Montreal: a building that looks like four storeys from the front can have five at the back.
The first inspection report is required no later than the tenth anniversary of construction, then the five-year cycle begins. Between two reports, the register must be kept up to date and any work done on the facades must be recorded in it.
Is our underground garage a multi-level parking structure?
It is if at least one driving deck does not rest on the ground, for example a deck where vehicles drive above another level. A garage whose only driving surface rests directly on the ground generally doesn't fit the definition. If in doubt, an engineer can decide from the plans or during a visit.
Who can sign the inspection report?
For facades, an engineer or an architect. For a multi-level parking structure, an engineer. The report describes the observed condition, the defects found and the recommended work. It then goes into the building's register.
What should we do if the report flags an unsafe condition?
Secure the area without delay, for example with a safety perimeter, scaffolding or by closing part of the parking structure, and notify the Régie du bâtiment du Québec. The corrective work follows, based on the professional's recommendations.
Further reading
Is your facade or parking structure report coming due? Tell us the year of construction, the number of storeys and the date of the last report. We'll get back to you with a proposal suited to your building.
Method
Our approach
For Bill 16 and Bill 122 alike, everything starts with an on-site survey. Here's how we proceed.
- Gathering documentsPlans, previous reports, the building register, invoices for work, meeting minutes that mention repairs. It's often the longest step, and the one where the board or the property manager can save us the most time.
- Technical visit of the buildingSurvey of the common portions: roof, building envelope, masonry, balconies, parking, drainage, building mechanical systems. For Bill 122, the facades and the parking slabs are examined up close, where defects tend to hide.
- Inventory and actual conditionEach component is measured in actual quantities and assessed by direct observation, never from the age shown on the plans. Two roofs of the same age are not at the same point.
- Analysis and reportsFor the study: remaining service life, replacement cost at today's prices and indexing to the year the work is planned. For Bill 122: observed conditions, recommended work and schedule.
- Presenting the resultsWe explain the conclusions to the board and, if you wish, at the general meeting: contribution scenarios for Bill 16, work priorities for Bill 122. A study nobody understands changes nothing in the budget.
General questions
Both laws at once
The questions that come up when a building falls under both regimes.
What's the difference between Bill 16 and Bill 122?
Bill 16 is aimed at condo syndicates. It requires a maintenance log and a contingency fund study to plan upkeep of the common portions and fund major work. Bill 122 is about safety: it requires periodic inspection of facades of 5 or more storeys and of multi-level parking structures, whoever owns the building. A condominium can be covered by both.
Our building isn't a condominium. Are we covered?
Not by Bill 16, which only concerns divided co-ownerships. However, if a facade has 5 or more storeys above ground, or if the building has a multi-level parking structure, the Bill 122 obligations apply, whether the building is rental, commercial or institutional.
Can we handle Bill 16 and Bill 122 at the same time?
Yes, if the building is covered by both. The maintenance log visit and the facade or parking inspections can be scheduled together. Each obligation still keeps its own document: the log and the study on one side, the inspection report on the other.
Guides
Further reading
Our detailed guides, to dig deeper into each obligation.
Bill 16: understanding the contingency fund study and the maintenance log
The three required documents, how a 25-year projection is built, the costly mistakes and the key dates.
Bill 122: facade and parking structure inspections in Quebec
The buildings covered, what we look for on a facade, what an unsafe condition means and how an inspection unfolds.
Balconies and guardrails: warning signs, inspection and repair
The warning signs, what the rules say, and when to repair rather than replace.
Structural inspection in Montreal: what an engineer checks and what they can conclude
What the engineer looks at and in what order, what the report contains, and what an inspection cannot tell you.
Next step
Tell us about your building
We'll tell you what still needs to be produced for Bill 16 and Bill 122, in what order, and how much time to allow. To speed things up, have the following on hand:
- the address and the year of construction;
- the number of units and the number of storeys above ground;
- whether there is an underground or multi-level parking structure;
- existing documents: log, previous study, facade or parking reports;
- the date of your next general meeting, if applicable.
- Firm
- GC4I Inc., structural engineers
- Office
- 8350 Christophe-Colomb Avenue, Suite 18, Montreal
- Service area
- Montreal, South Shore, North Shore and across Quebec
- contact@gc4i.ca
This page presents the regulatory framework that applies in Quebec as of its last update. It does not replace a review of your declaration of co-ownership or legal advice.