Anonymised, illustrative composite. A mid-sized Ontario rental portfolio was taking, on average, 26 days to re-lease a vacated suite — and most of that time was spent on an applicant-screening process that was quietly out of step with the Human Rights Code.
At a glance
A vacated suite went through the same sequence every time: post the listing, collect applications, then work through them one at a time, asking each applicant for income proof first. Only applicants whose income “looked strong enough” were asked for the rest — rental history, references, a credit check. Weaker-looking applicants on income alone were quietly moved to the bottom of the pile without ever being asked for anything else.
That sequence felt efficient — why chase paperwork on an applicant likely to be declined anyway — but it was also adding days to every turnover, because a leasing agent could spend two or three rounds working through applicants before finding one whose full file actually cleared.
The sequence was also not what the rules actually allow. the Ontario Human Rights Commission is explicit that a landlord “can ask for income information, but they must also ask for and consider together any available information on rental history, credit references and credit checks” — income cannot be the first filter with the rest as a formality. The same policy states plainly that “income information can only be considered on its own when no other information is made available,” and that “it is illegal for housing providers to apply a rent-to-income ratio such as a 30% cut-off rule.”
One rejected applicant in the file review had strong rental history and solid references but a thin Canadian credit file — exactly the profile the same OHRC policy protects: “a lack of rental or credit history should not be viewed negatively.” She had been screened out on income timing alone, before anyone looked at the rest of her file at all.
Across the four buildings, the leasing team logged 71 vacancy turnovers over two prior quarters at an average of 26 days each. Of those, 44 took more than one screening round — meaning the first applicant considered was not the one who ultimately signed — and the extra rounds accounted for most of the added time, not the physical make-ready work on the unit itself, which averaged a stable 4 days across the whole portfolio.
The physical side of turnover — cleaning, paint touch-ups, a lock change — was never the bottleneck. The applicant pipeline was.
Breaking the 44 multi-round turnovers down further, 29 of them needed a second round only because a strong applicant had been passed over on the income-first filter before their rental history was ever requested — not because the eventual tenant was genuinely a stronger applicant, but because the process had never asked for the fuller picture on the first pass.
Reg. 290/98 does not just prohibit specific bad outcomes; it structures how the request has to happen — income, rental history and credit references requested and reviewed as one package, on one pass, for every applicant. A sequential, income-first process is not simply less efficient than that; it is a different process the regulation does not permit, and it produces exactly the kind of round-by-round delay this portfolio was seeing.
That structure is not just OHRC guidance interpreting the Code — it is the regulation’s own operative text: O. Reg. 290/98, s.1(3), made under the Human Rights Code, provides that “a landlord may request income information from a prospective tenant only if the landlord also requests information listed in subsection (1)” — rental history, credit references and credit checks — and s.1(4) permits considering income only together with that other information. For how this can go wrong even without an income-first sequence, see this Lindsay screening-rule complaint.
The leasing team switched to a single application packet requesting all three categories — income, rental history, credit reference — from every applicant up front, reviewed together once a complete file came back. Measured over the following two quarters, average vacancy-to-lease time fell from 26 days to about 13, roughly half of what it had been.
The applicant with the thin credit file, screened the compliant way on her next application to the portfolio, was approved within the standard review window. For how the same portfolio handles applicant communication and lease renewal timing once a tenant is in place, see AI-assisted tenant screening in Canada and how portfolios are managing lease renewals with AI.
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