Supportive Housing Providers Have Until October 26 to Act

Urgent Action Required: Supportive Housing Providers Have Until October 26, 2026 to Unilaterally Amend Tenancy Agreements

October 15, 2026 | Authored by Nazanin Kousha and James Struthers


If you operate supportive housing in British Columbia, your organization has until October 26, 2026 to unilaterally amend provisions of your supportive housing tenancy agreements respecting:

  1. access to a rental unit for health and safety reasons;

  2. occupants and proposed occupants;

  3. guests; and

  4. possession of weapons.

In order to do so, your organization needs to prepare and serve on existing supportive housing tenants a new residential tenancy form called an RTB-60 before October 26, 2026.

Supportive housing providers should also update their supportive housing tenancy agreement templates to:

  1. include the new standard terms applicable only to supportive housing units;

  2. remove inapplicable standard terms;

  3. add terms respecting:

    1. health and safety standards;

    2. occupant and guest restrictions;

    3. access to rental units for health and safety reasons;

    4. prohibiting possession of weapons;

    5. updates to crime-free addenda; and

    6. other revisions to reflect the amendments set out in Bill 11 and recently enacted regulations implementing Bill 11.

Our team has capacity to assist supportive housing providers with preparing and issuing RTB-60s and updating supportive housing tenancy agreements in line with Bill 11. 

Should you require any assistance, please reach out to James Struthers at james@coalharbourlaw.ca. 

Additional information regarding Bill 11 is provided below for background.

SUMMARY OF BILL 11


Enactment

Bill 11, the Residential Tenancy Amendment Act, 2026 (“Bill 11”), passed third reading and received Royal Assent on April 16, 2026. It adds a new division to the British Columbia Residential Tenancy Act (the “RTA”) with special provisions for supportive housing, aimed at improving safety for the people who live and work in these buildings while keeping tenant protections in place.

Purpose of Bill 11

The purpose of Bill 11 is to improve health and safety in supportive housing in a manner that is cost effective and efficient for supportive housing providers. The Honourable Christine Boyle opened her introduction of Bill 11 in the B.C. legislature on March 4, 2026, with the following statements:

“I move that the bill be introduced and read a first time now. I’m pleased to introduce the Residential Tenancy Amendment Act. This bill achieves a key legislative outcome. Bill 11 proposes amendments to the Residential Tenancy Act to improve health and safety in supportive housing. 

Through increased investment in supportive housing, more British Columbians have come indoors from encampments or have avoided homelessness altogether. We’ve also been able to support people with more complex needs. At the same time, supportive housing providers have experienced challenges related to rare but serious safety incidents, including problematic guests and tenants who may pose a risk to the well-being of others. 

Based on insights from engagement that began in summer 2025, changes are being proposed that strike the right balance between effectively promoting safety in supportive housing and maintaining protections under the RTA for people who call supportive housing home. Everyone deserves a safe place to live and work. To achieve this, the right tools are needed.

This bill will create provisions tailored to the operational realities of supportive housing, including addressing urgent challenges related to weapons and de-escalation of serious health and safety risks. Beyond supportive housing, amendments will also strengthen existing eviction provisions to better protect guests and workers across all forms of rental housing. 

Finally, the amendments will clarify the jurisdiction of the RTA related to transitional housing. This bill is a significant step toward improving safety and stability for people who live and work in supportive housing.”

Bill 11 also furnishes the BC legislature with regulatory powers which allow policy initiatives respecting health and safety in supportive housing to be deployed by regulation, increasing government’s ability to respond to sector realities flexibly and in a more time sensitive manner.

Regulations and In Force Dates

Most of the provisions of Bill 11, as well as the Residential Tenancy (Supportive Housing) Regulations, B.C. Reg 143/2026, were brought into force on July 23, 2026 by Order in Council 355-2026. The remaining sections, primarily those related to weapons, along with additional provisions of the New Regulations respecting weapons come into force effective December 1, 2026 under Order in Council 357-2026.

Summary of Amendments

Definition of Supportive Housing

For the first time, the RTA spells out what a supportive housing rental unit is. All four of these must apply:

  • The building is operated by a supportive housing operator.

  • The tenant has been assessed as experiencing, or at risk of, homelessness and as someone who would benefit from housing stability support.

  • Housing stability support is available to at least one tenant of the unit.

  • The unit is not provided on a temporary basis.

Transitional Housing

Transitional housing is defined separately and stays outside these rules. Bill 11 also lets the government set special rules for amending supportive housing tenancy agreements, including an exception to the usual requirement that landlord and tenant both agree to a change. That exception is what opened the current window.

Standard Terms

As of July 30, 2026, a new set of standard terms applies to every supportive housing tenancy agreement, new or existing, however, some of the standard terms are only effective from and after December 1, 2026. As such, the wording of the RTB-60s and any amendments to existing tenancy agreements, as well as new tenancy agreement terms, must be worded carefully to ensure no rights are truncated during the period from issuance of an RTB-60 until December 1, 2026.

Most standard terms are unchanged. The key changes are summarized below. The changes respecting weapons, access restrictions and landlord entry take effect on December 1, 2026:

  • Unilateral Amendments.  Supportive housing providers can unilaterally amend certain tenancy agreement provisions within certain specified windows of time.

  • Plain Language and Font Size.  Supportive housing tenancy agreements are subject to new rules respecting font size and readability.

  • Weapons. Landlords can apply to the Residential Tenancy Branch to end a tenancy where a tenant, or someone the tenant or an occupant let onto the property, possessed a weapon there, or where the landlord, while reasonably exercising a right or performing an obligation under the RTA or the tenancy agreement, saw a weapon in plain view in the unit.

  • Access restrictions. In circumstances set by regulation, landlords can temporarily restrict a tenant’s access to all or part of the property.

  • Landlord entry. The landlord can enter a unit only in limited circumstances: in an emergency, with the tenant’s permission, if the unit has been abandoned, under an order of the Residential Tenancy Branch or a court, to provide housekeeping or related services, for a purpose set out in a reasonable term of the tenancy agreement, or for another reasonable purpose with 24 hours’ to 30 days’ written notice. This is why your entry and wellness-check terms matter.

Tenancy agreement should be revised to clarify the landlord’s expanded rights.

Other Changes

Bill 11 also broadens existing grounds for ending a tenancy to protect any “authorized person” on the property, such as staff, contractors and health-care workers. It also lets the government set, by regulation, a minimum amount of compensation landlords must pay tenants for breaking certain rules. From December 1, 2026, the Residential Tenancy Branch must award at least that amount wherever one has been prescribed. As noted above, government can now make significant changes to supportive housing tenancies by regulation. Supportive housing providers should subscribe to governmental updates regarding supportive housing to ensure they keep apprised of regulatory reform on an ongoing basis.

WHAT YOU CAN CHANGE BEFORE OCTOBER 26

From July 30 to October 26, 2026, supportive housing providers can add, change or remove certain non-standard terms in existing tenancy agreements without tenant approval. This is a one-time window. It covers two kinds of changes.

1. Terms about entry, occupants and guests. You can update terms dealing with:

  • Landlord entry into a unit for the tenant’s health or safety, including wellness checks.

  • Occupants, for example requiring landlord approval before someone new moves in.

  • Guests, for example how many can visit at once and at what times.

The Regulation doesn’t prescribe the wording for these terms, so you can tailor them to your building and your tenants. These changes take effect 30 days after the tenant is considered to have received your notice.

2. Terms that conflict with the new rules. You can also change or remove any existing term that conflicts with the new provisions on landlord entry or weapons. These changes take effect on December 1, 2026.

Whatever you add must still be enforceable. A term won’t hold up if it is inconsistent with the RTA or its regulations, is unconscionable, or doesn’t clearly explain each party’s rights and obligations.

HOW YOU MAKE THE CHANGES: FORM RTB-60

Every change must go in Form RTB-60: Notice of Amendment to Tenancy Agreement for Supportive Housing Rental Unit. Section 2 of the form covers entry, occupant and guest terms; Section 3 covers terms that conflict with the new rules. 

If a tenancy began before July 30, 2026, the first RTB-60 you give that tenant must attach Appendix A, which sets out the new standard terms. Serve the notice using an approved method of service and keep proof that it was done properly.

If you need to cancel an amendment before it takes effect, use Form RTB-61: Notice of Rescission (Cancellation) of Amendment to Tenancy Agreement for Supportive Housing Rental Units.

You can give a tenant more than one RTB-60 before October 26 to add terms or adjust earlier amendments. And for tenancies that start between October 27 and November 30, 2026, you can still use RTB-60 to change or remove conflicting terms, as long as you give it within 21 days of signing the agreement.

UPDATE YOUR TENANCY AGREEMENT TEMPLATE TOO

Bill 11 and the New Regulations include quite significant changes to the supportive housing regulatory regime in B.C. In particular, supportive housing is now in a tenancy class of its own. Tenancy agreements for supportive housing should be updated to reflect these recent developments, and periodically revisited as regulatory updates continue.

Operating Agreements

Many operating agreements with BC Housing are also not being renewed. Supportive housing providers are not permitted to end tenancies when these operating agreements renew, and ensuring the provider has the tools available in order to increase rent to sustain operations, and do so in a way that mitigates risk of litigation, is essential to preparing for operating agreement expiry.

YOUR COUNTDOWN CHECKLIST

Work through these steps now, and leave yourself room for service before October 26.

  • Confirm you’re covered. Check each unit against the four-part definition above. Transitional housing and emergency shelters aren’t covered.

  • Review your current tenancy agreements. Flag any terms on entry, wellness checks, occupants or guests, and anything that conflicts with the new weapons and entry rules.

  • Decide what you want your terms to say. Draft clear, property-specific terms for staff entry, occupants and guest management.

  • Prepare Form RTB-60 for each tenant. Set out every term you’re adding, changing or removing, and attach Appendix A if the tenancy began before July 30, 2026. This is a significant opportunity for providers to improve their ability to manage their supportive housing units, and while limited, the New Regulations give supportive housing providers significant latitude to amend their existing tenancy agreements. RTB-60s should be very carefully worded to avoid unintentional consequences and mitigate the risk of administrative penalties provided for in the New Regulations. Supportive housing providers can easily miss out on this important opportunity to improve their ability to manage health and safety in their supportive housing developments, or increase their risk of administrative penalties or unintentionally invalidating existing tenancy agreement terms, with inappropriately worded RTB-60s.

  • Serve the RTB-60 on every tenant using an approved method, and keep a record of how and when each was served. What counts is the date you give the notice, not the date it’s deemed received, but a notice given even a day late is invalid. Remember Section 2 changes only take effect 30 days after deemed receipt (a mailed notice, for example, is deemed received on the fifth day).

  • Update your tenancy agreement template for new tenants so it matches the new standard terms and your amended terms.

  • Brief your staff on the new terms and the December 1 changes to entry, access restrictions and weapons.

WHAT HAPPENS IF YOU MISS IT

After October 26, 2026, you’ll need each tenant’s written approval to change non-standard terms in their tenancy agreement, unless the law otherwise allows it. In practice, that means:

  • Tenant-by-tenant negotiation. Any update to entry, occupant or guest terms depends on each tenant agreeing in writing. 

  • Inconsistent rules in one building. Tenants who signed before and after your update could be living under different terms, which is hard for staff to manage and enforce.

  • Outdated terms that may not hold up. Old terms that conflict with the new standard terms can be unenforceable, leaving gaps you thought were covered.

  • Less clarity for staff on December 1. The new entry and weapons rules arrive either way. Without updated agreements, your staff and tenants may be unclear about what applies.

An RTB-60 given after October 26 is not valid, and its amendments never take effect. The new standard terms themselves apply automatically. What you lose is the chance to shape the terms that are specific to your property.

HOW WE CAN HELP

We have capacity to take on supportive housing clients before the October 26 deadline, and we’re happy to help. We can:

  • Review and update your supportive housing tenancy agreement.

  • Draft entry, occupant and guest terms that fit your property and are written to be enforceable.

  • Populate Form RTB-60 for your tenants using automations technology.

  • Provide administrative and automation support to prepare and serve RTB-60s on supportive housing tenants.

  • Guide you through serving the notices and keeping the right records.

If you need support, reach out to James Struthers, Partner, at james@coalharbourlaw.ca as soon as possible. 

HELPFUL RESOURCES

James Struthers

James Struthers advises non-profits, charities, corporations, and First Nations on a broad range of corporate, commercial, real estate, governance, construction, development, employment, financing, tenancy, workplace, and regulatory matters.

While James maintains a general solicitor practice, he has focused experience in the First Nations housing and infrastructure, affordable housing, construction and development, non-profit and charities, and impact enterprise sectors. He regularly advises on:

  • Aboriginal law;

  • complex real estate developments both on and off reserve;

  • financing and funding arrangements;

  • governance matters;

  • charities compliance;

  • affordable housing tenancy matters;

  • mergers and acquisitions;

  • commercial agreements;

  • workplace matters; and

  • commercial advisory services.

Prior to joining the Coal Harbour Team, James has practiced in small firm, national firm, and midsized firm environment, where he advised public companies, private enterprises, Indigenous organizations, and non-profit entities on a variety of corporate, commercial, regulatory, and real estate matters. Having served clients of varying size, on matters of varying complexity, and in varying practice environments, he can capably serve clients no matter the size of organization, and tailor services to the clients’ needs and budget.

James served as a Bencher of the Law Society of British Columbia from 2024 to 2026. In that role, he participated in the governance of the legal profession in the public interest and served on a number of committees relating to access to justice, practice standards, finance, audit, and professional conduct.

He is also a regular mentor to articling students and early-career lawyers and has contributed extensively to pro bono initiatives, legal education programs, and community organizations.

James has delivered presentations on governance, housing, asset management, corporate law, and legal issues affecting First Nations, charities, and non-profit organizations. He has also served as an instructor and supervising lawyer with community-based legal programs focused on increasing access to justice.

James holds a Juris Doctor from the Peter A. Allard School of Law at the University of British Columbia and is called to the bars of British Columbia and the Yukon.

Outside of practice, James is active in community service and charitable initiatives, tries in vain to lower his handicap at his local public course, noodles away on his guitar, putters around the yard, spends time outdoors, and cares for his bonded mother-son pair of rescues, Pip and Lily.

https://www.coalharbourlaw.ca/james-struthers