The Strong Mayors, Building Homes Act, 2022 inserts a new Part VI.1 into the City of Toronto Act, 2006 and the Municipal Act, 2001 and adds a related provision to the Municipal Conflict of Interest Act. The new Parts assign a suite of municipal powers and duties to the head of council in designated municipalities (including appointing or dismissing most division heads, directing municipal staff in writing, appointing chairs of local boards and committees, establishing or dissolving committees, requiring council to consider specified matters, and exercising veto powers over certain by-laws and budget amendments).
The head of council must act in writing, make prescribed information available, and follow any regulations the Minister or Lieutenant Governor in Council issues.
The statute ties several of these authorities to “prescribed provincial priorities,” gives the Lieutenant Governor in Council and the Minister broad regulation-making authority (including retroactive regulations up to six months), protects executed decisions from judicial review on unreasonableness grounds, and amends conflict-of-interest rules to restrict a head of council with a pecuniary interest from using these powers. The change centralizes significant operational and budgetary discretion in the office of the head of council and creates new procedural timelines and oversight mechanics (e.g., notice and override rules for vetoes, by-election rules for vacancies).
At a Glance
What It Does
The Act creates a new statutory framework that assigns specified municipal powers to the head of council by adding Part VI.1 to both the City of Toronto Act and the Municipal Act. Those powers include directing employees in writing, structuring the organization and appointing most division heads (with enumerated exceptions), controlling local board and committee leadership, requiring council consideration of matters tied to provincial priorities, and vetoing certain by-laws and budget amendments subject to a council override.
Who It Affects
Designated municipalities (the Minister may designate which municipalities under the Municipal Act) and the City of Toronto; heads of council (mayors or equivalent), municipal senior management (chief administrative officers and most division heads), local boards and committee chairs, clerks’ offices who must administer notice and record-keeping, and the provincial government through regulation-making powers.
Why It Matters
The statute shifts day-to-day operational and budget authority from collective council decision-making toward the single office of the head of council, subject to regulatory guardrails and an override mechanism. That reallocation affects how municipalities implement provincial priorities, how staffing and governance decisions are made, and where legal and political accountability will sit.
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What This Bill Actually Does
The Act makes a single structural change across Ontario municipal law: it adds a new Part VI.1 in the City of Toronto Act and in the Municipal Act that vests a set of municipal powers and duties in the head of council of a designated municipality. Those powers are exercised in writing, and the head of council must publish or otherwise make available prescribed information and documents under regulations.
The Lieutenant Governor in Council may define the circumstances — “prescribed provincial priorities” — that activate certain meeting and veto powers, and the Minister may make detailed regulations governing timing, form and limits.
Practically, the head of council can appoint a chief administrative officer and exercise broad control over the City’s organizational structure, including hiring and dismissal powers for most division heads; the statute explicitly lists excluded positions (e.g., clerk, treasurer, auditor general, integrity commissioner, police chief, fire chief, chief building official, medical officer of health, and other officers required by statute). The head may also appoint or remove chairs and vice-chairs of prescribed local boards and may establish, dissolve or assign functions to prescribed committees.
When the head considers a matter to advance a prescribed provincial priority, they may require council to consider it at a meeting.On by-laws and budgets the Act creates a structured timing-and-notice regime. For by-laws that fall under the section, a head of council may give written notice of intent to consider a veto shortly after council votes; if vetoed in writing within the allowed window the by-law is deemed not to have been passed unless two-thirds of council later override the veto.
Similar procedures apply to budget resolutions: the head prepares a proposed budget, council may amend it, and the head may veto amendments subject to a two-thirds override. The Act also contains transition rules preserving existing office-holders until dismissed, special rules for filling vacancies (including different treatment for vacancies arising after March 31 in an election year), delegation limits, an immunity provision protecting good-faith exercises of power from being quashed for unreasonableness, and additions to the Municipal Conflict of Interest Act requiring disclosure and abstention where a head of council has a pecuniary interest in a matter covered by these new powers.
The Five Things You Need to Know
The head of council’s veto over eligible by-laws becomes effective only after a written veto document is delivered; council can override the veto with a two-thirds vote.
If the head gives notice of intent to consider vetoing a by-law, they must give that notice on or before the earlier of two days after council’s vote or any prescribed deadline; if notice is given the by-law does not take effect for up to 14 days unless approved in writing by the head.
The Minister may make regulations that (a) prescribe provincial priorities that trigger meeting and veto powers and (b) govern forms, timing and limits for exercising the head’s powers, and such regulations may be retroactive up to six months.
Certain senior municipal officers are expressly protected from removal by the head of council: clerk (and deputy), treasurer (and deputy), integrity commissioner, ombudsman, auditor general, chief building official, police chief, fire chief, medical officer of health and other officers required by statute.
The Municipal Conflict of Interest Act is amended to require a head of council who has a pecuniary interest in a matter covered by these new powers to file a written disclosure with the clerk, not exercise the power or duty in question, and not use their office to influence municipal decision-making on that matter.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Written directions to employees and disclosure duties
Sections 226.1 and 226.2 let the head of council direct city employees in writing to research, advise and implement decisions tied to the head’s powers, but impose a formal writing requirement and a regulatory duty to make prescribed information and documents public. Administratively, that places new recordkeeping and transparency obligations on clerks and corporate services functions and channels staff work through the head of council rather than through council committees.
CAO appointment, organizational control, and local boards/committees
Section 226.3 gives the head authority to appoint a chief administrative officer. Section 226.4 vests organizational-structure powers and hiring/dismissal of most division heads in the head of council, subject to an explicit list of exclusions. Sections 226.5–226.6 transfer appointment powers for prescribed local boards and committee-establishment and leadership powers to the head. Those provisions centralize personnel and governance control while carving out statutorily protected offices.
Provincial priorities, meeting requirements and veto mechanics
Sections 226.7–226.9 create the conditional mechanism: the Lieutenant Governor in Council prescribes ‘provincial priorities’ that activate the head’s power to require council consideration of matters and to veto specified by-laws (including some Planning Act items unless prescribed otherwise). The by-law rules set timing for notice, a 14‑day window if notice is given (or earlier if approved), the requirement of written veto reasons delivered to the clerk, and a two‑thirds council override. These provisions reshape municipal legislative timing and create a defined override path.
Vacancy rules, delegation and immunity
These sections require by-elections for head-of-council vacancies subject to regulations, but allow appointment to fill late vacancies (after March 31) with constraints: appointees cannot exercise the new Part’s powers for the remainder of the term and the municipality assumes those powers. The head may delegate certain powers (subject to limits), and section 226.12 immunizes good‑faith decisions from being quashed on grounds of unreasonableness — a significant judicial‑review limitation.
Budget authority and ministerial regulations
Section 226.14 assigns budget proposal and initial adoption responsibilities to the head of council: the head prepares a proposed budget, council may amend it, and the head may veto amendments subject to a two‑thirds override. Section 226.15 gives the Minister broad regulation-making powers to define what must be published, prescribe procedures and limits, govern by-elections and transitional matters, and make regulations retroactive up to six months.
Parallel regime for designated municipalities
Schedule 2 reproduces the same structure for municipalities designated by the Minister under the Municipal Act. The Minister decides which municipalities the Part applies to, and the regulatory apparatus mirrors the City of Toronto provisions, including identical exclusions for protected offices, the same veto and meeting mechanics and similar delegation, transition and immunity rules.
Conflict rules for heads of council with pecuniary interests
Schedule 3 inserts section 5.3 into the Municipal Conflict of Interest Act. If a head of council has a pecuniary interest in a matter and holds a power or duty under the new Part VI.1 respecting that matter, they must disclose the interest in writing to the clerk, must not exercise the power or duty in relation to that matter, and must not use their office to influence municipal decision-making on the matter. The section excludes the head’s power to delegate from its reach.
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Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Heads of council (mayors and equivalents): The statute consolidates operational, appointments and budget-shaping authority in their office and grants tools (written directions, vetoes, meeting requirements) to drive priorities forward.
- Provincial government: By prescribing ‘provincial priorities’ and broad regulations, the province gains a lever to align municipal actions with provincial objectives without direct municipal bylaws.
- Chief administrative officers and executive teams aligned with the head: CAOs appointed or confirmed by the head can expect clearer lines of responsibility and a single decision-maker for organizational structure and execution.
- Developers and actors seeking expedited approvals: Where provincial priorities (such as housing) are prescribed, the head’s ability to prioritize matters and veto obstructing by-laws can accelerate decision timelines affecting development approvals.
- Municipal administrative staff (clerks/records): The Act creates new formal processes and record obligations that centralize requests and produce clearer documentation for actions taken under the head’s authority.
Who Bears the Cost
- Municipal councils and individual councillors: Collective decision-making power is reduced by delegation to the head and by the head’s veto power, increasing friction around local democratic control and political accountability.
- Municipal legal and clerk’s offices: New notice, publication and recordkeeping duties (including timely dissemination of veto documents and managing by-election rules) will increase administrative workload and require procedural changes.
- Excluded senior officers (if dismissed indirectly): Although certain offices are statutorily protected from dismissal, other senior managers and heads of divisions face direct hiring and firing risk, producing potential turnover costs and recruitment disruptions.
- Municipal taxpayers: Centralized decision-making and the capacity for the head to alter budget adoption mechanics could shift fiscal outcomes and priorities, with potential budgetary impacts borne by taxpayers.
- Local boards and community stakeholders: Chairs and vice-chairs of prescribed boards may be appointed or removed by the head, reducing local stakeholder influence over board leadership and potentially changing program priorities.
Key Issues
The Core Tension
This law attempts to balance two legitimate goals — giving a single municipal leader the tools to advance province‑level priorities quickly, and preserving democratic checks on local power — but it centralizes authority in the head of council while insulating many exercises of that authority from traditional administrative review, placing speed and provincial alignment in direct tension with local accountability, collective council control and procedural transparency.
The Act creates several implementation pinch points. First, the power to act is repeatedly conditioned on regulations and on provincial prescription of priorities, meaning much of the practical reach of the head’s powers will be determined administratively rather than in the statute — and the Minister/Lieutenant Governor in Council may write detailed rules, deadlines and exceptions, including retroactive regulations going back six months.
That raises planning and legal certainty issues for municipalities and third parties who must interpret which matters are ‘prescribed’ and when the head can exercise vetoes or require council consideration.
Second, the immunity clause barring quashing or review on unreasonableness grounds narrows judicial review of the head’s exercised powers; combined with broad delegation and limited statutory constraints, that creates tensions between speed-of-decision and legal accountability. The Act protects certain officers from removal but leaves many senior roles exposed to dismissal, raising organizational continuity and human-resources risks.
Finally, the vacancy rules (including the rule that appointees after March 31 cannot exercise these Part VI.1 powers) and the exclusion of delegation from the Municipal Conflict of Interest Act’s prohibition create governance gaps and fine-grained exceptions that will require careful policy and procedural design at the municipal level.
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