British Columbia is no stranger to housing policy controversy.
In 2024, the provincial government amended its residential tenancy regulations to better define supportive housing as non-profit permanent housing paired with support for people who have experienced homelessness or are at risk of homelessness to live independently. Those changes also gave operators new tools, including the ability to manage guests and conduct wellness checks.
The changes were well intentioned, but the process drew criticism from advocacy organizations which felt that tenant rights were eroded by the changes.
Two years later, the province has returned with Bill 11, which includes more expansive proposed amendments to the province’s Residential Tenancy Act. The bill, which is in first reading, amends the act to even more explicitly define supportive housing and the rules governing it.
This time, the government did consult widely. But having listened more carefully, did it hear the right things? More importantly, did it respond with the right policies?
The answer is no. The bill contains provisions that could significantly hurt many vulnerable people. The province should go back to the drawing board on its most punitive provisions and build in proportionality tools that tenants, providers and adjudicators need to navigate these issues with fairness and humanity.
What Bill 11 proposes
Bill 11 introduces several significant changes.
It creates new grounds for supportive housing operators to end a tenancy if a tenant or anyone they permit on the property is found in possession of a weapon or if a weapon is observed in plain view during a “lawful entry,” such as a person responding to a maintenance request.
It also expands the grounds for eviction due to misconduct. Previously, evictions on these grounds were limited to conduct affecting the landlord and other tenants. Bill 11 extends protections to any “authorized person” on the premises – a broad category that includes contractors, health-care workers, guests and others.
As well, Bill 11 grants supportive housing operators the ability to temporarily restrict tenant access to part or all of a property in critical situations and enables them to apply for a temporary order to limit tenant access to other parts of the building, without requiring that the tenant be notified of the application. This is consistent with emergency orders elsewhere that give landlords tools to quickly respond to urgent situations.
The bill also attempts to clarify where and how the act applies to supportive housing by distinguishing it from transitional housing, which is exempt from the Residential Tenancy Act and which has a defined end date (i.e., is time-limited). This clarification includes new regulation-making powers to formally designate certain addresses as transitional housing.
On paper, these changes respond to genuine operational pressures facing supportive housing operators. However, in practice, several provisions raise serious concerns about proportionality, tenant rights and the unintended consequences of blunt legislative tools applied to deeply complex situations.
The problem with weapons-based eviction
The new weapons-related grounds for eviction are perhaps the most alarming element. Under the proposed changes, a tenant can be evicted not only for personally possessing a weapon, but because someone they permitted on their property had one or because a weapon was simply observed during a lawful entry.
The first problem is that “weapon” is not clearly defined in the bill. Items that might be classified as weapons could include common things such as a kitchen knife or a baseball bat. This matters enormously when someone’s home is on the line.
The second problem is scope. Holding a tenant responsible for the actions of a visitor introduces a form of liability that is particularly dangerous in cases of gender-based violence and intimate partner violence. Following separation, victims of such violence often face continued threats and coercion, and may not have the option of moving out of the unit or building.
Allowing those circumstances to become grounds for eviction, without any mechanism to account for coercion or vulnerability, is not just a policy gap. It is a potential pathway to punishing survivors.
The third and perhaps most systemic problem is the complete absence of proportionality mechanisms. Bill 11 includes no option other than eviction on weapons-related grounds, no pathway to mediation and no conditional order process through which tenants and landlords could negotiate an agreement that avoids eviction.
Comparative research on eviction protections across Canadian provinces and territories places British Columbia among the weakest jurisdictions for conditional orders. In a context where supportive housing tenants who are evicted frequently have nowhere to go but the street, the absence of any off-ramp is not a minor oversight. It is a structural failure.
Broadened misconduct grounds: Who is actually protected?
The expansion of misconduct grounds to include incidents involving contractors, health-care workers and other authorized persons on the property addresses a real gap. Previously, behaviours that threatened anyone outside the limited landlord-tenant relationship were covered only narrowly by the act. The intent to protect frontline workers is legitimate and deserves acknowledgment.
But the implementation raises difficult questions. Under the proposed rules, a conflict — such as a heated exchange — between a tenant and an “authorized person” could potentially constitute grounds for eviction if the authorized person reports feeling their safety was affected.
This is an extremely low bar, particularly given that supportive housing tenants often live with mental health challenges, substance use issues, trauma histories and chronic stress. The same circumstances that make someone vulnerable enough to need supportive housing may also make them more likely to experience and express conflict in ways that could trigger these new provisions.
More troubling still, these changes apply to all rental properties in British Columbia, not just supportive housing. The absence of mediation requirements or conditional orders before eviction means the threat of losing one’s home becomes possible as a consequence for a much wider range of interpersonal conflicts, with no obligation to explore less disruptive remedies first.
Temporary access restrictions and the right to possessions
Bill 11 also allows supportive housing operators to temporarily restrict tenant access to their property and their personal possessions. The exemption from Section 26(3) of the act, which otherwise limits a landlord’s ability to seize personal property, is especially concerning.
Research by scholars such as Alexandra Flynn and Nick Blomley has documented the profound significance of personal possessions for people experiencing poverty and homelessness. Objects that may seem insignificant to outside observers often carry deep personal, practical and emotional weight for these people.
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Policies that erode access to those possessions, even temporarily, extend a long history of regulatory frameworks that treat the belongings of low-income people as lower status or more disposable.
In the coming weeks, it will be important to see what clarifications are made in the regulations. The bill includes no maximum time for access restrictions, no mechanism tied to meeting agreed-upon conditions and no expiration clause. Without these safeguards, what is framed as a temporary emergency tool could function as an indefinite punitive measure.
Transitional housing designation: Clarity or new bureaucracy?
The bill’s attempt to clarify the scope of the act through formal designation of transitional housing does address genuine legal confusion. The B.C. Court of Appeal decision in McNeil v. Elizabeth Fry Society highlighted how housing can be legally classified as transitional even when tenants have lived there for years with no concrete transition plan, meaning they lack the protections of the act despite having genuine homes.
Designating specific addresses as transitional may reduce some of this ambiguity, but it risks creating a new problem: that bureaucratic classification, rather than lived reality, determines legal protection.
A better approach would establish clear guidelines on maximum residency lengths in transitional housing and create an explicit pathway through which long-term residents can access the fuller protections of supportive housing tenancy, regardless of how their building is formally categorized.
The bigger picture
Bill 11 did not emerge in a vacuum. British Columbia’s affordable housing crisis is decades in the making. The province faces a shortfall of hundreds of thousands of affordable homes, with estimates suggesting Vancouver alone needs more than 50,000 units.
Supportive housing providers operate at the sharp end of this crisis — understaffed, underfunded and caught between the needs of vulnerable tenants and the limits of strained operating budgets.
In that context, providers have sought more robust funding models but instead have been given legislative tools to manage increasingly difficult situations.
It is important that the government has responded. But the solutions offered in Bill 11 are in critical ways the wrong ones. Making it easier for providers to evict tenants does not reduce the underlying pressures they face. It simply relocates the problem to the street.
What is actually needed, and notably absent from Bill 11, is a serious investment in proportionality mechanisms: mandatory mediation before eviction filings, conditional orders that allow landlords and tenants to set fair expectations, and options that give tenants a genuine path to keeping their homes when the underlying concern can be addressed.
British Columbia has made real progress in recent years in protecting tenants from no-fault evictions. Bill 11 risks undermining that progress by introducing fault-based grounds so broad, and remedies so one-dimensional, that the net effect is a significant weakening of housing security for some of the province’s most vulnerable residents.
Getting housing policy right is difficult. But getting it wrong again has consequences that cannot be papered over with consultation processes or regulatory amendments.
