The Renoviction Moratorium (Bill 65): What You Can and Can No Longer Do in Your North Shore Plex

ImmoMulti — a direct buyer of multi-unit properties on the North Shore — works each week with plex owners who have an ambitious renovation project… blocked by the law. Since June 2024, Bill 65 has imposed a moratorium on certain types of eviction in every rental building in Quebec, including duplexes, triplexes and multi-unit buildings on the North Shore (Terrebonne, Laval, Repentigny, Saint-Jérôme, Mascouche, Mirabel). If you were planning to subdivide a large unit, merge two of them, or convert your income property to commercial use, you are legally blocked until 2027 — and possibly beyond. This guide explains what you can and can no longer do, and when selling becomes the most sensible decision for a North Shore plex owner.

What is the renoviction moratorium and where does it come from?

The term renoviction refers to the practice of evicting a tenant under the pretext of carrying out renovations in their unit. In Quebec, this practice was already illegal before 2024: a plex owner cannot terminate a tenant's lease simply to paint walls or renovate a kitchen. But until 2024, certain forms of eviction for structural work remained possible: subdividing a unit into several, carrying out a substantial enlargement, or changing the building's use.

Bill 65, assented to on June 6, 2024 by Quebec's National Assembly, suspended these options for a three-year period. It applies to all rental dwellings in Quebec, with no geographic exception — whether your plex is in Laval, Terrebonne, Repentigny, Saint-Jérôme or Blainville on the North Shore, you are subject to it just as much as a Montreal owner.

The law provides an automatic exit clause: if the average vacancy rate for rental housing reaches 3% across all Quebec urban centres of 10,000 inhabitants and more — according to data published by the Canada Mortgage and Housing Corporation (CMHC) — the moratorium ends before the three-year term. Current CMHC data remains well below this threshold for the vast majority of Quebec rental markets, including the North Shore.

Source: Radio-Canada — "Quebec wants to ban evictions until 2027" ; Tribunal administratif du logement — Eviction notice for subdivision, enlargement or change of use

What Bill 65 concretely prohibits in your North Shore plex

The moratorium suspends three specific types of eviction. Concretely, for the duration of the moratorium, you cannot evict your tenant for:

• Subdivision of a dwelling: splitting a large apartment into two or more separate units to increase the number of dwellings in your income property. For example, turning a 5½ into two 2½ units.
• Substantial enlargement of a dwelling: merging two occupied units to enlarge one of them — typically to create a larger dwelling to rent out or live in.
• Change of use: converting a rental dwelling to commercial, institutional or other non-residential use (e.g., office, gallery, warehouse). This operation also requires municipal permits independently of the TAL.

It is crucial to clearly distinguish evictions prohibited by the moratorium from repossession of a dwelling for personal or family use, which is not covered by Bill 65. A North Shore plex owner can still repossess a unit to house themselves or a close relative — subject to the usual TAL rules (6-month notice, indemnity of 3 months' rent and reasonable moving expenses). This type of repossession has in fact tripled in Quebec over the past 12 years, as highlighted in our article on repossessions that have tripled on the North Shore.

Major work: what you can still do with your occupied plex

Bill 65 blocks permanent evictions for structural work, but it does not affect major work — that is, work that requires a temporary relocation of the tenant without terminating the lease. This distinct regime is defined by the Tribunal administratif du logement and continues to apply normally during the moratorium.

Concretely, if you must carry out work that makes the unit temporarily uninhabitable (foundation replacement, complete plumbing or electrical overhaul, etc.), you can ask the tenant to leave for the duration of the work. The tenant nonetheless keeps their lease and their right of return to the unit once the work is finished, at the same rent. It is you, the multi-unit property owner, who must cover the reasonable temporary relocation costs.

• The tenant receives appropriate notice and can contest the duration or necessity of the work before the TAL.
• If the tenant chooses to terminate their lease rather than relocate, you will owe them an indemnity.
• You must inform the tenant of their right of return in writing, in the forms prescribed by law.

Source: Tribunal administratif du logement — Major work ; Éducaloi — Eviction from a dwelling

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Eviction for work vs. major work: the essential difference

When the renoviction moratorium pushes you to sell your multi-unit property

For many plex owners on the North Shore, the Bill 65 moratorium has fundamentally changed their value-add plan. If your strategy was to subdivide a large unit to create an additional one, to convert your income property to a condominium or to change its use, you are blocked — potentially until June 2027, or even beyond if the government chooses to extend the moratorium.

Several concrete situations signal that selling is often more advantageous than waiting:

• Subdivision project: You wanted to convert a triplex into a quadruplex by subdividing a large unit. Blocked until 2027. If you sell now, you realize the current value of the triplex without waiting — a buyer with a longer horizon can factor the conversion premium into their own offer.
• Change-of-use project: You were considering converting the ground floor into a commercial space. You cannot evict your tenant for now. The potential commercial value is invisible to the ordinary buyer, but a specialized buyer will know how to price it fairly.
• Low current profitability: If your North Shore multi-unit property is barely profitable in its current configuration and the structural renovation project was the only path to a better return, the moratorium cancels your plan B. In this context, selling can free up capital to reinvest in a higher-performing asset.
• Extension uncertainty: The government may decide to extend the moratorium beyond 2027 if Quebec's rental market does not ease. Waiting 3 years only to maybe wait longer is not a strategy.

Selling your North Shore plex as-is: often a simpler path

Contrary to what many owners believe, selling a plex with tenants in place is not an obstacle to a fast and fair sale. ImmoMulti buys multi-unit properties on the North Shore in exactly this state: tenants in place, no prior renovation, no broker commission, with an offer within 48 hours.

For an owner whose structural renovation project is blocked by the moratorium, selling offers several clear advantages:

• You have nothing to evict: tenants stay in their units — it is the buyer who manages the landlord-tenant relationship from the moment of possession.
• You avoid TAL proceedings: no eviction process, no risk of contestation, no unexpected legal fees.
• You free up capital now: rather than waiting until 2027 in uncertainty, you cash in the current value of your income property and can reinvest it.
• You sell at a fair price: a knowledgeable buyer like ImmoMulti correctly values a multi-unit property on the North Shore based on its real income, not on a hypothetical post-renovation value.

For owners whose tenants have become difficult to manage — whatever the reason — our complete guide on selling an income property with difficult tenants covers all your options. And if you are in an urgent situation (estate, separation, job relocation), our page on selling an income property quickly details how a sale can close in 30 to 60 days on the North Shore.

Why Quebec adopted Bill 65: the housing shortage in the background

For a North Shore plex owner, understanding why the moratorium exists also sheds light on its likely duration and the risk that it may be extended. Bill 65 was not born of a theoretical debate: it responds directly to the housing crisis that has struck Quebec since 2022. The government wanted to curb the attrition of the affordable rental stock — that is, the net loss of low-rent housing caused by subdivisions, mergers and conversions that make existing units disappear or push their rents up.

The central figure is the vacancy rate. According to the Canada Mortgage and Housing Corporation (CMHC), the Montreal census metropolitan area — which covers a good part of the North Shore (Laval, Terrebonne, Mascouche, Repentigny) — posted a vacancy rate of 2.1% in the fall of 2024, up from the previous year but still below the 3% balance threshold. It is precisely this 3% threshold that serves as the legal trigger for lifting the moratorium early. In other words, as long as Quebec's rental market stays tight, the moratorium holds.

Source: Observatoire du Grand Montréal — "Vacancy rate rises to 2.1% in 2024 but remains below the balance threshold" ; CMHC — Rental Market Report, fall 2024

For an owner, the strategic lesson is clear: the moratorium is not a simple three-year administrative delay that will mechanically expire in June 2027. Its duration is indexed to the health of the rental market. If the shortage persists — the most likely scenario for the North Shore, where housing demand far outstrips new construction — the government could choose to extend the freeze. Building a value-add plan that relies on subdivision or change of use is therefore betting on a deadline whose date and certainty you do not control.

Does your project fall under the moratorium? The verification process, step by step

Many multi-unit owners assume their project is blocked — or, on the contrary, that it is not — without having done the qualification exercise. Yet the line between a prohibited eviction and a perfectly legal project turns on details. Here is the process we recommend following, in order, before spending a single dollar on architect's plans or proceedings at the Tribunal administratif du logement.

Step 1 — Qualify the exact nature of your work

The first question is not "can I evict?" but "do I actually need to evict to carry out my project?". Distinguish three categories:

• Ordinary maintenance and repair work (kitchen, bathroom, floors, windows): this has never allowed eviction, moratorium or not. You do it when a tenant leaves or in stages, without terminating the lease.
• Major work with temporary relocation (foundations, plumbing stacks, complete electrical overhaul): permitted during the moratorium, with the tenant's right of return at the same rent.
• Subdivision, substantial enlargement or change of use: these are the only three cases covered by the moratorium. If your project fits none of these boxes, Bill 65 simply does not concern you.

Step 2 — Test your project against the three blocked grounds

For each of the three grounds, ask the concrete question. Are you splitting one unit into two or more? That is a subdivision. Are you merging two occupied units into a single larger one? That is a substantial enlargement. Are you converting a residential unit into an office, a shop, tourist accommodation or any other non-residential use? That is a change of use. A "yes" to any of these three questions means the corresponding eviction is suspended until 2027.

Step 3 — Check the date of any notice already sent

If you had already sent an eviction notice to your tenant, its date is decisive. A notice delivered before May 22, 2024 escapes the moratorium; a later one, for any of the three covered grounds, is neutralized. Keep proof of delivery (registered mail, bailiff): that is what will carry weight before the TAL.

Step 4 — Don't forget the municipal layer

Even if the moratorium did not apply, a change of use or a subdivision almost always requires municipal permits and compliance with local zoning. On the North Shore, by-laws vary from one municipality to another: what is allowed in Mascouche may be prohibited in Blainville. The TAL moratorium and the planning by-law are two independent filters — your project must pass both.

Special cases and exceptions: what the moratorium does not block

The Bill 65 moratorium is often presented as an impassable wall. In reality, it targets three specific grounds and leaves several perfectly legal paths intact. Knowing these exceptions avoids abandoning a viable project — or, conversely, embarking on a doomed process.

The condo conversion case

Many North Shore plex owners confuse the Bill 65 moratorium with the ban on converting a rental building into a divided co-ownership (condo). These are two distinct regimes. Condo conversion has long been governed by a specific municipal or provincial moratorium and by the requirement to obtain TAL authorization, independently of Bill 65. In other words, even after June 2027, turning your triplex into three condos will not be automatic: it is a project to validate separately.

The already-vacant unit

The moratorium protects the sitting tenant. If there is no tenant — the unit is vacant or the lease ended without renewal — there is no one to evict, so nothing to block. You can subdivide, merge or change the use of an empty unit, subject to municipal permits. This is why some owners wait for a natural departure before starting structural work: a legal strategy, but with an uncertain horizon that can stretch over years.

Illegal or bad-faith eviction: the penalties that await you

The temptation exists: since the moratorium blocks the "official" eviction, some owners consider shortcuts — a repossession invoked but never carried out, pressure to buy out the lease, an eviction notice on a false ground. This is the most dangerous calculation of all, and its consequences must be measured before even considering it.

The Civil Code of Quebec (article 1968) allows a tenant who is the victim of a repossession or eviction obtained in bad faith to recover the resulting damages — and, on top of that, to claim punitive damages. The latter do not repair a loss: they punish the conduct and aim to deter its repetition. Since the amendments that came into force on February 21, 2024, the burden of proof has been reversed: it is now up to the owner to demonstrate that they acted in good faith, and not up to the tenant to prove bad faith. A reversal with heavy consequences for any contested file.

The amounts are not symbolic. The average punitive damages awarded in cases of bad-faith repossession reached $4,618 in 2021, sharply up from previous years — and courts have set new highs, with a record $55,000 in punitive damages in a high-profile case. To these sums are added compensatory damages (moving costs, rent difference, trouble and inconvenience) and your own legal fees. A questionable eviction can therefore cost far more than the value you hoped to create.

Source: Légis Québec — Civil Code of Quebec, art. 1968 ; Blogue du CRL — "Record punitive damages in Trépanier v. Bleier"

Repossession of a dwelling: the only eviction path still truly open

If the moratorium closes three doors to you, it leaves one ajar: repossession of a dwelling for personal or family use. This is not a workaround — it is a distinct right, provided by the Civil Code, that Bill 65 did not touch. But it is a strictly framed right, and increasingly scrutinized.

Repossession lets you take back a unit of your plex to live in yourself, or to house an ascendant, a descendant or another first-degree relative. It can never serve to "make room" for a renovation project, a higher rent or a resale: that would be a misuse, precisely what article 1968 sanctions. Here are the steps and timelines to respect.

Repossession has in fact grown to such an extent that it has become a matter of vigilance for the courts: the number of repossessions has risen sharply in Quebec in recent years, which fuels suspicion of dubious files. For a North Shore multi-unit owner, repossession therefore remains a legitimate tool, but reserved for a genuine housing need — not a value-add strategy. If your goal is to free up units to transform or resell the building, repossession is neither meant for that nor risk-free.

The moratorium's impact on the value of your North Shore plex

Beyond the law, the moratorium has a very concrete effect on what your income property is worth today. A plex is valued mainly by capitalizing its net income: you divide the net operating income by the market's overall capitalization rate (cap rate) to obtain its economic value. Yet for many buildings, part of the "theoretical" value rested on a transformation project — subdivide, densify, change the use — now frozen.

Take a simplified numerical example, purely for illustration. Suppose a triplex on the North Shore generating net operating income of $36,000 per year, in a market where the cap rate sits around 5%. Its current economic value is around $720,000 ($36,000 ÷ 0.05). The owner planned to subdivide a large unit to create a 4th one, raising net income to $46,000 — a post-project value of $920,000. The moratorium has just put those $200,000 of additional value out of reach until at least 2027.

Purely illustrative example for educational purposes. The real value of a building depends on many factors (location, condition, area cap rate, verified income). For a valuation, consult a certified appraiser or a notary.

Two conclusions follow for the owner-seller. First, the transformation premium has not disappeared — it is deferred and uncertain. A long-horizon buyer can still factor part of it into their offer, because they will be able to carry out the project after the moratorium is lifted. Second, the good market news remains: the "as-is" value of your plex stays solid. The plex market in the Greater Montreal area posted a 6.1% rise in median prices in May 2026 according to APCIQ, driven by the scarcity of supply. In other words, you lose access to a hypothetical future premium, but the current value of your multi-unit property holds firm.

The common mistakes owners make when facing the moratorium

After working with many North Shore plex owners, we see the same missteps repeat. Knowing them is already avoiding them.

Mistake 1 — Believing the moratorium blocks all renovation

This is the most widespread misunderstanding. The moratorium targets only three grounds of eviction; it prohibits neither ordinary renovations nor major work with a right of return. You can keep maintaining, modernizing and even deeply overhauling your income property — as long as you do not end the lease to subdivide, merge or change the use.

Mistake 2 — Waiting passively for June 2027

Many owners "pause" their project assuming the moratorium will expire mechanically in three years. But the lifting depends on the vacancy rate, and an extension is possible. Tying up capital for three years — or more — waiting for an uncertain deadline has a real opportunity cost, often greater than the hoped-for premium.

Mistake 3 — Trying to circumvent the moratorium

Fictitious repossession, pressure, punitive increases: these strategies expose you to damages and punitive damages, with the burden of proof now on the owner. The game is never worth the candle.

Mistake 4 — Undervaluing your plex "as-is"

Frustrated by the frozen project, an owner may dump their building believing it "is no longer worth anything" without the transformation. That is false: the value from capitalizing current income remains solid, and a specialized buyer knows how to recognize latent potential. Selling at a discount out of discouragement is the most costly mistake of all.

Mistake 5 — Neglecting documentation

Whether you sell or keep, a well-kept file (leases, rent receipts, maintenance history, work invoices, proof of notice delivery) protects your position and speeds up any transaction. A serious buyer pays more for a building whose income and upkeep are documented.

Sell now or wait for 2027: two numerical scenarios

The recurring question: "Is it better to wait for the end of the moratorium to carry out my project, or to sell right now?" There is no universal answer, but a numerical reasoning helps decide. Let's compare two trajectories for the same North Shore plex, for illustration.

Scenario A — Wait until 2027 to subdivide

You keep the building three more years hoping to create the 4th unit. You must then weigh: tying up your capital for three years; the risk of the moratorium being extended; the cost of the work when the time comes (materials and labour historically rising); the delays and fees for municipal permits; the hazard of a tenant contesting. The $200,000 premium in our example is not acquired — it is conditional on the moratorium being lifted, permits being obtained and execution going smoothly.

Scenario B — Sell now, as-is

You immediately realize the building's current value (≈ $720,000 in our example), with no eviction, no TAL proceedings, no risk of damages. You free up your capital to reinvest today in an unblocked asset. You transfer to the buyer all the regulatory and operational risk of the frozen project.

The choice depends on your risk tolerance, your horizon and your liquidity needs. For an owner nearing retirement, dealing with an estate, a separation or a job relocation, waiting often makes no sense: scenario B turns a blocked asset into mobilizable capital. For a young, well-capitalized investor ready to bear the uncertainty, scenario A can be defended. But in both cases, the decision must be quantified, not merely endured.