When does Ontario law actually require a Record of Site Condition to be filed for a change of land use?

Ontario's Environmental Protection Act framework requires a Record of Site Condition to be filed in specific change-of-use situations, generally where land is moving from a less sensitive use, such as industrial or commercial, to a more sensitive one, such as residential, institutional, or parkland, and the property's history or zoning change triggers the requirement under the applicable regulation. The underlying idea is that more sensitive uses, particularly residential ones where people live and spend extended time, warrant confirmation that the land actually meets the environmental standards appropriate for that use.

Not every property sale or change of use triggers the requirement, and whether it applies in a specific case depends on the particular regulatory triggers involved, including any municipal zoning process tied to the change. Because this determination is technical and fact-specific, anyone involved in redeveloping land from an industrial or commercial history toward a more sensitive use should get a proper legal and environmental opinion on whether an RSC is required before proceeding, rather than assuming either that it's automatically needed or automatically exempt. Municipalities involved in the relevant approvals may also require confirmation before finalizing zoning or building approvals.