Bill 20’s Blind Spots on Housing

March 31, 2026
Photo of a person experiencing homelessness sitting in a hammock set up in front of the Webster Pavilion of the Old Brewery Mission.
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A person experiencing homelessness sitting in a hammock set up in front of the Webster Pavilion of the Old Brewery Mission.

With consultations on Bill 20 now underway at the National Assembly, we wish to express our concerns along with some recommendations. The bill’s introduction by Housing Minister Caroline Proulx testifies to a willingness to act. Unfortunately, for the Old Brewery Mission, the target is wide of the mark. Omitting to legislate on eviction prevention and housing support services, two criteria that are central to reducing homelessness, would be, in our eyes, a missed opportunity.

Ambitious legislation aimed at encouraging access to housing must first be backed by large-scale development of non-market housing. To make our system viable again, we must aim for the now widely-agreed-upon target of 20% non-market rental housing. Without a comprehensive policy that treats housing as essential social infrastructure the same way schools and hospitals are, we will not succeed in making housing in Quebec affordable again.

Three mechanisms for real prevention

For this bill to really work to prevent homelessness, we propose three practical ways forward:

  • 1. Expanded rent banks : An unforeseen expense can turn up at any time, and a household with a modest income will have a tougher time paying the rent. Rather than see this household fall into homelessness—which costs the state infinitely more—a rent bank offers interest-free loans or subsidies to low- to moderate-income tenants facing temporary financial hardship. It’s an agile, human and economically responsible safety net that has been shown to work and that should be further developed.

  • 2. A mandatory rent registry : There can be no management without measurement. An official registry is the only tool capable of curbing abusive rent hikes and keeping the private rental stock, where most vulnerable Quebecers live, affordable. At the same time, toughening penalties for landlords guilty of abusive rent increases and illegal evictions would curb such practices.

  • 3. Reforming Quebec’s rental board, the Tribunal administratif du logement (TAL) : The most effective way to end homelessness is to stop people from losing their homes. Preventing homelessness must be at the heart of the TAL’s mandate. When people are at risk of losing their homes, the TAL must have the responsibility to assess their risk of homelessness and report it to the healthcare network. In doing so, the TAL will prevent many people from ending up on the streets after an eviction by ensuring they are looked after. We nevertheless welcome the bill’s inclusion of an option for the TAL to require that the parties hold a conciliation session. It is a step in the right direction.

Housing doesn’t stop when you hand over the keys

Building isn’t enough. For people with complex profiles, an apartment without support remains an empty shell. Yet right now the funding for support services is insufficient. To ensure residential stability, funding for support services must be commensurate with often complex needs. Only then will housing become the path to dignity it is meant to be.
Confusion for community organizations

A concern has nevertheless emerged over the autonomy of community organizations, and coordination of access to housing. By setting up a new centralized system for applications for affordable and low-rent housing and by creating new definitions through regulation, we risk duplicating the existing mechanisms for allocating housing, and eroding accessibility.

As a housing manager, we fear that the new system will undermine the work of community organizations, most notably by prioritizing tenants, preventing us from offering a roof to those who need it most. The solution lies not in adding a new and vaguely defined system, but in building new housing and fostering genuine synergy between the healthcare network, the housing sector and community organizations.
We know what the needs in housing are, and non-profit organizations are there to help develop affordable housing in Quebec. Let’s give them the means to act rather than piling on new rules and processes.
In the face of the affordability crisis, Bill 20 can become a catalyst in the development of non-market housing. It is time, parliamentarians, to take this bold step.

William Hodgson
Senior Advisor, Public Affairs and
Government Relations, Old Brewery Mission

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