Commercial Property Tax Appeals in Ontario: You Have an Option Homeowners Don’t — Free RfR or Filing Direct with the ARB
Homeowners must run the free Request for Reconsideration before they can appeal. Commercial, industrial and multi-residential owners aren’t forced to — so you get a choice a homeowner doesn’t: use the free RfR, or skip it and file straight with the ARB. That choice is really a trade-off between saving a fee and controlling your deadline.
Should my commercial property use the free Request for Reconsideration first, or go straight to the ARB?
It depends on how much time you have left. Plenty of runway and a clear over-assessment? Run the free Request for Reconsideration first — you may save the fee entirely. Down to the wire? Skip it, pay to file directly with the Assessment Review Board (ARB), and keep the March 31 deadline in your own hands. The reason you even get to choose comes from a point most owners have backwards: the RfR is free and open to every owner — residential, farm and managed-forest properties (the ARB adds conservation land) are simply required to use it before appealing, while commercial, industrial and multi-residential owners are not, which hands you the extra option of going straight to the Board. The trade is concrete: filing direct costs $318 per roll number (less $10 to e-File), while the free RfR route swaps your deadline for “90 days after MPAC’s decision” — a clock you don’t control, and one MPAC says it’s currently behind on.
Sources: MPAC, How to file a Request for Reconsideration; Tribunals Ontario — Assessment Review Board, Filing an Appeal & Fee Chart; Assessment Act, R.S.O. 1990, c. A.31 (full text at Ontario e-Laws). Reviewed 2026-08-05.
I’m Arthur Zhao. On the commercial side, the property-tax call I get most often opens with a misunderstanding: “The value’s too high — I have to file that free reconsideration with MPAC first, right?” Not quite — and the correction actually works in your favour.
That free reconsideration (the RfR) isn’t a homeowner-only step; you can use it too. The real difference is that homeowners are required to run it before they can appeal, while commercial, industrial and multi-residential owners aren’t. So you actually have one more option than a homeowner does: skip the RfR and file directly with the Assessment Review Board. This piece isn’t about what you’re missing — it’s about spending that extra choice well: try it free, or pay to lock down your deadline. (A process explainer, not legal or tax advice.)
The option a homeowner doesn’t have
When a homeowner disputes their value, the free RfR isn’t optional — it’s the mandatory first step before the Board will hear them. That’s the part worth getting right: the RfR itself is free and open to any owner. MPAC’s own site frames it as an option it reviews free of charge. What the rules actually gate by property class isn’t the price — it’s whether you’re compelled to use it.
ℹ️Drop this myth before you read on: “free” is not a homeowner perk you’re locked out of. The RfR costs nothing for any class — your class only decides whether using it is mandatory or optional before you can appeal.
Who’s forced, and who gets to choose
Residential, farm and managed-forest properties — and, per the ARB, conservation land — must file an RfR and receive MPAC’s decision before they can appeal. Commercial, industrial and multi-residential buildings carry no such requirement. Tribunals Ontario puts it plainly: for all other property types, you may choose to file an RfR with MPAC or file an appeal with the ARB. That single word — choose — is your advantage, and the rest of this piece is about spending it wisely.
💡 My honest take: for a commercial owner, the answer usually comes down to how much runway you have left. Plenty of time and a clear-cut over-assessment? Running the free RfR first — and possibly saving the $318 entirely — is reasonable. But MPAC currently warns it’s behind on some RfRs, and if the RfR fails your ARB window becomes 90 days from a decision letter you can’t schedule. Close to the deadline, don’t gamble your timeline to save a fee — file directly and nail down the March 31 date you control.
Same dispute, two very different paths
Once you’ve chosen the ARB: what makes a filing valid
Whether you go direct or land at the ARB after a failed RfR, three things decide whether your filing counts before anyone weighs the merits.
Confirm the property class on every roll number
roll number. Mixed-use buildings are the trap: a portion classed residential (apartments over ground-floor retail) falls into the mandatory-RfR side, while the purely commercial portion keeps the go-straight-to-ARB option. Read the class on every roll number before assuming you can choose.Match the deadline to the path you picked
⚠️The free RfR has a hidden price, and it isn’t dollars — it’s someone else’s calendar. Pick it and your ARB clock doesn’t even start until MPAC issues a decision; then you get 90 days from a letter you can’t schedule, while MPAC reports it’s behind on RfRs. The closer March 31 sits, the more that “free” can cost you the window.
Pay per roll number — and only if you reach the ARB
roll number, less $10 to e-File — and it’s charged per appeal per roll number, not refunded just because appeals get consolidated into one hearing. Portfolio owners should total it across every roll number first. This is also the quiet upside of trying the RfR: if MPAC adjusts your value at that free stage, the $318 never gets spent.Two deadlines owners routinely confuse
- MPAC — How to file a Request for Reconsideration (the RfR is free and optional for every class; residential/farm/managed forest must file one first; MPAC notes it is currently experiencing delays on some RfRs)
- Tribunals Ontario — Assessment Review Board, Filing an Appeal (residential/farm/managed forest/conservation land must RfR first; all other types may choose; direct deadline March 31 / 120 days for other notices; 90 days after an RfR decision; deeming into the next tax year)
- Tribunals Ontario — ARB Fee Chart ($132.50 residential class, $318 business class, per roll number; −$10 to e-File; charged per appeal, not refunded on consolidation)
- Assessment Act, R.S.O. 1990, c. A.31 — full text at Ontario e-Laws (reader self-check)
- MPAC — The Assessment Cycle (2026 assessments still use the January 1, 2016 valuation date; province-wide reassessment postponed)
Mpac Assessment Appeal Rfr →The Property-Tax Bill That Arrives After Closing: Why Commercial Buyers Need a Supplementary-Assessment Holdback →The Rooftop Lease: How a Cell Antenna Turns Your Commercial Building Into a Second Income Stream →First-Time Renter Guide →
Frequently Asked Questions
Do I have to try the RfR first, or can I go straight to the ARB?
As a commercial, industrial or multi-residential owner, you can go straight to the ARB — you’re not required to file an RfR first. That mandatory-first-step rule applies only to residential, farm, managed-forest and conservation-land properties. You may still use the free RfR if you want to; for business classes it’s an option, not a prerequisite. (Tribunals Ontario ARB)
I have several roll numbers — how many ARB fees do I pay?
One fee per appeal per roll number. The ARB charges $318 (business class) for each roll number even if it consolidates your appeals into a single hearing, and it generally won’t refund for consolidation. Total the cost across all roll numbers before deciding how wide to appeal.
What evidence actually moves the Board at an ARB hearing?
Data tied to the legal valuation date, not opinion. The ARB weighs current value as of January 1, 2016 — comparable sales and rents, capitalization rates, your building’s income and vacancy, and how MPAC valued similar properties. A general sense that the number is too high won’t move it; a defensible set of comparables can.
Can a property tax agent or consultant file the ARB appeal for me?
Yes — owners commonly use a representative (a property tax agent, consultant or lawyer) to file and argue an ARB appeal, especially on larger commercial files where comparable-sales and income evidence get technical. You’re still on the hook for the deadline and the fee, so confirm who is tracking March 31. This isn’t legal advice — for a specific file, get professional representation.
If I win, do I get the ARB filing fee back?
Generally no. Tribunals Ontario says the Board won’t waive or refund a filing fee absent appropriate circumstances, and winning isn’t automatically one of them. Treat the $318 as a sunk cost — which is exactly why resolving it for free at the RfR stage, when you have the time, can be worth trying.
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