Every September, thousands of Queen's University students move out of Kingston rentals within the same few days, and landlords across the city rekey doors for the next tenant. That part is completely legal. What trips up more landlords than you'd expect is changing the locks on a unit that's still occupied, without following the rules in Ontario's Residential Tenancies Act. Get that timing wrong and it can be treated as an illegal lockout, which the Landlord and Tenant Board has real power to penalize.
What the Residential Tenancies Act Actually Says About Changing Locks
Section 24 of the Residential Tenancies Act, 2006 (RTA) is direct: a landlord shall not alter the locking system on a door giving entry to a rental unit or residential complex, or cause it to be altered, during the tenant's occupancy, without giving the tenant replacement keys. The rule runs both ways. A tenant can't change the locks without the landlord's consent either, except in a genuine safety emergency, and even then the tenant has to get the landlord a new key right away.
The phrase that matters most is "during the tenant's occupancy." As long as a tenant is living in the unit, or still has the legal right to be there, the landlord cannot swap out the locking system and simply keep the new key. Rekeying itself isn't the problem. Withholding the key from someone still occupying the unit is what turns a maintenance decision into a lockout.
When a Lock Change Becomes an Illegal Lockout
The Landlord and Tenant Board (LTB), Ontario's tribunal for landlord and tenant disputes, is blunt about this for tenants: only a sheriff from the Court Enforcement Office can force a tenant to move out, and only after the LTB has issued an eviction order and its deadline has passed. A landlord who changes the locks, removes belongings, or blocks entry without going through that process, whether or not rent is owed, is committing an illegal lockout. A notice to end a tenancy is not an eviction order, and it gives a landlord no authority to touch the locks.
What the LTB Can Order, and What an Illegal Lockout Can Cost a Landlord
A tenant who believes they've been illegally locked out files a Form T2, Application About Tenant Rights, and the LTB can schedule these hearings on an urgent basis. If the member finds the lockout happened, they can order the landlord to let the tenant move back in, but only if the unit is still vacant, pay the tenant an abatement of rent, cover reasonable out-of-pocket costs such as a hotel stay or damaged property, and pay an administrative fine of up to 35,000 dollars.
That's separate from provincial prosecution. Changing the locks on an occupied unit without giving the tenant a key is also listed as an offence under the RTA, and as of July 1, 2026, Ontario doubled the maximum fines for offences under the Act: up to 100,000 dollars for an individual landlord and up to 500,000 dollars for a corporation, pursued through the province's Rental Housing Enforcement Unit rather than the LTB itself. Very few cases go that far, but the ceiling exists, and as of this year it's twice as high as it used to be.
Changing Locks Between Tenancies Is Legal, and It's Standard Practice
None of the above applies once a tenant has genuinely moved out. Section 24 governs locks during the tenant's occupancy, and a vacant unit between tenancies has no occupying tenant to give a key to. A Kingston landlord who rekeys or fully replaces the exterior locks after one lease ends and before the next tenant moves in isn't just permitted to do it, they're doing exactly what most property managers recommend. A previous tenant, a former roommate, or a maintenance contractor could still have a working copy of the old key, and there's no reliable way to know how many copies exist. Rekeying between tenancies closes that gap.
The September Turnover: A Practical Checklist for Kingston Landlords
Kingston's student rental market runs on tight, predictable dates, with most leases ending April 30 or August 31 and a huge share of Queen's-area units turning over on or around September 1. That compressed window is exactly when landlords are most likely to blur the line between a vacant unit that's legal to rekey and a still-occupied one that requires a key. A few habits keep landlords on the right side of Section 24.
Turnover-season rekey checklist
- Confirm the outgoing tenant's move-out date in writing, and don't touch the locks until it has passed
- Rekey if the existing hardware is in good shape; it's faster and cheaper against a hard September 1 deadline
- Replace instead if the deadbolt is older or damaged, or you want a security upgrade, covered in our rekey vs. replace guide
- Document the handoff: note how many new keys were cut and get written confirmation from the incoming tenant
- Never give a new tenant early access before the outgoing tenant's legal move-out date
For landlords managing several student units at once, upgrading to restricted or high-security locks during a rekey can also cut down on how often this scramble repeats, since fewer duplicate keys circulate in the first place.
What Kingston Tenants Should Do If They Think They've Been Locked Out
If you come home and your key no longer works, and you haven't been served an eviction order that's already passed its deadline, treat it as a possible illegal lockout. Contact the landlord in writing first and ask what happened. Document everything: photograph the changed locks, save any notices left on the door, and keep copies of texts or emails. Then file a Form T2 with the LTB and ask for an urgent hearing, since the Board can typically only order you let back in while the unit remains vacant. A community legal clinic or paralegal familiar with Ontario landlord and tenant law can help move the application quickly if the situation is time-sensitive.
Frequently Asked Questions
Can a landlord in Ontario legally change the locks on a tenant?
Not while the tenant is living there and not without immediately giving them a new key. Section 24 of the Residential Tenancies Act says a landlord cannot alter the locking system on a rental unit during the tenant's occupancy without providing replacement keys. Changing the locks and withholding a key from a current tenant is treated as an illegal lockout.
What can the Landlord and Tenant Board do about an illegal lockout?
A tenant files a Form T2 Application About Tenant Rights, and the LTB can hold an urgent hearing. If the Board finds an illegal lockout happened, it can order the landlord to let the tenant move back in if the unit is still vacant, pay an abatement of rent, cover the tenant's out-of-pocket costs, and pay an administrative fine of up to 35,000 dollars. Separate provincial prosecution can add fines of up to 100,000 dollars for an individual or 500,000 dollars for a corporation.
Is it legal for a landlord to rekey a unit between tenants?
Yes. Section 24 only restricts lock changes during a tenant's occupancy. Once a tenant has fully moved out and before the next tenant moves in, there is no occupying tenant to give a key to, so rekeying or replacing the locks is legal and is standard practice for Kingston landlords, especially around the September Queen's University turnover.
What should a Kingston tenant do if they think they have been illegally locked out?
Contact the landlord in writing first, document everything with photos of the changed locks and any notices, then file a Form T2 with the Landlord and Tenant Board and ask for an urgent hearing. A community legal clinic or paralegal can help move the application quickly, since the LTB can order the tenant let back in only while the unit remains vacant.
Rekeying a Kingston Rental for Turnover Season?
We handle rekeys and lock replacements for landlords and property managers across Kingston, Amherstview, Cataraqui, Barriefield, and Gananoque, including tight September turnaround jobs near Queen's.
Call (613) 480-5625