New Real Property Register May Have Environmental Implications

On December 10, 2016, the Ontario Business Corporations Act ("OBCA") will be amended by the Forfeited Corporate Property Act, 2015 ("FCPA") to include new record keeping obligations for corporations with interests in land. Ontario companies should be aware that these obligations may have environmental implications.

Corporations will be required to prepare and maintain a register of their ownership interests in land in Ontario. The register must identify each property, show the date the corporation acquired the property, the date it was disposed and include supporting documents.

For companies incorporated or continued under the OBCA before December 10, 2016, these obligations will not apply for two years, until December 10, 2018. For companies incorporated on or continued on or after December 10, 2016, these new obligations apply immediately.