A commercial refinance in Ontario almost always triggers a fresh appraisal. Your lender is required to revalue the collateral on current information before re-pricing the loan, and the deliverable is a CUSPAP 2026-compliant written report signed by an AACI, P.App. member of the Appraisal Institute of Canada. That signature is what underwrites the credit decision. Expect a standard 10 to 15 business days from engagement letter to signed delivery for typical assignments, and longer for complex multi-tenant or specialty assets. This guide walks the four steps in order and flags what most often slips the schedule.

Key takeaways

  • A standard Ontario commercial refinance appraisal runs 10 to 15 business days from engagement letter to signed delivery for typical income-producing assets; complex multi-tenant, mixed-use, and specialty assignments take longer.
  • The signature your lender underwrites against is AACI. OSFI's Commercial Real Estate Risk Management regulatory notice (November 21, 2024) governs federally-regulated lenders; FSRA's Commercial Lending Guidance (effective July 1, 2024) governs Ontario credit unions and names AACI by full credential.
  • OSFI Guidelines B-20 and B-21 are residential and do not govern commercial mortgages.
  • Four steps drive the schedule: engagement letter (authorized use, authorized client, scope, report type), document assembly, site inspection, and drafting through signed AACI delivery.
  • The largest source of timeline blowout is a late or incomplete document set.

When a lender requires a new commercial appraisal

Most refinance appraisals are ordered for one of four reasons: a maturing five-year term, a covenant-driven revaluation, an acquisition refinance, or a workout file. The 2026 environment compresses the first category - the back-end of the 2020-2021 vintage debt wall is renewing into a different rate and cap-rate environment, covered in our Canadian CRE refinance cycle guide. Briefly, the Bank of Canada has held the overnight rate at 2.25% since October 2025, with a fourth consecutive hold on April 29, 2026, and a 2021-vintage cap-rate underwrite often does not survive contact with current spreads.

The regulatory backdrop is misunderstood often enough to fix in writing. OSFI Guideline B-20 (effective January 1, 2018) and Guideline B-21 (effective March 31, 2019) are residential. They do not apply to commercial mortgages. The commercial-side OSFI framework is the Commercial Real Estate Risk Management regulatory notice published November 21, 2024, which directs federally-regulated lenders to perform "rigorous initial and ongoing valuation risk assessments of the underlying collateral." OSFI sets no LTV cap; each institution sets its own ceiling.

For Ontario credit unions and caisses populaires, the operative document is FSRA's Commercial Lending Guidance, effective July 1, 2024. Under Approach to Principle #1 (Property appraisals), it directs the credit union to provide "an independent and professional appraisal of commercial property by a qualified entity, such as those with credentials issued by the Accredited Appraiser of the Canadian Institute." Among the Big Five, RBC publishes the most explicit requirement list: a current appraisal from an AACI-qualified, bank-approved appraiser; a passing Phase I Environmental Site Assessment; and where applicable a Building Condition Report. TD, BMO, Scotiabank, and CIBC convey their lists privately; do not assume parity. A CMHC-insured multi-residential refinance carries its own requirement: as of November 15, 2024, CMHC requires an appraisal for every MLI submission regardless of unit count.

Step 1 - Get the engagement letter right

The engagement letter prices the assignment, scopes the report, and binds reliance. Four fields carry most of the weight.

Authorized use. CUSPAP 2026 - mandatory for AIC member assignments completed on or after April 1, 2026 - uses authorized use for the use the appraiser permits the report to serve. For a refinance, the authorized use is mortgage financing or renewal underwriting by the named lender. The same property appraised for matrimonial litigation under Rule 53.03 or a deemed-disposition tax filing is a different assignment.

Authorized client. CUSPAP 2026 uses authorized client for the party permitted to rely on the report - usually the lender, often with the borrower as a named intended user. Misnaming the authorized client is the most common reason a report has to be re-issued late. If the file is brokered, the broker, the funding lender, and any syndicate participant must be named accurately before signature.

Scope of work. The appraiser sets the depth required to deliver a credible value for the authorized use, which drives report type, inspection scope, and treatment of the three valuation approaches (income, direct comparison, cost). The engagement letter records the scope and any extraordinary assumptions, hypothetical conditions, or limiting conditions.

Report type. CUSPAP 2026 s. 7.5.3 recognizes three report formats: a Form Report, a Concise Report (brief, narrative format), and a Comprehensive Report (extensive, full narrative, broadest in scope). Most Ontario commercial refinance engagements run as a Concise or Comprehensive report; Form reports are uncommon for institutional commercial collateral.

Step 2 - Assemble the document set

The largest controllable variable on the schedule is the document set. The fastest engagements are the ones where everything below is ready on day one. For deeper treatment see our documents needed for a commercial appraisal checklist; the refinance shortlist:

  • Current rent roll - tenant by tenant, with unit number, square footage, base rent, escalations, recovery method, term commencement and expiry, options, and any free-rent or step-rent terms in effect.
  • Trailing 12-month operating statement (T12), plus the most recent annual statement and budget where available.
  • Leases - executed copies for every tenant, with amendments and extension or termination notices. For anchor tenants on percentage rent, sales reports for the most recent two years.
  • Capital expenditure log for the last three to five years, with planned capex for the next two years where known.
  • Property tax record - the most recent MPAC assessment, the property tax bill, and any pending appeals or reassessment correspondence.
  • Environmental documentation if held - existing Phase I or Phase II ESA, or remediation records. Under RBC's pattern, a current Phase I ESA will run in parallel as a separate engagement.
  • Building Condition Report if one exists or has been ordered in parallel.
  • Title and survey - the most recent parcel register, easements, and the most recent survey or reference plan.

What slows a file is rarely a missing document; it is one the borrower has but cannot locate quickly, or a lease the property manager has not provided amendments for. Pull everything before signing the engagement letter.

Step 3 - Site visit and inspection

The inspection verifies the rent roll against actual unit configuration, measures or confirms gross leasable area, inspects interior and exterior condition, assesses deferred maintenance, identifies functional or external obsolescence, and photographs the asset and its setting. CUSPAP frames desktop, drive-by, exterior-only, and full interior-and-exterior as scope-of-inspection decisions, not report types. A federally-regulated lender on a primary-collateral refinance will almost always require a full interior-and-exterior inspection.

What helps the day run cleanly: a single point of contact who can move the appraiser through every unit, unit-by-unit access where the rent roll shows configuration changes, and the property manager available by phone. A standard inspection of a five-to-fifteen-tenant Ontario commercial asset typically takes a half-day to a full day on site.

Step 4 - Drafting and signed AACI delivery

Drafting runs roughly five to ten business days depending on report type and asset complexity. The income approach work - stabilized NOI derivation, market rent reconciliation, vacancy and collection-loss reasoning, expense normalization, cap-rate selection from an explicit comparable sample, and where appropriate a DCF scenario - is usually the longest single element. Direct comparison runs in parallel: identifying the transaction set, documenting verification, applying adjustments with stated reasoning, and reconciling the indicated values. The cost approach is engaged where asset type or comparable scarcity makes it load-bearing.

Before signature the file goes through the firm's own quality-control check for methodology, internal consistency, and compliance with the authorized use, and any corrections are folded in - CUSPAP does not require a second AACI to peer-review a refinance appraisal. The final step is the AACI member's signed certificate of value: the named designation holder takes professional accountability for the conclusion, and delivery is normally a PDF to the authorized client and any named intended user. Same-day responses to drafting follow-ups (an unusual recovery clause, a square-footage figure, a missing capex receipt) keep the schedule - two-day turn-arounds on three follow-ups is how a 10-day file becomes 16.

What can go wrong

Timeline blowouts. The document set arrives in pieces. The site visit gets pushed because key access to occupied units was not arranged. A specialty asset has only two usable comparable sales in eighteen months and defending adjustments takes a third week. None of this is exotic - it is why we plan against the lender's deadline working backwards. See commercial appraisal turnaround for lender deadlines.

Value gaps versus lender expectations. A 2021-vintage acquisition underwritten at a sub-6% cap rate now sitting inside a wider 2026 range will likely indicate a value below the originated value. That is not a failure of the report; it is the system working as the regulators expect. OSFI's commercial guidance directs that valuations be adjusted where current information indicates a meaningful decline. Run your own LTV and DCR sensitivity at plausible reset rates before the renewal conversation - the report is rarely the surprise; the rate environment is.

Scope creep. A refinance engagement is sometimes asked, mid-stream, to also support a partnership buyout, estate filing, or litigation reference. CUSPAP's authorized-use framework does not let one report serve multiple uses by default; each additional use is a scope change requiring a re-issued report. Decide on the use up front, or scope multiple uses at the engagement-letter stage. For why these decisions move the fee, see our commercial appraisal fees - Ontario cost drivers pillar and the why commercial appraisals cost more than residential explainer.

Frequently asked questions

Does OSFI B-20 apply to my commercial mortgage refinance?

No. Guideline B-20 (effective January 1, 2018) and Guideline B-21 (effective March 31, 2019) are residential mortgage underwriting and mortgage-insurance frameworks only; they do not govern commercial lending. The commercial-side OSFI framework is the Commercial Real Estate Risk Management regulatory notice published November 21, 2024, which applies to federally-regulated lenders. For Ontario credit unions, the operative document is FSRA's Commercial Lending Guidance effective July 1, 2024.

How long does a refinance appraisal take in Ontario?

Standard 10 to 15 business days from engagement letter to signed delivery for a typical income-producing asset where the document set is complete on day one and inspection access is prompt. Complex multi-tenant, mixed-use, and specialty assignments take longer. A separate broker-published national pattern reports full narrative 3-5 weeks, limited-scope 2-3 weeks, desktop 3-7 days, and drive-by 5-10 days (LendCity, 2026) - one broker's observation, not an industry norm. Calibrate against the engagement-letter quote on your file.

Can I choose my own appraiser?

For federally-regulated commercial lenders and Ontario credit unions on primary collateral, effectively no - the appraiser must be on the lender's approved AACI panel. The borrower can usually express a preference within the panel, and on broker-arranged files there is sometimes more flexibility, but the practitioner must hold the AACI designation and be accepted by the funding lender.

What if the value is lower than I need for the refinance?

The most common 2026 conversation. A lower value compresses the available loan amount at any given LTV - the lender does not need to move its ceiling; the denominator does the work. Options are usually some combination of paydown to fit the LTV at the new value, a second-position or mezzanine layer, a longer amortization to restore DCR headroom at the reset rate, or a different lender. None of these are failures of the appraisal; the AACI member's signed conclusion is the professional opinion of value as of the effective date, and the deal economics adjust to that fact.

Further reading

Update log: 2026-05-15 - Initial publication.