Occupancy Permits and Change of Use in Winnipeg: What to Check Before You Lease

In Winnipeg, a building occupancy permit identifies how a commercial space can be used. You need one before you open after a substantial renovation or a change of use. Whether a new tenant needs one often depends on the permit the last tenant left behind, so it's worth checking before you sign a lease.

This guide is for tenants and landlords of stores, offices, restaurants and clinics. It's based on City of Winnipeg documents checked on October 15, 2026. It's general information, not legal advice: the City interprets the code for your space, so confirm your plans with its Occupancy Permit Branch.

When does a commercial space need an occupancy permit in Winnipeg?

The City's occupancy bulletin (2023-005-A/B, July 19, 2023) says a building occupancy permit is required for “the construction, substantial alteration or change of use of portions of most buildings, with the exception of single-family dwellings, two-family dwellings and multi-family dwellings without shared exits.”

Under the Winnipeg Building By-law No. 4555/87, the bulletin says it is “your responsibility to obtain a final or interim building occupancy permit prior to occupying a space.” The City's occupancy page lists who needs one:

• A building owner constructing a new building or addition
• An existing tenant who has to vacate the building, floor, wing or unit for alterations, or whose alterations the City decides are significant enough to need one
• A tenant expanding their unit within a building
• A tenant who wants to increase the occupant load of the space
• A new tenant establishing a use that doesn't have a valid occupancy permit in place
• A new tenant making alterations that the City decides warrant one

Occupying starts before opening day. The bulletin allows construction and the delivery of fixed equipment and furnishings before the permit. It prohibits stocking shelves, installing computers, training staff, meeting clients and conducting business until the permit is issued. Our guides cover moving furniture and computers into an office and who is responsible for site safety before the permit.

Does a new tenant need a new occupancy permit?

Not always. Since April 4, 2022, the City no longer requires a building occupancy permit “for a change in tenant/occupant only,” according to its Change in Occupancy Requirements sheet (updated March 2023). The change aligned occupancy permits with the Manitoba Building Code. The sheet says a new permit is not required if:

• No change in use is planned under the Manitoba Building Code
• No construction work is planned that would otherwise trigger the need for an occupancy permit
• No increase in size, or change in dimensions, of the tenant space is planned
• No increase in the occupant load (the number of people using the space) from the previous use is planned

Administrative changes, such as a new business name or owner, don't need one either. The catch is the previous tenant: the City's occupancy page says a new tenant establishing a use without a valid occupancy permit still needs one. The unit's existing permit matters as much as your own plans.

What counts as a change of use?

For occupancy permits, the City looks at use as the Manitoba Building Code defines it, not as zoning does. Its examples are a retail space becoming a restaurant, and a manufacturing facility changing from low to high hazard. Its March 2023 sheet says a change of use needs an occupancy permit and “may or may not include alterations.”

Even with no construction, a change of use starts with a building permit application. The City says that to get an occupancy permit, you must first apply for a building permit, and its commercial permit form (CADS, October 2025) has a box for a change of use with “no work proposed or limited to cosmetic upgrades.”

The same form says a change from one major occupancy classification to another “may require the involvement of an architect and/or engineer(s).” In a Part 3 building, a change in major occupancy classification is listed as complex work, which needs drawings sealed by an architect or engineer.

Selected groups, as listed on the City of Winnipeg's occupancy permit definitions page, which lists all 18. The City decides which group your use falls into.

Zoning is a separate approval. The same March 2023 sheet notes that “a zoning use is different than a building code use and must be established or changed through a development permit application.” Confirm the zoning before you pay for plans.

Restaurants and clinics add their own approvals on top of the City's, such as a public health plan review or X-ray approvals. The restaurant guide above covers food premises, and our guide to clinic renovation permits covers medical and dental spaces.

How can you check a unit's occupancy history before you sign?

Start with the City's free online searches, then ask the landlord for a centralized property file search before you commit. Together they show what the unit is approved for and whether anything is outstanding.

Sources: City of Winnipeg permit search pages, centralized property file search page and zoning letters form (updated May 2026), checked October 15, 2026.

A tenant can't order a CPFS alone. The authorization letter must come from the registered owner, on company letterhead for a commercial property, with a signature that “cannot be electronically generated.” Ask the landlord to provide the letter or order the search, and build the 15 business days into your lease timeline.

In the construction permit search, a status of “closed with an incomplete inspection” means the City closed the permit without its standard inspections. The City says that work “was not audited by the City through the inspections process,” so ask the landlord about any permit with that status.

Why check at all? The City's occupancy page says by-law changes aren't retroactive, but if a space or use “was not legally established through the building permit process,” the current tenant “could be ordered to obtain an occupancy permit as per current bylaw requirements.” An unpermitted past use can become the new tenant's problem.

Checking a house rather than a commercial unit? Our guide to checking a Winnipeg home's permit history covers the residential side.

Do occupancy permits work the same way outside Winnipeg?

Not exactly. The Province says building, plumbing and occupancy permits in Manitoba are issued by one of three authorities: the municipality, a planning district or the Province's Inspection and Technical Services. Which one depends on where the building is and whether it falls under Part 9 or Part 3 of the Manitoba Building Code.

The Province requires an occupancy permit before occupying any newly constructed, renovated or repaired building where a building permit was issued, but not for the construction, renovation or repair of a one- or two-family dwelling. Winnipeg's 2022 change-of-tenant rule is the City's own, so ask the local authority how it treats a new tenant.

Which occupancy questions should you settle with the landlord?

Put these questions to the landlord, and get the answers in writing, before the lease is final:

• What occupancy permit does the unit have, for what use and occupant load, and is it final or interim?
• Is our use allowed under the zoning, or will it need a development permit?
• Does our plan change the use, the unit's size or the occupant load, or include work that needs a permit?
• Will you authorize a centralized property file search, and are there open permits, orders or violations?
• Who applies for the building and occupancy permits, and who signs the letter of authorization the City asks for?
• Who pays for any code upgrades the City requires because of our work?
• Does the lease start date leave time for permits, inspections and the occupancy permit?

The City says an occupancy permit application can be made by the building owner or an authorized agent: the property manager, the intended tenant, the general contractor or a designer. Its commercial permit form also needs the owner's or property manager's letter of authorization for the intended use. Have a lawyer review the lease itself.

Next step

An on-site visit before you sign shows whether your layout fits the space and which approvals it is likely to need. Bridgeland Builders handles retail store renovations, office renovations, restaurants and clinics in Winnipeg and nearby communities, and coordinates permits and inspections with the City or the local municipality.

Book a free on-site visit for a free written quote; we reply within one business day. You can also see all our commercial renovation services.