RL-31 for Quebec Condos: Who Must Issue It?

Every winter, several co-owners who rent out their condo wonder whether they must file the RL-31 slip. In a divided co-ownership, responsibility can seem unclear between the co-owner, the syndicate and even the condominium manager. Here, in simple terms, is who must issue it in Quebec, when to do so and how to handle it without hassle.

What is the RL-31 slip, and what is it used for?

The RL-31 is a Revenu Quebec form confirming that a person lived in an eligible dwelling on December 31. Tenants use the information on the RL-31 to claim, if eligible, the solidarity tax credit.

In practical terms, the landlord must send the RL-31 to Revenu Quebec and provide a copy to the eligible occupants of the dwelling. The obligation applies to each eligible rental dwelling occupied on December 31. In the event of an omission or delay, Revenu Quebec may impose administrative penalties.

For detailed rules, consult Revenu Quebec:

• Official information about the RL-31 slip
• The solidarity tax credit and its eligibility criteria

In a divided co-ownership: who is responsible for issuing the RL-31?

In a divided co-ownership, a condo is a private portion owned by a co-owner. When the co-owner rents out the private portion to a tenant who occupies it on December 31, the co-owner-landlord must prepare and provide the RL-31. The syndicate is not the landlord of the private portion and therefore generally does not have to issue an RL-31 for units owned by co-owners.

This division of responsibility follows from the syndicate’s legal role: administering the common portions and safeguarding the building, not managing leases for private portions (see section 1039 of the Civil Code of Quebec). The board of directors may, however, remind co-owner-landlords of the deadlines and help ensure that information is circulated effectively.

Possible, but less common, exceptions:

• The syndicate is the landlord of a dwelling it owns (for example, a former caretaker’s dwelling that became a common portion for residential use and is rented out). In this specific case, the syndicate must prepare the RL-31 for that dwelling.
• The declaration of co-ownership provides for a specific mechanism under which the syndicate manages a residential lease for a portion it administers. If, in practice, the syndicate acts as the landlord of an eligible dwelling, it assumes the obligation to issue the RL-31 for that dwelling.

In all other cases, for condos rented out by co-owners, the owner-landlord issues and submits the RL-31.

Special condo situations: roommates, subletting, parking, vacant dwellings and short-term rentals

Several common situations in divided co-ownership can cause confusion. Here is how to handle them correctly from an RL-31 perspective.

• Roommates in the same condo: The co-owner-landlord prepares one RL-31 for the dwelling, listing all eligible occupants present on December 31. Each adult occupant will receive a copy.
• Subletting the unit: If a head tenant sublets the entire condo, it is generally the sublessor (the tenant who sublets) who must prepare the RL-31 for the subtenant occupying it on December 31. The original owner does not prepare an RL-31 for the subtenant unless the owner remains the direct landlord within the meaning of Revenu Quebec.
• Change of ownership during the year: The RL-31 must be prepared by the person who is the landlord of the dwelling on December 31. If the sale closed in November, the new purchaser who becomes the landlord issues the RL-31. At the time of the sale, make sure to exchange the necessary information to avoid any duplicate or missed filing.
• Dwelling vacant on December 31: No RL-31 is required for that year because no one occupied the dwelling on the reference date.
• Short-term rental (tourist accommodation): Short-term tourist accommodation stays do not qualify for the solidarity tax credit. An RL-31 is therefore not required for these rentals.
• Renting a room only: The RL-31 applies to an eligible dwelling (rooms forming a self-contained residence). Renting a room without a private kitchen or bathroom generally does not constitute an eligible dwelling; no RL-31 is then required.
• Parking space and storage space (locker): Renting only a parking space or locker does not trigger the issuance of an RL-31. If these items are included with a condo rented as a dwelling, they are simply part of the services associated with the dwelling.

For definitions and examples of eligible dwellings, refer to Revenu Quebec’s guidelines.

When and how to prepare the RL-31 (form and submission)

Here is a simple process to help you meet the requirements and deadlines.

1) Confirm that the dwelling is eligible and was occupied on December 31.

• Confirm that the condo constitutes an eligible dwelling and was occupied on the reference date.
• Identify all adult occupants on December 31 (roommates, spouse or partner, etc.).

2) Gather the required information.

• Landlord’s contact information (yours) and business number, if applicable.
• Full civic address of the dwelling, postal code and, if applicable, unit number.
• Names and contact information of the eligible occupants on December 31.

3) Prepare the RL-31 online.

• Use Revenu Quebec’s online services (My Account for businesses) to submit the RL-31 slips and, if necessary, the summary. The tool also makes subsequent corrections easier.
• The RL-31 form and its instructions are also available on the Revenu Quebec website.

4) Meet the deadline of the last day of February.

• Submit the slip electronically to Revenu Quebec and provide a copy to the eligible occupants no later than that date.
• Keep proof of submission and a copy for your records in case of an audit.

5) Correct errors promptly.

• If any information is inaccurate (name, address, occupants), promptly prepare an amended RL-31 according to Revenu Quebec’s procedures to limit the impact.

Good practices in divided co-ownership:

• Inform your building’s board of directors that your unit is rented so it can circulate general reminders to co-owner-landlords (without collecting sensitive information).
• Keep an up-to-date register of your leases and occupants’ contact information. Rigorous administrative management avoids last-minute follow-ups. See our administrative management services and our financial management support to structure these processes.

If you are a non-resident co-owner, make sure your representative in Quebec has the access credentials needed to prepare the RL-31 on time. Arrange these credentials well before February to avoid delays.

FAQ

Can the syndicate centralize the issuance of RL-31 slips for all co-owners?

Legally, the syndicate is not required to do so, and it is generally not the landlord of the private portions. The board of directors may, however, circulate an annual reminder and, with consent, offer logistical support (a communication template, calendar). Any centralization must comply with tenant data confidentiality requirements and the declaration of co-ownership.

Is an RL-31 required for a furnished condo?

Yes, if the tenant’s principal residence was there on December 31 and the rental does not constitute short-term tourist accommodation. Furnishing the dwelling neither removes nor adds an RL-31 obligation; the key factor is eligible occupancy on December 31.

What happens if I forget to issue the RL-31?

Your tenants may be unable to claim the solidarity tax credit correctly, and Revenu Quebec may impose penalties for late filing. Prepare the RL-31 as soon as possible and provide the copy to your occupants. For correction and late-submission procedures, refer to Revenu Quebec’s official guidelines.

Useful resources:

• Revenu Quebec — RL-31: Information about a rented dwelling
• Revenu Quebec — RL-31 form and instructions
• Revenu Quebec — My Account for businesses (online services)
• Revenu Quebec — Solidarity tax credit
• LégisQuébec — Civil Code of Quebec (see section 1039)

For more information about managing your syndicate and administrative compliance:

• multiRent — Our services (administrative management)
• multiRent — Our services (financial management)
• multiRent Blog — Practical advice on divided co-ownership

This article provides general information and does not replace advice from a tax specialist or accountant. Refer to Revenu Quebec and the CRA for the exact requirements.

Do you manage a Quebec divided co-ownership? Explore our packages or contact us to assess your needs.