Updating the EEI and EFP After Work (Bill 16)

Bill 16 requires the syndicate of a divided co-ownership to document the building, plan maintenance and adequately fund the contingency fund. After major work, updating the building condition assessment (EEI) and contingency fund study (EFP) becomes essential to reflect the current reality. Current as of 2026-07-17, this practical guide explains when, how and by whom these updates should be completed to help your board of directors (board) remain compliant and transparent with co-owners.

In what follows, we will use common terminology: maintenance logbook (also called EUC), condo fees, common expenses, meeting minutes, annual general meeting, DCV, common portions and private portions.

When should the EEI and EFP be updated?

An update is required as soon as work changes the condition, remaining useful life or replacement cost of a major common-portion component. Typical examples include restoration of the building envelope, roofing, parking membranes, plumbing stacks, elevator overhauls, and security/fire-protection systems.

• If a complete replacement is carried out (e.g., a new roof), the EEI must reflect the new life cycle and warranty.
• If partial repairs extend the useful life (e.g., sealing infiltration points), the EEI must adjust the remaining useful life and risks.
• The EFP must then revise its projections and future contributions based on actual costs, construction-inflation indexes and the new work schedule.

Bill 16 amended the Civil Code of Quebec to require a maintenance logbook and a periodic contingency fund study; the co-ownership register must be kept up to date on an ongoing basis (see sections 1070 and 1070.2 C.C.Q.; study-of-the-fund requirements, see sections 1071 and 1071.1 C.C.Q., LégisQuébec). Even if the EFP must be redone on a prescribed cycle, a one-time update after substantial work is a sound governance and document-compliance practice.

Who does what: board, manager and professionals

• Board of directors: oversees the process, approves the update mandate, ensures that supporting evidence is archived and validates communications to co-owners.
• Condominium manager: coordinates the participants, gathers technical and financial documents, updates the maintenance logbook (EUC) and maintains the records.
• Professionals: the EEI and EFP are prepared or updated by qualified individuals who are independent of the work provider (an engineer, architect or other professional authorized under the applicable regulations). Their recommendations inform the budget, contingency fund contributions and planning for upcoming work.

Before awarding the mandate, verify competence and independence. For contractors involved, confirm their licence and compliance with the Regie du batiment du Quebec (RBQ).

The step-by-step process after work

Here is a simple sequence for a board of directors that wants to get straight to the point.

1. Close out the work and compile the evidence

   • Provisional and final acceptances, warranties, as-built drawings, before-and-after photos.
   • Detailed invoices, progress payment statements, payment certificates.
   • Test reports (e.g., asphalt cut tests, building-envelope tests), commissioning records.

2. Update the maintenance logbook (EUC)

   • Describe the work, date, materials, warranties and recommended maintenance.
   • Adjust preventive-maintenance frequencies (e.g., annual joint inspections, drain cleaning).

3. Update the EEI

   • The professional reviews the condition of the affected components and reassesses remaining useful life and risks.
   • Related elements (e.g., balconies following building-envelope work) are also analyzed.

4. Revise the EFP

   • Incorporate actual capital expenditures (CAPEX) incurred and recalculate future replacements.
   • Update the assumptions: construction inflation, fund investment/return rates and indexing.
   • Propose contingency fund contribution scenarios and, if necessary, a special assessment.

5. Governance and communication

   • Present the results to the board of directors; provide co-owners with a clear summary.
   • Incorporate the budgetary impact into the next annual budget, to be adopted at the annual general meeting.
   • Archive in the register: signed reports, warranties, minutes and budget excerpts.

Documents to gather for a smooth update

• Final contract and specifications, change orders, technical data sheets.
• Warranties, compliance reports, relevant location certificates.
• Previous EEI and EFP, maintenance logbook (EUC), most recent financial statements.
• Insurance documents and contractor certificates, RBQ licences, releases.

Realistic timelines and tips

• Allow 2 to 6 weeks to gather the evidence and update the EUC/maintenance logbook.
• Depending on the scope, the revised EEI/EFP may require an additional 4 to 10 weeks from the professionals.
• Save time: mandate the EEI and EFP at the same time when the work is substantial; provide an organized digital file.

For an overview of record-keeping responsibilities and tools, see our administrative management services and financial management services.

Impacts on condo fees, common expenses and the budget

An updated EFP adjusts the trajectory of contingency fund contributions. After a major replacement has already been paid for, your contributions may stabilize in the short term, but rise again to prepare for the next cycles (e.g., 20-25 years). Construction-inflation assumptions and labour costs have a major influence on these projections.

• Annual budget: the board of directors incorporates the recommended contingency fund contribution into the budget for the financial year submitted to the annual general meeting. Co-owners vote on the budget and, indirectly, on common expenses.
• Special assessment: if the EFP reveals a shortfall in the short term, the declaration of co-ownership may provide for a call-for-funds mechanism. The board of directors must then clearly explain the reasons and the time horizon.
• Contingency fund: the objective is to achieve balances consistent with the actual replacement curve, reducing the risk of surprise assessments.

To explain the impacts in plain language, a visual summary (replacement schedule, projected balances) is very helpful. Publish it in the co-owner portal and place it in the register (section 1070 C.C.Q.).

Compliance, records and traceability (Bill 16)

Bill 16 strengthens record-keeping and access to documents, including the EEI, EFP, maintenance logbook (EUC), insurance documents, warranties, contracts, minutes and financial statements. Without quoting the provisions in full, sections 1070 and 1070.2 C.C.Q. address, among other things, the register and maintenance logbook; section 1071.1 deals with the contingency fund study and its frequency. Consult the text on LégisQuébec – Civil Code of Quebec. You can also view the legislation that amended these sections, often called “Bill 16”: S.Q. 2019, c. 28.

Good traceability practices:

• Keep an internal checklist: who approved what, when, and where each document is archived.
• Link actual expenses (general ledger) to the line items in the updated EFP and planned replacements.
• Record in the board minutes that the reports were received and the decision to update was made; file a summary with the annual general meeting materials.
• For condo sales, the broker or notary may request the reports and a certificate from the syndicate; see the OACIQ.

The RGCQ also publishes good-practice guides on applying Bill 16 to divided co-ownership.

Quick example: after a roof replacement

In a divided co-ownership under our management, the syndicate replaced the roof and added insulation. Results:

• EEI: new remaining useful life of 25 years, reduced infiltration risks and defined annual maintenance.
• EFP: adjustment of the costs of future replacements (roofing + accessories), and revision of inflation assumptions and contribution scenarios.
• Communication: an illustrated summary was provided to co-owners; it was filed in the register; the budgetary impact was explained at the following annual general meeting.

This type of update strengthens trust, reduces disputes and aligns condo fees with reliable data.

FAQ

Q1. Does the EFP need to be updated if the work is minor?
If the work does not affect the remaining useful life or replacement cost of a major asset, you can wait until the next periodic review. However, you should still update the maintenance logbook (EUC) and the register.

Q2. Who can sign the updated EEI/EFP?
Under the Civil Code (see section 1071.1 C.C.Q.), the contingency fund study must be prepared by a qualified and independent professional. The EEI is generally signed by an engineer or architect with building expertise.

Q3. Must a special assessment be approved to implement the revised EFP?
Not necessarily. Adjusting contingency fund contributions is normally incorporated into the annual budget adopted at the annual general meeting. A special assessment may be considered if a significant and immediate shortfall is identified; refer to your declaration of co-ownership and, if necessary, consult legal counsel.

For further reading, explore our blog and our services focused on Bill 16 compliance.

This article provides general information and does not constitute legal advice. Consult a lawyer or notary for your particular situation.

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