Indoor Playground Premises in Ontario: Occupant Load, Licensing, Play Equipment and the Lease

By Jatin Dua · Broker of Record, RE/MAX Quantum Realty · Updated 18 October 2026 · 10 min read — what an indoor playground or kids’ party place needs for egress, occupant load and fire safety, which licences and equipment rules apply, and the lease.

Looking for indoor playground space in Toronto or the GTA? Tell me what you need and I will send you units that fit, with the zoning and the lease checked before you commit.

Why a play centre is an assembly use, not a store

Most indoor playgrounds I see in the GTA go into former retail units, warehouse bays in employment areas, or the end unit of a big plaza. The trap is that the unit was approved for one kind of occupant and you are about to bring in another. A clothing store might have a few dozen shoppers spread across the floor. A play centre on a Saturday has parents seated at party tables, children climbing, and staff moving between rooms. The Building Code and Fire Code treat that as an assembly occupancy, and the exits, washrooms, fire alarm and fire separations the unit needs follow from that.

Ontario’s Building Code is now O. Reg. 163/24, which adopts the National Building Code of Canada 2020 together with Ontario’s own amendments; the version on e-Laws refers to an Ontario amendments document dated 1 October 2026. Projects permitted under the old code (O. Reg. 332/12) before the end of 2024 could continue under it, but a new fit-out today is designed to the current code. Your architect or qualified designer classifies the occupancy and confirms what the existing shell can support. I ask for that review before a lease is firm, because the answer can be that the unit needs a second exit or a sprinkler upgrade that the rent never priced in.

If you are weighing several venue formats, my notes on entertainment venue premises and banquet hall premises cover the larger assembly cases.

Occupant load: the number that decides the unit

Under the Ontario Fire Code (O. Reg. 213/07), the number of people in a room or floor space in an assembly occupancy cannot exceed the occupant load for its use. That load is the lower of two figures: the count worked out from the Fire Code’s floor-area table, or the number of people the exits can serve under the Building Code. So a bigger unit does not help if the doors and exit widths stay the same.

The Fire Code table gives area per person for different kinds of space. The ones that matter most for a play centre are below, along with the posting rules.

The equipment footprint, storage and staff areas don’t hold patrons, so the usable number is usually far below the gross unit size divided by a table figure. Ask your designer for a stamped occupant load per room early, and plan pricing, party sizes and staffing to that number.

Fire safety, decorations and the fire safety plan

The Fire Code’s fire safety plan section applies to every building containing an assembly occupancy, with no minimum occupant load. In a multi-tenant plaza that plan is often the landlord’s responsibility for the building as a whole, but your unit, your staff and your evacuation procedures have to fit into it. Ask the landlord for the current plan and who maintains the fire alarm, sprinklers and emergency lighting.

Two other Fire Code points come up in play centres:

• Textiles and netting. Drapes, curtains, netting and similar decorative materials used in the access to exits of an assembly occupancy, and in assembly occupancies with an occupant load over 100, must meet CAN/ULC-S109 for flame resistance. Ask your play equipment supplier and decorator for test documentation on netting, fabric panels and themed decor.
• Combustible accumulation. The Fire Code prohibits accumulating combustible materials where they create a fire hazard, and bars storage in exits, service rooms and ceiling spaces. Party supplies, balloons and boxes of foam mats stacked in the corridor are a common inspection finding.

Whether your unit needs sprinklers or a fire alarm depends on the building’s classification, area and construction under the Building Code. That is your designer’s call, not something to assume from the last tenant.

Licences and approvals before you open

Toronto amusement establishment licence. Since 1 January 2025, Toronto Municipal Code Chapter 545 has an amusement establishment category (Article LII, added by By-law 492-2024). It covers premises that offer, or provide space for, amusement activities such as bowling, arcades, trampolines, rebound tumbling, mini golf, roller skating rinks and other like activities, but not fitness facilities, recreation centres or community centres. Indoor playgrounds are not named in the list, so ask Municipal Licensing and Standards whether your concept is captured. If it is, the City requires an approved zoning review before you apply, liability insurance of at least $1,000,000 for bodily injury or death and $25,000 for property damage with the certificate deposited with the City, a list of persons in authority with at least one on site during hours, and any TSSA licence and device permits that apply. If you add trampolines, the by-law requires one first-aid-certified supervisor for every 12 trampoline units, one person per unit at a time, and a patron register.

TSSA and amusement devices. Ontario’s amusement devices regulation (O. Reg. 221/01) covers devices that entertain people by moving them. Its exemption list includes children’s play space and equipment covered by the CSA Z614 and ASTM F1918 (soft contained play) standards, dry slides under set height, angle and speed limits, and air-supported pillows under 900 mm thick without inflated walls. Inflatable bouncers and structures with inflated walls are not on that list, so get a written answer from TSSA before you buy them.

Food. If you sell or serve food, Toronto Public Health must be notified before you start, the premises falls under the provincial Food Premises Regulation, and inspection results are published on DineSafe. Toronto also licenses eating and take-out food establishments under Chapter 545. If you only allow families to bring a cake, confirm with the health unit how that is treated.

Outside Toronto. Mississauga’s business licence list includes amusement arcades, banquet halls and restaurant or retail food businesses. Check with Mississauga, Brampton, Vaughan or Markham licensing before you sign, because a play centre may or may not fit one of their categories.

Play equipment standards: what CSA Z614 does and does not cover

Owners often assume CSA Z614 is the rulebook for an indoor play structure. The current edition, CSA Z614:20 (reaffirmed 2025), is titled Children’s playground equipment and surfacing. CSA’s own scope summary says it applies to outdoor public-use playground equipment, and it expressly excludes soft, contained play equipment with controlled public access, such as that provided in commercial establishments. Soft contained play is generally built to ASTM F1918, which is also the standard the TSSA exemption refers to.

What to ask for when you buy or inherit equipment:

• The manufacturer’s statement of which standard the structure was designed and certified to, and the edition.
• Installation drawings with anchoring details, which your landlord and structural engineer will want if the structure is bolted to the slab or hung from the roof framing.
• Flame-spread or flame-resistance documentation for pads, netting and panels.
• An inspection and maintenance schedule your insurer will accept.

Zoning, change of use and the drop-off question

In Toronto, Zoning By-law 569-2013 defines a recreation use as premises used for sports, physical play or exercise, and an amusement arcade as premises for entertainment with amusement devices such as arcade games. An indoor playground reads most naturally as a recreation use, but adding a bank of arcade games can change the analysis. Recreation use appears in the commercial residential (CR) zone with conditions, and in the employment industrial (E) zone a recreation use must be on a lot fronting a major street on the Policy Areas overlay map. Ask for a preliminary zoning review on the exact address; site-specific exceptions are common in plazas.

Ontario’s Building Code Act, section 10, says no one may change the use of a building or part of a building in a way that increases the hazard, as determined under the Building Code, without a permit, even if no construction is planned. Toronto Building says the same on its permit page. A retail or warehouse unit becoming a play centre is the textbook case. My change of use guide walks through the process.

The lease clauses that matter for an indoor playground

1. Use clause. Name the use broadly: indoor children’s play centre, birthday parties and private events, ancillary food and beverage service, retail of toys and party goods. A narrow "children’s play area" clause can block the party revenue that makes the model work.
2. Conditional period tied to approvals. Make the lease conditional on a satisfactory zoning review, a designer’s confirmation of the occupant load you need, and the change-of-use building permit, with your deposit returned if any fails.
3. Landlord’s base building work. Spell out who pays for a second exit, washroom upgrades, fire alarm tie-ins and sprinkler changes. These are the costs that sink play centre budgets.
4. Ceiling and structure. Get consent in the lease to anchor play structures to the slab or hang them from the structure, subject to an engineer’s letter, and agree that clear height and structure are as represented.
5. Insurance. Match the lease’s liability limit to what your insurer will write for a play centre, and make sure it at least meets any City licence minimum. Ask the landlord to accept your certificate format before signing.
6. Hours and noise. Confirm evening and weekend hours, party music and neighbouring tenants. Plazas with medical offices or residential above often restrict amplified sound.
7. Parking and pickup. A Saturday with four parties can fill a small plaza lot. Ask for a parking count and any exclusive or shared spaces in writing.
8. Exclusive use. Ask for an exclusive on children’s play and party venue uses within the centre, so the landlord doesn’t lease next door to a competitor.
9. Restoration. Limit the obligation to remove play structures and padded flooring at lease end, or agree a fixed restoration amount.

For the general mechanics of use clauses, exclusives and radius restrictions, see my commercial lease use clause guide.

Deal-killers to check on a viewing

• Only one exit. Many deep plaza units have a front door and a rear service door that opens into a shared corridor. Ask your designer whether the exits can serve the occupant load you need.
• Washroom count. Assembly occupancies need more fixtures than a store. Adding washrooms in a unit with the drain line on the wrong side means cutting the slab.
• Low or obstructed ceiling. Multi-level play frames need clear height. Measure under the lowest beam, duct or sprinkler line, not to the roof deck.
• Sprinkler coverage. If a multi-level structure blocks sprinkler heads, the system may need changes. Ask for the sprinkler drawings.
• Zoning that only says retail. If recreation use is not permitted at the address, you are looking at a minor variance or rezoning, which takes months.
• Second floor units. Stairs, an elevator and egress for a crowd of small children and strollers are hard to solve upstairs.
• Kitchen expectations. If you plan to cook rather than reheat, you may need ventilation and plumbing the unit doesn’t have. Decide the food model before you choose the unit.

Where I fit

I help play centre and party venue operators find units across Toronto and the GTA, from end units in Etobicoke and Mississauga plazas to employment-area bays in Vaughan and Brampton, and I check zoning and the exit and washroom picture before you commit. I read the lease with you and push for approval conditions and base building work wording like the clauses above, and if you are buying an existing centre the retail store valuation tool gives a first read on price.

Frequently asked questions

Sources

• City of Toronto — Amusement Establishment licence — activities covered, zoning review, insurance, fees
• City of Toronto — Municipal Code Chapter 545, Licensing — Article LII amusement establishments, definitions, trampoline rules
• Ontario e-Laws — O. Reg. 213/07, Fire Code — occupant load table, posting, fire safety plan, textiles
• Ontario e-Laws — O. Reg. 221/01, Amusement Devices — TSSA scope and exemption list
• CSA Group — CSA Z614:20 Children's playground equipment and surfacing — outdoor scope, soft contained play exclusion
• Ontario e-Laws — Child Care and Early Years Act, 2014 — patron service exemption, licence requirement
• Ontario e-Laws — Building Code Act, 1992 — section 10 change of use permit
• City of Toronto — Zoning By-law 569-2013, Chapter 800 Definitions — recreation use and amusement arcade
• City of Toronto — Food business regulations and licensing requirements — notify Toronto Public Health, DineSafe

Related reading

• Entertainment venue premises in Ontario
• Child care centre premises
• Martial arts and dance studio premises
• Banquet hall premises
• Change of use permits for tenants
• The use clause in a commercial lease