Vancouver Put a Price on Filing Before September 30. It Comes to $370 Million.

In the report Vancouver Council approved in July, in a list of downward adjustments to projected revenue, sits the City's own estimate of what its September 30 deadline is worth to the people who beat it:

$370-380 million related to ACC in-stream rate protection¹

The Amenity Cost Charge programme it sits inside is $480 million over 2027–2036.¹ The City is forecasting that roughly three-quarters of the money the new charge would otherwise raise will not be collected, because of projects that get their applications in before the charge takes effect.

That is the most direct evidence available that the deadline is worth taking seriously. Nobody concedes $370 million to a transition rule that does not matter.

What actually happens on September 30

The ACC is a new city-wide charge on new floor area, payable at building permit issuance, on top of Development Cost Levies. It applies everywhere except areas excluded on Map 1 of Schedule A of the by-law.¹

The City's published position is one sentence, and it is the operative rule:

"Applications in-stream (including rezoning, development permit, and building permit) before September 30, 2026, will not be subject to the ACC By-law, and will be expected to continue with applicable CAC and public art contributions. To be eligible under the new framework, in-stream applications must be re-submitted or amended after September 30, 2026."²

Note what that covers. A rezoning application counts. A development permit application counts. You do not need to be at building permit. And note the trap in the second sentence: re-submitting or amending an in-stream application after September 30 is what moves it onto the new framework.

If you read the statute yourself, you will get a different answer

This is worth stating plainly, because anyone doing their own legal research will hit it.

Vancouver Charter s. 523N(2) disapplies an initial ACC by-law where a precursor application is in-stream on the date the initial by-law is adopted.³ Council approved the framework on July 21.⁴ Read the statute alone and you would conclude the window shut in July, and that September 30 is merely when the charge switches on.

The City does not administer it that way. Its report describes the same provision as exempting applications "submitted prior to the effective date of the initial ACC by-law",¹ and its public page tells applicants to file before September 30.² The City assesses and collects the charge, so its reading is the one that governs what you pay.

The safe way to hold both: an application in-stream on or before the adoption date has the stronger, statutory claim. An application filed between then and September 29 rests on the City's published administrative position. Both mean the same thing in practice — file before September 30 — but they are not equally armoured, and if you are relying on the second, do not also amend it.

How long the exemption lasts, and why "five years" is real

The exemption is not permanent. Under the Charter it runs "until such time as the by-law is amended", and once amended, a rolling 12-month protection applies instead.¹³

Here is the part that is actually clever, and that a reader would not guess. The by-law contains four years of pre-approved rate increases — September 30 of 2027, 2028 and 2029, at 3.0% a year.¹ Those scheduled steps are written into the original by-law, so triggering them is not an amendment. The City says so in terms:

"By approving inflationary rate increases out to 2029, the City can delay amending the by-law until 2030, providing in-stream applications 5 years to reach building permit issuance and be rate protected from the ACC."¹

So the widely repeated "up to five years" figure is not press embroidery. It is the City's own stated design, with a stated mechanism: pre-approve the escalations, avoid amending, and the clock in s. 523N(3) never starts. The report is careful to add the caveat, and so should anyone quoting it — "an amendment to the ACC rates before 2030 may result in a reduced period of in-stream protection".¹

What it costs if you miss

Table B of Schedule C, read from the by-law in Appendix A.¹ Rates are per square metre of floor area.

Read the apartment row again. It is not a 3% step. Council resolved that the rate for residential above 1.5 FSR "be phased in over a two-year period, with:

1. a 50% reduced rate effective September 30, 2026, and 2. the full rate

effective September 30, 2027."¹ The full calculated rate is $107.64 per square metre — a round $10.00 per square foot — and 2026 is being charged at half of it.

So an apartment project has two different deadlines, a year apart. File before September 30, 2026 and you are exempt. File after, and you pay $53.82 for a year, then $110.87 — a 106% increase on 2027-09-30. On 8,000 m² of qualifying floor area that step alone is about $456,000.

Under s. 3.1(b), the rates in effect at 12:01 a.m. on September 30, 2029 "remain in effect unless and until this By-law is amended or repealed."¹

There is a second, narrower protection for everyone who misses the first one. By-law s. 3.2 says a Table B rate increase "has no effect" if the building permit issues within 12 months of the increase and a precursor application was in-stream on the date of the increase — "unless the payer agrees in writing that the rate increase should have effect."¹ Read that last clause twice before signing anything.

Credits, and the way to lose one

If you hold an approved rezoning with a secured CAC, you may not have to pay twice for the same amenity. The by-law provides two credits:¹

• Full ACC credits for projects with approved rezonings and secured CACs

before September 30, 2026, "where development proceeds without additional density or amendments to the CAC within that approval."

• Partial ACC credits where an amendment increases density but does not

amend the CAC, so ACCs are payable only on the incremental density.

And the sentence to underline: "any rezoning that amends the CAC after September 30, 2026 will not be eligible for an ACC credit, and any new CAC negotiation will factor in the applicable ACC."¹ Amending your CAC after the transition date destroys the credit outright.

Two other things move the same day

Public art. September 30, 2026 is the transition date after which new rezoning applications stop contributing to public art and contribute through the ACC instead. In-stream applications submitted before it "will continue to be subject to the public art policy". The City counts roughly $25 million in already-secured public art contributions in the pipeline.¹

Waivers survive. Table A keeps a 100% ACC waiver for For-Profit Affordable Rental Housing Class A and 86.24% for Class B.¹ Table C charges school use $5.49 per square metre, and child care and temporary buildings a flat $10.00 per building permit.¹

What to do before September 29

1. File anything you can. Rezoning, DP or BP all establish in-stream status.

The City names all three.²

1. Then leave it alone. Re-submitting or amending after September 30 moves

you onto the new framework.² The same logic kills ACC credits if what you amend is the CAC.¹

1. Check your rezoning's CAC status if you hold one, and confirm the credit

before the date rather than after.

1. Re-run pro formas for anything filing after. ACC is additive to DCL, not

a replacement, and DCL rates are separately held at their December 2025 reduction.¹

1. If you are above 1.5 FSR and cannot file in time, the September 2027 date

is now the one that matters, and the s. 3.2 12-month window is the only thing standing between $53.82 and $110.87.

The City has been unusually explicit about why the transition is this generous. It priced the concession at $370–380 million and wrote it into the revenue forecast anyway, on the reasoning that recent rezonings need "sufficient time to move through the approval process and not be subject to an additional charge they were not anticipating."¹

That reasoning has an expiry date on it, and the date is September 30.