REDMA Early Marketing Period Frequently Asked Questions

BCFSA launched the pilot to provide the option for an extended REDMA early marketing period for development projects of 100 or more development units and to increase data collection related to REDMA. The pilot aims to assess the effects of REDMA’s early marketing period on the development industry, as well as address industry concerns about the 12-month period by providing developers with additional time to secure necessary permits and meet their financing thresholds. BCFSA envisions this pilot as an opportunity to gain important insights on trends in the development industry. 

A project that meets the program’s eligibility criteria of 100 or more development units can generally expect approval for participation in the pilot program, unless there is or has been any significant non-compliance with REDMA by the developer.

For the purposes of pilot eligibility, ‘development unit’ has the same meaning as defined in REDMA. Per REDMA, a ‘development unit’ means any of the following in a ‘development property’:

(a) a subdivision lot;

(b) a bare land strata lot;

(c) a strata lot;

(d) a cooperative interest;

(e) a time share interest;

(f) a shared interest in land; and

(g) a leasehold unit.

If the rental unit or below-market unit meets the definition of a ‘development unit’ under REDMA, it will count towards the pilot eligibility threshold.

BCFSA is implementing its Early Marketing Period Pilot Program due to the perceived challenges larger developments are facing in the present economic environment. Given the complexity and scale of larger developments, obtaining municipal building permits and meeting sales targets to obtain financing within the current 12-month early marketing period can be challenging. This challenge for large scale developments has been amplified by current market conditions, including factors such as interest rate hikes, increased inflation, and economic uncertainty. Therefore, the pilot is targeted at developments with 100 or more development units to address these unique challenges and ensure the feasibility and success of larger projects in the current economic climate. BCFSA will review all applications on a case-by-case basis and reserves the right to approve an application for a project that is close to the 100-unit target, based on all of the specifics of the project.

During the pilot, BCFSA will continue to monitor its impact on both consumers and developers.

Yes.  BCFSA provided a transitional period for existing developments to apply to participate in the pilot.  This transitional period ended on June 30^th, 2025. If a developer with an active project wishes to participate in the Pilot, and allow marketing for an additional 18 months, the developer will be required to file a new disclosure statement. 

No, unless the developer files a new disclosure statement. The 18-month early marketing period permitted under the pilot program is calculated from the date the disclosure statement was filed. If a developer does not file a new disclosure statement, acceptance into the pilot program would only result in a six-month ‘extension’ of the early marketing period.

For example, if a developer filed a disclosure statement for its project on March 1, 2024, and was subsequently accepted into the pilot program, the early marketing period deadline would be ‘extended’ from March 1, 2025 (12-months after the disclosure statement was filed) to September 1, 2025 (18-months after the disclosure statement was filed).

Purchasers who entered into contracts before a project participates in the pilot program may have a 12-month rescission right, and purchasers who entered into contracts during a project’s participation in the pilot program may have an 18-month rescission right.

Yes. If each development project has 100 or more development units, each one would be eligible to participate in the pilot. A separate exemption request is required for each project.

Yes. Phased developments, where there are more than 100 development units across all phases of the development, are eligible to participate. Only one exemption application is required across all phases of the project. The application should be submitted prior to, or concurrently with, the filing of the initial disclosure statement.

Yes. In order to participate in the pilot, a developer must request and receive an exemption under section 20 of REDMA. The fee for filing an application for an exemption in REDMA is $13,500 (for developments of 100 or more development units), on top of the $13,500 fee to file a disclosure statement. Visit BCFSA’s website for a full list of REDMA fees.

To apply for the pilot, ensure that your development project meets the eligibility requirements, and then submit your exemption application by email to realestatedevelopment@bcfsa.ca. The developer is required to include a completed application form and provide proof of payment of the $13,500 exemption application fee.  The application should be submitted prior to, or concurrently with, the filing of the initial disclosure statement.

The pilot will be monitored on an ongoing basis and decisions about appropriate early marketing periods will be made when BCFSA has sufficient information to evaluate the pilot’s impact.

There is no set limit to the number of projects accepted into the pilot. Projects will be approved on a case-by-case basis.

Yes. Approval to participate in the pilot is project-specific and will be granted on a case-by-case basis.

Each quarter, during the 18 months, developers are required to submit data on the development units sold, including details such as the number of bedrooms, square footage of the unit, and the sale date.

In addition to the first quarterly data submission, developers will be asked to submit general information about the project, such as the number of development units, the date marketing commenced for the project, and whether the project contains any rental units.

At the conclusion of the 18 months, developers will be asked to fill out a mandatory survey to gather feedback on their experience with the pilot.

For a full list of data field submissions required to participate in the pilot, see REDMA Early Marketing Period – Pilot Program for Large Developments.

Data can be submitted on BCFSA’s IRIS platform starting July 2025.

BCFSA is implementing this pilot program as a means of determining the impact of the early marketing period on developers. REDMA, via Policy Statements 5 and 6, currently allows developers to market projects for up to 12 months before obtaining necessary local government approvals and a satisfactory financing commitment. By collecting specific data (sales and permitting timelines) from participating developers, BCFSA will be able to determine if the extended early marketing period provides developers with sufficient time to meet the requirements set out in REDMA. Should the data support the need for a longer early marketing period, BCFSA may consider a permanent extension.

If a developer and its directors fail to meet the program’s data reporting requirements in full, the exemption allowing participation in the pilot could be suspended or cancelled. The developer and its directors may also be deemed ineligible to participate in the pilot for future projects, even if they meet the eligibility criteria.

A developer is expected to provide all required data for every development unit, regardless of whether a sale occurred prior to being accepted into the pilot program. This includes data for units sold before the project’s participation in the pilot. If a developer is unable to provide the required data, the project will not be eligible for participation in the pilot program.

Data on individual developments will be kept confidential and only reported in aggregate for the purposes of public reporting on the pilot.

BCFSA is governed by the Freedom of Information and Protection of Privacy Act, which sets limitations and requirements related to BCFSA’s collection, disclosure, and use of personal information. For additional information on how BCFSA complies with these requirements, please visit BCFSA’s Privacy Policy.

Yes, all developers that participate in the pilot will be required to provide data throughout the 18 months, regardless of when they receive permits and secure financing.

No. The pilot program does not alter or invalidate the existing contractual rescission rights between a purchaser and a developer that are described in Policy Statement 5 or Policy Statement 6.

Yes. Purchasers who entered into contracts before a project participates in the pilot program may have a 12-month rescission right, and purchasers who entered into contracts during a project’s participation in the pilot program may have an 18-month rescission right.

Developers must recognize rescission rights and should be aware of the 12-month rescission right for pre-pilot program purchasers and the 18-month rescission right for pilot program purchasers.

Yes. Before marketing under the pilot program, a developer should amend their disclosure statement to disclose the 18-month rescission right for new purchasers and update the form of purchase agreement attached as an exhibit to the disclosure statement. The developer may also wish to explain that participation in the pilot program does not alter existing 12-month rescission rights for purchasers already under contract.

Yes. If you apply for the pilot after June 30, 2025, you will be required to file a new disclosure statement.

Effective April 15, 2025, developers that wish to participate in the pilot must decide whether they are going to do so prior to, or at the time of filing their initial disclosure statement. If a developer decides that they want to participate in the pilot after having commenced marketing under the 12-month early marketing period, they may still do so by applying for the pilot and, if approved, filing a new disclosure statement.