CWELCC guide · autumn 2026
Your closure calendar is a funding number.
Most operators treat the holiday list as an operations question — when to close, how to tell families, who gets paid. Under cost-based funding it is also an input to the formula. The number of days you charge a base fee for is your service-day count, and every part of the benchmark allocation except the rent is built on it. Decide the 2027 calendar carelessly and you have adjusted next year's allocation without noticing.
The definition that does the work
A service day is a day you charge for, open or not.
The provincial cost-based funding guideline defines a service day as a 24-hour period beginning in the calendar year, starting when the centre normally first begins to accept children, during which the licensee is enrolled in CWELCC and charges a base fee per the parent handbook — even if the centre is not open, for example on a statutory holiday. The number of service days in a year cannot exceed the number of days in the year.
So the test is not whether the doors were open. It is whether your parent handbook says families pay for that day. Peel's 2026 guideline carries the same definition and draws the consequence out: unpaid closure days "are not service days. This means that we will not include unpaid days in your funding calculations."
That matters because service days are the multiplier underneath most of the benchmark allocation. Program staffing and the variable half of operations are counted on operating space-days — the sum of planned service days across each operating space. The fixed half of operations is counted on licensed space-days, the same arithmetic against licensed spaces. The supervisor component is the centre's total service days, adjusted by the eligible child ratio.
One component does not move with service days at all. Accommodation is the accommodation benchmark multiplied by your number of licensed spaces, multiplied by the whole months of the year you participated in CWELCC, divided by twelve. Close for a week without charging and your rent funding is unchanged — as is your rent.
The short version
A paid closure day inside the cap is funded like any other day. An unpaid closure day is invisible to the formula: no funding, no fee revenue, and no reduction in the costs that run whether you are open or not.
Four kinds of day
Paid or unpaid, planned or unplanned — and each combination lands differently.
Peel defines a closure day as any day child care services are not available to children, even if the centre is open for something else — a professional development day, parent-teacher interviews, an open house. Whether families pay decides the funding; whether you could have seen it coming decides the cap.
| Type of day | Counts toward the 20? | A service day? | In Peel |
|---|---|---|---|
| Planned, paid by families | Yes | Yes — funded under the formula | Statutory holidays, Civic Holiday, Easter Monday, Remembrance Day, March break, winter break, religious observances, PD days, parent-teacher days, routine maintenance |
| Unplanned, paid by families | No | Yes — qualifies for CWELCC funding | A closure the event and the response to it are outside your control and that requires immediate closure, such as a major snowstorm on a day the Peel school boards close |
| Planned, unpaid | No | No — excluded from the funding calculations | Any scheduled closure your handbook says families do not pay for |
| Unplanned, unpaid | No | No | Same treatment: if no fee is charged, the day is outside the formula |
The edge case worth reading twice is Peel's treatment of trouble you can schedule around. Unexpected repair work that does not require an immediate closure is a planned closure, because you can move it to a long weekend or your next scheduled closure without compromising children's safety. Landlord-mandated closures you know about in advance are planned for the same reason, and Peel's instruction there is to either align your closure calendar with the landlord's dates or not charge families for the day. "Out of my control" is not the test; "could not be planned for" is.
New for 2026 in Peel: where an unplanned paid closure runs more than five business days, Peel says it will work with the operator to limit the number of days fees are charged, so that families are not negatively affected. A fortnight of boiler failure is therefore not simply fourteen funded days.
The cap
Twenty paid closure days a year, ten in a row.
The number comes from the province, in the Ministry's CWELCC Participation Guideline, though as guidance addressed to service managers rather than a rule aimed at licensees: service managers “should follow this guidance as part of their funding framework”. The binding version is your own service manager's guideline, and in Peel and Halton it reads the same. Where a licensee charges fees during a closure period, the programme may not exceed two consecutive weeks — 10 business days — of closure, and not more than four weeks, 20 business days in total, within a calendar year. Statutory holidays are expressly included: charge for a statutory holiday closure and it counts toward the limits. Closures due to events outside the licensee's control, such as a natural disaster, a major weather event, a pandemic or a school board strike, are not counted. Nor are days you do not charge for.
The guideline then hands service managers two levers: they may restrict the period further — down to 10 consecutive days — or allow the count to run on the school year rather than the calendar year, provided the total stays within what the Ministry and the service manager have agreed. So Peel and Halton both adopt the provincial numbers and build different machinery around them, while Toronto's funding guidelines do not address closure limits at all, which leaves the provincial guidance to apply by default.
| Question | In Peel | In Halton | In Toronto |
|---|---|---|---|
| Counting period | January 1 to December 31, or September 1 to August 31 if your programme runs on an academic year — including a 10-month programme | Calendar year. Programmes running a September–June academic calendar must still count on the calendar year | Not addressed in the 2026 funding requirements guideline; the provincial limits apply |
| Going over the limit | Changes cannot result in more than 20 planned paid closure days a year | You may close for more days, but cannot charge families for them and are not eligible for cost-based funding for them | Not addressed; the forms simply collect the days a base fee is charged |
| Telling the service manager | In writing before increasing your number of closure days — email the Early Years System Division and your Early Years Specialist, subject line "change to closure days" | Where you want to close beyond the allowable period: in writing to your Quality and Accountability Specialist, at least eight weeks ahead for a planned closure and 24 hours for an unplanned one | Through the annual Operating Information Online Form; in-year changes go through the OIOF Update Form, online from January 2027, and are applied on a go-forward basis only |
| Telling families | At least 60 days' notice, and an updated parent handbook shared with families and with the Region | Strongly encouraged to give a reasonable period, for example 60 days | Via the parent/family handbook that the service-day count is drawn from |
| Reporting closures | Through the parent handbook's list of planned closure days, paid and unpaid shown separately | Monthly closure days on the Web Record of Attendance in OCCMS | Service Days on the Operating Information Online Form — renamed Annualized Service Days for 2027 |
Two more Peel points. The transition that let legacy centres carry more than 20 planned paid closure days ended on December 31, 2025: since January 1, 2026 every centre must comply. And if you do have to add a closure day, Peel's advice is to pick one where attendance has historically been low.
In Halton there is a subsidy consequence as well: an operator may claim fee subsidy for an approved child for up to 20 closure days a calendar year, and parental contributions may continue to be collected for up to 20 closure days. Charge for a statutory holiday closure and it counts toward that limit too.
The arithmetic
What one unpaid week actually costs.
Take a centre open Monday to Friday. There are 261 weekdays in 2027. Suppose the handbook charges for every weekday, including nine statutory holidays and a five-day winter closure: 261 service days, 14 of them planned paid closure days, comfortably inside the cap.
Now make the winter week unpaid. Service days fall to 256.
- Program staffing, supervisor and both halves of operations fall by five days out of 261 — roughly 1.9% of each of those components for the year.
- Accommodation does not move. It is counted on licensed spaces and months of participation, not service days.
- The expected base fee revenue offset falls by five days of estimated fees multiplied by the 0.95 vacancy factor that applies for 2026 and later calendar years — so the allocation is reduced by less than the full five days of benchmark.
- Your fee revenue falls by whatever you would actually have collected. At the 5% vacancy the formula assumes, that is the same amount the offset gave back. Run at better than 95% occupancy and you give up slightly more than you recover.
- Your costs mostly do not fall. Rent, insurance, utilities and loan payments run through the week, and if you pay staff — see below — payroll runs too.
None of which is an argument for charging families for every closure. It is an argument for making the choice deliberately, and for knowing that a handbook change in November moves a funding number in the following calendar year rather than this one.
Where the allocation actually comes from
In Peel, the January allocation is a rollover: the 2026 January figure was built on the licensed and operating capacity reported in June 2025 and the 2025 benchmarks, with the fee revenue offset still at a 10% vacancy rate. The real number arrives with the April revision, which rebuilt the benchmark allocation from the data reported for October 2025 and the 2026 benchmarks, and moved the offset to 5%. Peel has not yet published its 2027 guideline, so treat this autumn's reporting as the data that matters and check the new guideline when it lands.
If the allocation looks wrong
Where a funding shortfall arises because operating or licensed capacity increased, Peel asks for an email headed "CWELCC Funding Request" to the Early Years System Division, copying your Early Years Specialist, and will review the data behind the allocation. If actual program costs exceed the program cost allocation after all in-year adjustments, the operator covers the difference.
Payroll
Who has to be paid when the centre is shut.
Peel sets minimum staff payment requirements for closure days, framed as a floor rather than a ceiling — the guideline says it is not intended to reduce or limit an organisation's compensation package, and advises providers to take independent legal advice on implementing them. The requirements run as follows.
- Public holidays. At least the public holiday pay requirements of the Employment Standards Act. Staff who qualify for public holiday pay cannot be asked to take vacation or unpaid time instead. Where a contract or HR policy promises more, the higher amount applies.
- Professional activity and development days. Training required by the employer or by law is work time and must be paid. If you close for professional activities, staff who take part are paid.
- Unplanned closures — inclement weather when the school boards close, for instance. Staff scheduled to work are paid the wages they were expecting. Peel's wording is "There are no exceptions," on the reasoning that the day is already funded by the Region and by families.
- Everything else is anchored to history. If you paid staff for other closure days in 2023, you must continue to, because the allocation was built on your 2023 cost structure. If you did not, Peel encourages you to pay staff for planned paid closure days, within the CWELCC allocation. Where 2023 was not representative and funding was based on 2024, 2024 practice is the minimum.
The wage enhancements follow the same logic, and this is the part that most often goes wrong in a payroll file. In Peel, hourly enhancements apply to all hours worked, including paid closure days that are not statutory holidays, vacation or sick days. Separately, enhancements must be paid for statutory holidays, vacation time, paid sick days and centre closures where staff are paid for those days — and for those hours the enhancement is treated as a benefit rather than as wages, which is where it belongs in the claim.
In Halton, operators are expected to pay staff for all closure days where families pay fees, within the allowable allocation, and to pay for professional learning days and unexpected closures. Halton's hours-worked table draws the same line as Peel's: closure days where families pay fees, planned or unplanned, qualify for WEG and workforce compensation funding provided they are not statutory holidays, vacation or sick days — and statutory holidays and vacation up to two weeks are supported through the 17.5% benefits funding instead.
Service levels
Closures are one of four things you promised to maintain.
Peel's requirement is to maintain all programmes and services — programme quality, hours of service, availability — offered as of March 27, 2022, or as approved by the Region when you enrolled in CWELCC, under your base fee. Families should not see reductions in service offerings, or surcharges for things that were inside the base fee before CWELCC. Four specifics sit under that heading:
- The number of days you provide services — the closure rules above.
- Spaces for eligible children. A licensed infant space stays an infant space. Licence revisions and use of alternate capacity are reported in the comments field of your OCCMS attendance reporting.
- Hours of operation. In Peel you must tell the Region at least one month before a change takes effect.
- What the base fee includes. Anything inside the base fee at March 27, 2022, or at enrolment, stays inside it.
Peel's one-line warning on the section is the operative part: changes to service levels may result in funding adjustments and recoveries. Halton puts it a different way — any requested reduction in programmes, services or offerings must be reflected by a proportionate reduction in fees for families.
Shortening the day is not a quiet change
Moving from a 10-hour day to a 9.5-hour day reduces hours of service, which is a service-level change in its own right — and hours of service is its own reported field on Toronto's operating information form, separate from the service-day count. It is not a closure-day question, and it is not something you can simply start doing.
What we do with this
For the centres we keep books for, the closure calendar, the handbook and the service-day count used in the funding forms are reconciled to each other once a year, before the forms go in — because that is the cheapest moment to find a disagreement between them.
The parent handbook
If the handbook is unclear, the Region assumes the worst for you.
O. Reg. 137/15, s. 45 and the centre-based licensing manual already require a parent handbook to set out whether the centre is enrolled in CWELCC, the times services are offered, and the holidays observed and all planned closures. In Peel, three further things must be in it, and they exist because the funding calculation reads them:
- Whether your programme runs on a calendar year (January 1 to December 31) or an academic year (September 1 to August 31).
- A list of all planned closure days for the year, listing paid and unpaid closure days separately.
- Every fee you charge, its frequency, what each fee includes, which fees are base fees and which are not, your payment method and schedule, and whether refunds or credits are given and when.
Then the sentence that should be pinned above the desk of whoever maintains the handbook: if this information is not findable or clear, Peel will assume that you operate on a calendar year and that families pay for all closure days. That assumption feeds the estimated base fee revenue that is deducted from your allocation, which is to say the Region may net off fee revenue you are not collecting. Peel shared a closure template on October 29, 2025 and an optional parent handbook checklist on November 5, 2025 to make this easier; a handbook that predates them is worth a read against both.
In Halton the handbook is not an internal document at all: operators must submit a copy to the Region by October 30, 2026, and again on request through the year, so the Region can verify compliance with Ministry requirements — including that fee reductions have been implemented correctly.
Between now and January
The dates that close the 2027 calendar.
| When | What | Where |
|---|---|---|
| October 13 to November 2, 2026 | 2027 Operating Information Online Form for child care centres opens and closes. Annualized Service Days is the field this guide is about: days the centre is open plus closed days where a parent fee is charged, including statutory holidays; closed days with no fee are excluded. Maximum 261 for a Monday-to-Friday operation in 2027 | In Toronto |
| November 15 to November 30, 2026 | 2027 Operating Information Online Form for home child care agencies, plus the Annual Provider Information Form | In Toronto |
| October 30, 2026 | A copy of the parent handbook to the Region, with the closure and fee information it must contain | In Halton |
| At least 60 days before the change | Notice to families of a change to your number of planned closure days, with the updated handbook shared with families and the Region. Written notice to the Region is required before increasing the number | In Peel |
| At least 8 weeks before the closure | Written notice to your Quality and Accountability Specialist where you want to close beyond the allowable period | In Halton |
| December 31, 2026 | Last day eligible costs count toward the year; an unspent allocation may be recovered | All |
Toronto's 2027 guideline carries a disclaimer on its first page: it is a draft and remains subject to change based on updates to the Ministry's funding guidelines. The submission dates are the operative part, and Toronto's own warning is blunt — licensees who submit after the deadline may not receive their January cost-based funding payment on time.
Peel published its 2026 guideline in January and Halton revised its in April, so a Peel or Halton centre setting a 2027 calendar this autumn is working from the 2026 rules. That is the right base to work from, and it is worth re-reading the closure section of the new guideline when it appears, because the closure rules changed in Peel in each of the last two years.
Quick answers
What operators ask us.
Do statutory holidays count toward the 20 closure days?
Yes, if you charge families for them. The Ministry's guidance is explicit that where a licensee charges fees for a statutory holiday closure, the statutory holiday counts toward the two-consecutive-week and four-week limits. If your handbook says families do not pay for that day, it does not count — but then it is not a service day either, and it drops out of the funding calculation.
We closed for a week in January because the furnace failed. Does that use up our 20 days?
No, provided the closure genuinely could not be planned for. Closures due to events outside your control are not counted toward the limits, and in Peel an unplanned paid closure is a service day that qualifies for funding. The qualification is that both the event and the response must be out of your control and require an immediate closure. Repair work you could have scheduled for a long weekend is a planned closure in Peel's framework, however unexpected the breakdown was.
Is a PD day a closure day if staff are in the building?
Yes. Peel defines a closure day as any day child care services are not available to children, even if the centre is open for other activities such as professional development days, parent-teacher interviews or open houses. If you charge for it, it is a planned paid closure day and counts toward the 20.
Can we stop charging for our winter closure to free up days under the cap?
You can, and sometimes it is the only route once you are at 20. Understand the trade: an unpaid day is not a service day, so it comes out of the operating space-days and service days that drive program staffing, the supervisor component and both halves of operations. Accommodation funding is unaffected because it is counted on licensed spaces and months of participation. Your expected base fee revenue offset also falls, which cushions part of it. In Peel, any change to your number of closure days needs 60 days' notice to families and an updated parent handbook shared with families and the Region; written notice to the Region beforehand is required where you are increasing closure days, and is worth sending either way, because the change moves a funding input.
Do we have to pay staff for a snow day?
In Peel, yes. The guideline requires that staff scheduled to work on an unplanned closure day be paid the wages they were expecting, with no exceptions, on the basis that the day is funded by the Region and by families. Public holidays carry at least Employment Standards Act public holiday pay, and staff who qualify cannot be asked to take vacation or unpaid time instead. Peel advises providers to take independent legal advice on implementing these requirements.
Do the wage enhancements apply to paid closure days?
In Peel, hourly enhancements apply to all hours worked, which expressly includes paid closure days that are not statutory holidays, vacation or sick days. They must also be paid for statutory holidays, vacation, paid sick days and centre closures where staff are paid for those days — and for those hours the enhancement is treated as a benefit rather than as wages.
Our programme runs September to June. Which year do we count closures in?
It depends on the service manager. In Peel, a programme operating on an academic year counts from September 1 to August 31 of the following year, and the guideline says this applies even to a 10-month programme. In Halton, operators running a September-to-June academic calendar must adhere to the closure requirements based on the calendar year. The underlying provincial guidance lets service managers allow school-year counting; it does not require them to.
What happens if our handbook does not list the closure days clearly?
In Peel, the Region will assume you operate on a calendar year and that families pay for all closure days. That assumption feeds the expected base fee revenue offset, which is deducted from your allocation — so an unclear handbook can have the Region netting off fee revenue you are not collecting. The handbook must list planned closure days for the year with paid and unpaid days shown separately.
Sources: Ontario Ministry of Education, Chapter 2 Division 1: CWELCC Participation Guideline (November 2025) — s. 1.C (7), fees during a closure period, and the requirement to maintain pre-CWELCC licensed spaces for children aged 0 to 5; Ontario Ministry of Education, Chapter 2 Division 2: CWELCC Cost-Based Funding Guideline (July 2026) — the definitions of service day and operating space, the benchmark components, and the expected base fee revenue offset; Region of Peel, 2026 CWELCC funding guideline, centre-based — sections 3.4, 5.9, 7, 8 and Appendix 2; Halton Region, CWELCC guidelines for child care operators (April 2026) — service levels, closure periods and unexpected closures, closure periods and fee subsidy, the hours-worked eligibility table, and the October 30, 2026 parent handbook submission; Toronto Children's Services, 2027 Funding Requirements Guideline (draft, September 2026) — submission timeline and Annualized Service Days; Toronto Children's Services, 2026 Funding Requirement Guideline; O. Reg. 137/15 under the Child Care and Early Years Act, 2014 — s. 45, parent handbook. Closure rules, notice periods and reporting differ by service manager, and Toronto's 2027 guideline is a draft subject to change. General information, not advice for your situation.
Setting the 2027 calendar?
Call 647-870-8498 or email info@ghayurtax.com. We keep the books for licensed centres and home child care agencies in Peel, Halton and Toronto, and we check the closure calendar, the handbook and the service-day count against each other before the forms go in.