Toronto’s ombudsman found serious gaps in how the TTC decided not to refund discontinued tickets and tokens, including an inability to establish who made the decision, inadequate consideration of affected riders and unclear policies. Kwame Addo’s No refunds for discontinued TTC tickets and tokens: An investigation behind how the decision was made, dated June 17, 2026, makes eight recommendations that the TTC accepted. It does not order refunds or compensation.
The investigation addressed administrative fairness in the decision-making process, not whether the TTC should have stopped accepting the fares or whether refusing refunds was itself the right outcome. Its significance lies in the standards of authority, evidence, documentation and public explanation expected when a transit agency makes a consequential fare decision.
A fare transition without a traceable refund decision
In October 2024, the TTC announced that it would stop accepting tokens and senior and student tickets at the end of that year, without refunds, credits or exchanges. The board subsequently extended acceptance to June 1, 2025, and allowed Wheel-Trans customers to continue using them on the Wheel-Trans system until December 31, 2025. The investigation examined the process from April 2019 through the board’s December 2024 consideration of the issue.
The change followed the transition to PRESTO. The report records that tickets and tokens accounted for approximately 0.1 per cent of fares used in July 2024. The TTC estimated in October 2024 that outstanding tokens and tickets had a face value of approximately $24 million. That was not a finding of financial liability or the amount that would have been refunded: the report notes that some fares could have been lost, damaged or kept as collectibles.
Investigators conducted 37 interviews and reviewed more than 500 documents containing thousands of pages. Among 30 TTC witnesses, 12 believed the board had made the refund decision, seven attributed it to executives or management, and 11 were unsure. No one could direct investigators to a record of the decision.
A missing response to a board request was central to that uncertainty. In April 2019, the board directed staff to report that June on the impact of refunding tokens for as long as customers had them to return. Investigators could not locate the requested report. A May 2019 briefing described historical refund practices, but did not establish that the board had decided the issue. Later briefings contained differing proposals and references to possible exceptions rather than a clear, recorded resolution.
The ombudsman also could not establish a clear delegation of authority for a system-wide refund decision. The governing materials addressed matters such as setting fares and handling individual refund requests, without clearly resolving who could decide the broader question. Addo considered that a decision with this public impact should have been brought openly to the board. That was an administrative-fairness assessment, not a court ruling that the TTC had acted outside its legal powers.
Two different policy problems
The report distinguished an existing refund policy from a broader fare policy that staff repeatedly invoked but could not produce. The refund policy dated from 1994. Two undated versions assigned responsibilities differently, included an obsolete position and did not clearly address discontinuing an entire fare type. Staff were unfamiliar with it or differed over its meaning.
Separately, the TTC referred publicly to a five-year fare policy even though no such policy document had been completed and approved. The board had adopted fare-policy goals, but those goals were not the comprehensive policy that public communications suggested existed. The distinction mattered because riders seeking explanations were being directed to policy language that did not clearly explain the decision or the treatment of their requests.
The ombudsman found broader weaknesses in the handling of fare decisions. Beyond fare increases, there was no sufficiently documented process explaining which changes required board approval, what evidence should be collected or when the public should be consulted. Important information could appear well inside a staff report without being clearly identified up front as a matter requiring a decision. Board directives also lacked an accessible public tracking mechanism.
Equity and notice were not adequately addressed
The TTC had an equity impact analysis tool and consultation resources, but did not use them for this decision. Some staff said equity considerations had been discussed. Investigators nevertheless found insufficient documentation, data or targeted consultation to establish how the impact on riders holding unused fares had been assessed. Low overall use of tickets and tokens did not answer who would be affected or how seriously.
The report also identified inconsistent public notice. A brief 2019 announcement mentioned that refunds would not be available, but investigators found no evidence of further notice of that position until October 2024. A March 2023 announcement about the end of token sales omitted it. Although the later campaign was reasonably comprehensive, some advertisements did not communicate the no-refund position.
Those shortcomings mattered against a history in which fares had been exchanged when earlier fare products were withdrawn and tokens were widely understood not to expire. The ombudsman treated that background as relevant to fair communication and expectations, not as a determination that every unused fare created an enforceable refund entitlement.
Between October 2024 and August 2025, the TTC received 110 refund requests and rejected them all. Standard responses referred to fare policy without adequately explaining the basis for the refusal. Staff described case-by-case consideration, yet investigators could not identify clear criteria for exceptions or a consistent understanding of the discretion available. The report questioned whether discretion was actually being exercised; it did not decide individual riders’ refund claims.
TTC accepts reforms while explaining operational constraints
In its five-page response dated June 3, 2026, the TTC acknowledged shortcomings in governance, documentation and communication and accepted all eight recommendations. It also said equity, accessibility, hardship and changed travel patterns had been discussed, and that extensions and alternative approaches had been considered. The absence of formal analysis, in its account, did not mean those issues had received no attention.
The TTC described practical constraints associated with PRESTO, maintaining parallel fare systems and revenue pressures. Refunds raised questions about authenticating fares without purchase records and determining appropriate values where purchase prices varied. It also referred to leadership transitions and said governance, oversight and documentation practices had since improved. Those statements are the TTC’s response, not independent verification that the recommended reforms have been completed.
Addo acknowledged positive intentions and candid cooperation from TTC personnel. His conclusion remained that those intentions did not cure a deficient institutional process. The investigation’s concern was whether the agency could demonstrate a fair, authorized and adequately explained decision, not simply whether staff could offer operational reasons for preferring the outcome.
Eight recommendations, not a refund order
The first recommendation calls for a board-approved fare-decision process defining the decisions it covers, the boundary between board approval and delegated authority, and requirements for evidence, consultation, records and public reasons. The second would integrate the TTC’s equity tool, or comparable analysis, into that process.
The third seeks a public tracker for board directives and requests to staff. The fourth calls for staff-report guidance that puts key information, requested approvals and recommended actions up front. The fifth requires a review and update of existing fare-related policies, including the fare-policy goals and refund policy.
The sixth calls for a public-facing rider fare policy explaining the refund process, staff discretion and how decisions are communicated. The seventh addresses responsibility for creating, approving and updating policy documents. The eighth requires quarterly progress reports to the ombudsman until he is satisfied that adequate steps have been taken, followed by a final report to the TTC board and City Council once the recommendations are fully addressed.
The TTC’s response sets a fourth-quarter 2026 target for the staff-report guidance and second-quarter 2027 targets for the other six substantive reforms. Quarterly reporting is a continuing commitment. Those are proposed completion targets, not findings that the work has been done. The report leaves the merits of refunds unresolved while setting out how future fare decisions should become more accountable and understandable to riders.
