The GTA's $3 million market and the quiet rise of private sales

The market for homes above $3 million in the Greater Toronto Area has thinned in 2026 without collapsing, and more high-end vendors are testing demand privately before any public listing appears. This note sets out what the published data shows, what the rules say about off-market sales, and what we see on our own files.

RE/MAX Canada's 2026 Spotlight on Luxury report, published 17 June 2026, counted 300 freehold and condominium sales above $3 million across the GTA between January and April 2026, down almost 17 percent from 361 in the same months of 2025. Sales above $5 million were almost unchanged at 62 against 63. Within Toronto, Rosedale and Lawrence Park led with 20 sales above $3 million each. Don Kottick, President of RE/MAX Canada, said in the accompanying release that "Canada's luxury market is becoming more dynamic and more regional."

TRREB's Market Watch for September 2026, released in October 2026, does not break out a $3 million band, but it recorded 275 GTA sales above $2 million in the month, 238 of them detached, and 2,707 sales above $2 million year to date. Detached averages were $1,740,421 in Oakville on 85 sales, $2,131,250 in King on 16, $3,835,800 in Toronto C12 on 10 and $7,185,000 in Toronto C09 on six. Samples that small move the averages sharply; they show where the top tier trades, not a trend.

Sotheby's International Realty Canada's Top-Tier Real Estate series is the usual reference for $4 million and $10 million sales counts, but we could not locate a 2026 GTA edition. Its most recent GTA report, dated 7 May 2025, recorded a 15 percent year-over-year decline in GTA sales above $4 million for the first quarter of 2025, five MLS sales above $10 million against none a year earlier, and noted that "private and off-market sales over $10 million also strengthened."

Two policy settings shape the buyer pool. Ontario's Non-Resident Speculation Tax has been 25 percent provincewide since 25 October 2022, and the federal Prohibition on the Purchase of Residential Property by Non-Canadians Act was extended on 4 February 2024 to 1 January 2027. The $3 million buyer in 2026 is therefore, with narrow exceptions, a Canadian citizen or permanent resident, and most often an existing owner moving equity from one property to another.

Royal LePage's second-quarter 2026 House Price Survey, released in July 2026, put the Oakville detached median at $1,951,700, up 3.1 percent year over year, while the GTA detached median fell 3.6 percent to $1,396,500. No Canadian institution we could find publishes the share of top-tier purchases made without a mortgage.

An "exclusive" or off-MLS sale is lawful in Ontario, but it is regulated more closely than it was. CREA's REALTOR Cooperation Policy, in force since 3 January 2024, requires a listing to be placed on an MLS system within three days of any public marketing, such as signs, flyers or digital campaigns. One-to-one communication with a buyer or another registrant does not trigger the requirement. A seller who wants to stay off MLS must give the brokerage a written instruction not to engage in public marketing, with an acknowledgement that doing so may reduce exposure and the number of offers. CREA confirmed on 9 January 2024 that exclusives "remain as an option for sellers who do not want broad exposure of their property to the public."

Ontario's Trust in Real Estate Services Act, 2002 reached its second phase on 1 December 2023, introducing designated representation, under which one registrant at a brokerage acts for the seller and another for the buyer, a new Code of Ethics, a mandatory RECO information guide, and an open offer process in which a seller may direct that the terms of competing offers be shared, with identities withheld. On a private file, the vendor's choices about exposure and offer disclosure must be documented.

The reasons vendors give for starting privately are consistent: privacy for a family or public figure, discretion with tenants or staff, and the wish to test a price with a few qualified buyers before a public number is fixed to the address.