For most of Canadian construction history, payment down the contracting pyramid was governed by contract, leverage and patience. A subcontractor waited because the general contractor was waiting, and the general contractor waited because the owner had not paid. The reforms of the last seven years replaced that with a clock, and the most important thing to understand about the clock is what starts it.

Key Takeaway

Under Ontario's Construction Act, an owner must pay a contractor within 28 days of receiving a proper invoice unless a notice of non-payment is validly served within 14 days, and payments cascade downstream within 7 days of each party receiving funds. Proper invoices must be given monthly unless the contract provides otherwise. Ontario's regime came into force October 1, 2019, and major amendments under Bill 216 and Bill 60, supported by O. Reg. 264/25, took effect January 1, 2026, making Ontario the first province to require the 10% accrued statutory holdback be released annually on all construction contracts regardless of duration, price, or what the contract says. Parties may now choose a private adjudicator. The national map is uneven: Ontario, Saskatchewan and Alberta were designated exempt from the federal regime on December 8, 2023, British Columbia's legislation is upcoming, Manitoba's and New Brunswick's received Royal Assent in 2023 but are not yet in force, and no exemption is contemplated for Quebec.

What Actually Changed

The reforms are usually described as accelerating payment. That understates them. What changed is where the default sits when nobody does anything.

Commentary describes the policy objective: prompt payment and adjudication legislation has been enacted across Canada in an effort to alleviate perceived payment delays down the construction pyramid[1]. Another notes that prompt payment and dispute resolution reforms are changing how construction project participants are to be paid, their disputes determined, and when liens are to be filed and holdbacks released[2].

Under the old arrangement, silence favoured the payer. A disputed or simply inconvenient invoice could sit, and the party owed money had to initiate something, usually a lien or a claim, to force movement. Delay was free to the party holding the cash.

Under the statutory regime, silence favours the payee. If an owner receives a proper invoice and does nothing for 28 days, payment is due; the owner had to act, within 14 days, to preserve any objection. The cost of inaction moved from the party owed to the party owing.

That inversion is the substance of the reform, and it explains why the technical requirements discussed below matter so much. The whole mechanism turns on documents and deadlines rather than on the merits of the underlying work, which advantages whichever party administers its paperwork properly.

Twenty-Eight, Fourteen, Seven

The core timetable, which is broadly consistent across the enacted regimes.

Under Ontario's Construction Act, payment is due from owner to contractor within 28 days after receipt of a proper invoice, unless a notice of non-payment is validly served within 14 days[2]. Commentary describes the regime as comprising swift payment deadlines requiring the owner either to pay within 28 calendar days or to dispute within 14 calendar days, describing the reasons for non-payment[1]. Downstream payments must cascade within 7 days of each party receiving funds[3].

The pattern repeats in other jurisdictions. New Brunswick's not-yet-in-force Act provides that payment is to be issued by the owner to the contractor within 28 days of receipt of a proper invoice, subject to notice of non-payment within 14 days, and that upon receipt of payment from the owner the contractor is to pay subcontractors within 7 days, with the subcontractor in turn paying its own subcontractors within 7 days after receipt[4]. Manitoba's not-yet-in-force amendments contain the same 28, 14 and 7 day structure[4].

Two observations about the cascade. The 7-day downstream obligation is triggered by receipt of funds, not by the passage of time, which means a general contractor who has not been paid is generally not obliged to pay down the chain, subject to the dispute and non-payment provisions. The regime accelerates money that moves; it does not manufacture money that does not.

And the calendar-day basis matters operationally. These are not business days. A 14-day notice window spanning a holiday period is still 14 days, which is a real administrative risk for owners with thin accounts payable functions over the December period.

The Proper Invoice Is The Trigger

The most consequential technical concept in the entire regime, and the one contractors most often get wrong.

Commentary on the Ontario amendments describes the reforms as including a redefined proper invoice that triggers the payment clocks, and states that once a proper invoice containing all prescribed fields is received, the owner must pay within 28 days or issue a notice of non-payment within 14 days[3]. The recommendation follows that payment clauses should reference the 28-day payment deadline and incorporate the statutory definition of proper invoice[3].

Follow the logic to its conclusion, which we set out as our own analysis. If the clock starts on receipt of a proper invoice, and a proper invoice is one containing all prescribed fields, then a document missing a prescribed field is not a proper invoice and does not start the clock.

A contractor issuing invoices on a template that predates the legislation, or one adapted from another jurisdiction, may be issuing documents that never engage the statutory timetable at all. It will believe it is owed money in 28 days. It has no statutory entitlement, because the precondition was never met.

The corollary for owners is the reverse and equally important: an owner receiving a defective invoice is not on a 28-day clock, but an owner who pays it anyway, or who fails to identify the defect and then misses the 14-day notice window on the assumption that the clock had not started, has taken a risk that turns on the same technical question.

The practical instruction is that the invoice template is now a cash flow instrument rather than an accounting document. It should be built against the prescribed fields in the applicable jurisdiction, reviewed by counsel once, and then used without variation.

The Monthly Rule

A default that quietly governs billing cadence across an entire industry.

Under the Construction Act in Ontario, proper invoices have to be given to an owner on a monthly basis unless the contract provides otherwise[2]. New Brunswick's provisions require proper invoices to be submitted by a contractor to an owner on a monthly basis unless otherwise provided in the contract[4], and Manitoba's contain the same monthly default[4].

Two consequences follow that are worth stating.

Milestone billing does not disappear, but it becomes a contractual departure from a statutory default rather than the ordinary course. Parties wanting milestone or completion-based billing must provide for it in the contract, and a contract silent on the point produces a monthly obligation.

And for a contractor, monthly invoicing is a working capital benefit conferred by statute. Under the previous arrangement a subcontractor might invoice at completion of its scope and wait. Monthly proper invoices, each starting its own 28-day clock, convert an irregular receipt pattern into something forecastable, which is the point at which this becomes a finance topic rather than a legal one.

The Notice Of Non-Payment

The owner's only escape from the clock, and its exacting character.

The obligation is to pay within 28 days unless a notice of non-payment is validly served within 14 days[2], describing the reasons for non-payment[1].

Three features deserve emphasis. The notice must be valid, meaning it must comply with the prescribed form and content requirements, so a general expression of dissatisfaction communicated by email is unlikely to qualify. It must state reasons, which means the owner has to articulate its objection at a point when it may not have completed its own review. And it must be served within 14 days, which is half the payment period.

The consequence of missing the window is that the payment obligation stands. An owner with a genuine and substantial complaint about the work, which fails to serve a compliant notice in time, is obliged to pay and must pursue its complaint separately.

This is the sharpest practical reversal in the regime, and it has an operational implication for owners that is easy to underestimate. The 14-day review is not a finance function task. It requires site knowledge, contract administration and a decision, compressed into two weeks from receipt, on every invoice received. An owner without a defined internal process for that review will miss windows, and missing them is expensive.

Interim Adjudication

The enforcement mechanism that makes the payment timetable meaningful.

Prompt payment deadlines without a fast dispute mechanism would achieve little, because a payer could simply dispute and force the payee into ordinary litigation, where delay again favours the party holding the money. Adjudication addresses that. Commentary describes prompt payment and interim adjudication regimes as already in force in Ontario and Alberta[2], and notes that Saskatchewan and Alberta have implemented similar reforms with nuanced provisions on invoice submissions and adjudication procedures[1].

The defining characteristic, as the word interim signals, is that an adjudicator's determination binds the parties on an interim basis, pending final determination by a court or arbitration. Money moves on the adjudicator's decision, and the losing party may pursue the merits afterwards.

The economic effect, which we state as our own analysis, is to reallocate the burden of delay. Under litigation, a subcontractor owed money must fund a dispute for years while the payer retains the cash, which is a structural advantage to whichever party has the deeper balance sheet regardless of merits. Under interim adjudication, the money moves quickly and the party wishing to overturn the outcome must fund the long proceeding.

For a small trade contractor, that is the difference between a claim worth pursuing and one worth abandoning, and it is the reason these regimes matter more to the bottom of the pyramid than to the top.

Private Adjudicators And Expanded Scope

The January 2026 Ontario changes to the adjudication regime.

Parties to an adjudication are now permitted to choose a private adjudicator, and the availability of adjudication has been expanded in both time and scope, following what commentary describes as a global trend of expanding access to statutory adjudication[1]. The reforms are described as broadening access to interim adjudication under expanded regulations including O. Reg. 264/25[3].

The private adjudicator change addresses a practical constraint. A regime dependent on a roster of authorised adjudicators is limited by the size and availability of that roster, and by whether its members have expertise in the technical subject matter of a given dispute. Permitting private appointment lets parties select for expertise and availability.

The expansion in time is the more significant change for a contractor's rights. Under the original Ontario regime, adjudication was generally available while the contract or subcontract remained ongoing, which meant a party that waited until completion could lose access to the mechanism entirely. Expanding availability in time addresses that, though the precise parameters are set by the amended Act and regulations and should be confirmed against them rather than assumed.

Our observation is that the direction of travel across these reforms is consistently toward making adjudication easier to reach. A contractor treating adjudication as a last resort after other avenues are exhausted is using the mechanism in the way the reforms were designed to make unnecessary.

Ontario's Annual Holdback Release

The single largest cash flow change in Canadian construction in years, effective January 1, 2026.

Additional major amendments came into force as of January 1, 2026 relating to the statutory framework for release of accrued holdbacks, private adjudication, and proper invoices. Due to the amendments, Ontario is now the first province in Canada to require that the 10% accrued statutory holdback be released annually on all construction contracts, irrespective of the duration of the completion schedule or the contract price, and regardless of whether the contract states that the accrued holdback is to be paid on an annual basis on the anniversary date of the contract[2].

Commentary describes the reforms as mandating an annual release of holdback that fundamentally alters cash-flow dynamics on every Ontario construction project[3], and as requiring a mandatory annual release of accrued holdback regardless of contract price or length of contract[5].

Three features make this substantial. It is mandatory rather than permissive, so it operates regardless of what the contract provides, which is a rare instance of statute overriding freely negotiated commercial terms in this area. It applies to all contracts irrespective of price or duration, so there is no small-project carve-out. And it converts holdback from a sum retained until substantial performance into a recurring annual release.

The working capital consequence runs in both directions and both parties should model it. For a contractor on a multi-year project, 10% of certified value that would previously have been locked up until the end now returns annually, which is a material improvement in cash conversion. For an owner, the same amount leaves the project account annually rather than remaining available as security against defective work, which changes the risk position and may affect financing arrangements and bonding requirements.

The Transitional Trap

A timing rule that produces a counterintuitive result and that we would expect many parties to miscalculate.

For contracts entered into prior to January 1, 2026, the relevant anniversary day for purposes of the annual holdback release regime will be the second anniversary date of the contract that falls after January 1, 2026. The example given is a contract dated December 15, 2025, for which the relevant anniversary date in respect of which the first annual release of holdback is to be calculated and paid will be December 15, 2027, being the second anniversary date[2]. Transitional measures are built into section 87.4 of the Act[1].

Work through that example, because the result is not what an ordinary reading of "annual release from January 2026" would suggest. A contract signed just seventeen days before the amendments took effect does not see its first mandatory holdback release until nearly two years after they did.

The implication for a contractor is that a cash flow forecast assuming holdback release begins in 2026 on an existing contract may be wrong by a full year, and the error is on the optimistic side. The implication for an owner is the reverse and is favourable, but it should be confirmed rather than assumed.

The general instruction is that the contract date determines the release schedule under the transitional rule, and that determination should be made contract by contract rather than by policy. Section 87.4 governs and should be read directly.

The Map Is Fragmented

The national picture, which matters for any contractor operating across provincial lines.

Ontario's regime came into force October 1, 2019[2], and Alberta has implemented prompt payment and adjudication regimes[5] under its Prompt Payment and Construction Lien Act[2]. Saskatchewan has implemented similar reforms[1]. British Columbia's upcoming regime followed the introduction of prompt payment legislation reported in October 2025[2].

Manitoba's Builders' Lien Amendment Act (Prompt Payment) received Royal Assent in 2023 but is not yet in force[4], as did New Brunswick's Construction Prompt Payment and Adjudication Act[4], which commentary elsewhere describes as awaiting proclamation of force[1].

So a contractor working nationally faces jurisdictions where the regime is in force and recently amended, in force in original form, enacted but dormant, imminent, and absent. The core 28, 14 and 7 day structure is broadly consistent where enacted, but the surrounding detail is not, and one commentary notes nuanced provisions on invoice submissions and adjudication procedures between provinces[1].

The practical consequence is that a single national invoicing and contract administration template is unsafe. The prescribed content of a proper invoice, the notice requirements, the holdback rules and the adjudication procedure are jurisdiction-specific, and a business that standardises on the rules of its home province will be non-compliant elsewhere.

The Federal Layer And Exempt Provinces

An additional regime governing federal construction work, with an unusual interaction mechanism.

Canada's federal prompt payment legislation, supported by the Federal Prompt Payment for Construction Work Regulations[1], permits Canada, by order of the Governor in Council, to exempt provinces from the application of the Act's prompt payment regime, and Canada may grant such an exemption if a province has already implemented a reasonably similar prompt payment and adjudication regime. On December 8, 2023, the Governor in Council designated Ontario, Saskatchewan and Alberta as exempt provinces. The Regulatory Impact Analysis Statement issued following the Order also notes that Nova Scotia and Manitoba have taken steps to enact similar legislation in order to be exempt. No exemption is contemplated for Quebec[6].

The exemption mechanism is a sensible piece of federalism: rather than layering a federal regime on top of functioning provincial ones, Ottawa steps back where a province has done the work. But it produces a consequence worth flagging.

A contractor performing federal construction work must determine which regime applies by reference to the province in which the work occurs and that province's exemption status. Work in an exempt province is governed by the provincial regime; work in a non-exempt province falls under the federal one. That is a determination made per project rather than per company.

The note that no exemption is contemplated for Quebec[6] is significant given the volume of federal construction activity there, and Quebec's civil law framework differs from the common law provinces in ways this article does not address.

Manitoba, New Brunswick, And Royal Assent Without Force

A status distinction that businesses regularly misread.

Both Manitoba's and New Brunswick's statutes received Royal Assent in 2023 and are not yet in force[4]. Royal Assent means the legislation has passed; coming into force means it operates. Statutes commonly provide that they come into force on proclamation, and the interval can run to years.

The practical position is that in those provinces the old law governs today. A contractor cannot rely on prompt payment timelines, cannot invoke adjudication, and remains subject to the prior lien and holdback framework, notwithstanding that the replacement is on the statute book.

Manitoba's package also contains changes worth noting for when it does operate. The Builders' Lien Act extends the general deadline for registering a lien to 60 days, and correspondingly the holdback period is extended to 60 days, which applies to all contracts regardless of when they were entered into[7]. Dispute resolution provisions for adjudication appear at section 21 of the Act[4].

The instruction for anyone operating in a pre-proclamation jurisdiction is to monitor the coming-into-force date actively rather than assume notice will reach them, because the day the regime operates is the day invoice templates, notice procedures and contract terms need to already be compliant.

The Professional Carve-Outs

A category of participant treated differently, which matters for consultants and for owners engaging them.

Manitoba's Act exempts architects and engineers from the application of the prompt payment and adjudication provisions, along with continuing prior exemptions including pre-existing exceptions for certain provincial highways and Manitoba Hydro contracts[7]. In Alberta, recent changes clarify that when a regulated professional engineer or regulated professional architect waives their lien rights, they are now also waiving any requirement for the owner to maintain a statutory holdback for their services[5].

Two distinct points sit here. Manitoba's carve-out removes design professionals from the prompt payment and adjudication regime entirely, so a project can have its trades inside the statutory timetable and its consultants outside it, governed by their contracts alone.

Alberta's change is narrower and concerns the linkage between lien rights and holdback. A professional who waives lien rights, which owners and lenders frequently request, now also releases the owner from maintaining holdback for those services, which is a cash flow benefit to the owner and a reduction in security for the professional.

For a design consultant the transferable point is that a request to waive lien rights is not a formality, and its consequences now extend beyond the lien itself, at least in Alberta. For an owner, the point is that the payment regime applying to consultants may differ from the one applying to trades on the same project.

What This Does To A Cash Flow Model

Translating the legal regime into forecasting practice, which is our own analysis.

A construction cash flow model built before these reforms typically forecast receipts by applying an assumed collection lag to certified progress, and treated holdback as a lump recovery at substantial performance. Both assumptions now need replacing in jurisdictions where the regime operates.

Receipts should be modelled from proper invoice date plus 28 days, not from an empirical average collection period. Where the historical average exceeded 28 days, the model should not carry that history forward without asking whether the invoices were proper.

Holdback should be modelled as an annual release in Ontario, on the anniversary determined under the transitional rule for pre-2026 contracts, rather than as a single recovery at the end.

Downstream payments should be modelled from receipt plus 7 days, which for a general contractor means the payable side accelerates in step with the receivable side rather than being managed at discretion.

That last point deserves emphasis for general contractors specifically. The regime accelerates money in and money out. A contractor whose working capital depended on holding subcontractor payments longer than its own collection cycle has lost that source of float, and the loss is legislated rather than negotiable.

A Worked Case: The Invoice That Never Started A Clock

An Ontario subcontractor on a commercial project. The reconstruction illustrates the mechanism rather than reporting a specific engagement.

The subcontractor issues monthly invoices on a template its bookkeeper built years ago. The template omits one or more of the prescribed fields required for a proper invoice. Payments run at roughly 60 days, and the subcontractor's finance function has come to treat that as normal.

The subcontractor believes it has a statutory entitlement to payment in 28 days and that the general contractor is chronically late. On the analysis above, the position may be that no statutory clock ever started, because the clock runs from receipt of a proper invoice containing all prescribed fields[3]. There is no breach of a deadline that never began.

The remedy costs almost nothing. A single review of the invoice template against the prescribed requirements in Ontario, and thereafter every invoice engages the 28-day obligation and every failure to serve a compliant 14-day notice of non-payment leaves the payment due.

Separately, on any multi-year contract, the 10% accrued holdback now falls to be released annually regardless of contract terms[2], subject to the transitional rule for contracts entered before January 1, 2026[2]. A subcontractor that has not asked when its first release date falls is leaving a scheduled receipt out of its forecast.

The transferable observation is that the largest available improvement in this business's cash position required no negotiation, no dispute and no leverage. It required a compliant document.

What To Do

Rebuild the invoice template against the prescribed fields. The clock starts on a proper invoice. A defective template means no statutory entitlement, however overdue the payment feels.

Confirm your billing cadence against the monthly default. Proper invoices are required monthly unless the contract provides otherwise, so check what your contract actually says.

Owners: build a 14-day review process that involves site knowledge. The notice of non-payment window is half the payment period, requires stated reasons and prescribed form, and missing it means the money is due.

Ontario contracts: determine your first annual holdback release date. For contracts entered before January 1, 2026 it is the second anniversary falling after that date, which may be later than you assume.

Model receipts at proper invoice plus 28 and payables at receipt plus 7. Historical collection averages may reflect defective invoicing rather than payer behaviour.

Do not standardise a national template. Prescribed content, notices, holdback and adjudication procedure differ by jurisdiction, and the regimes are at different stages.

In Manitoba and New Brunswick, watch for proclamation. Royal Assent in 2023 is not force, and the day it operates your documents must already comply.

Treat adjudication as a first-line mechanism, not a last resort. It is interim-binding and moves money quickly, and Ontario has expanded its availability in both time and scope.

Design professionals: read any lien waiver request carefully. In Alberta a waiver now also releases the owner from maintaining holdback for those services.

The Limits Of This Analysis

Several caveats matter, and this area is both technical and in flux. This article draws on legal commentary rather than the statutes and regulations directly, and the requirements should be verified against the Construction Act (Ontario) and O. Reg. 264/25, the Prompt Payment and Construction Lien Act (Alberta), Saskatchewan's legislation, the federal Act and its regulations, and the relevant provincial statutes before being relied on. We have not set out the prescribed content of a proper invoice in any jurisdiction, which is the single most operationally important detail in the article and which must be taken from the applicable regulation. The description of adjudication's expanded availability in time reflects commentary rather than our reading of the amended provisions. Statuses change: legislation described here as not yet in force may have been proclaimed since, and British Columbia's regime was described as upcoming at the date of the sources reviewed. This article does not address lien registration and preservation deadlines in detail, trust provisions, substantial performance and certification, surety and bonding, the adjudication procedure itself, enforcement of adjudication determinations, Quebec's civil law regime, or the interaction between the statutory holdback and contractual retention. Nothing here is legal advice; obtain construction law advice specific to your jurisdiction and contracts.

Frequently Asked Questions

What are the payment deadlines?
In Ontario, an owner must pay a contractor within 28 days of receiving a proper invoice unless a notice of non-payment is validly served within 14 days, and payments cascade downstream within 7 days of each party receiving funds. The same 28, 14 and 7 day structure appears in other enacted and pending provincial regimes.
Why might my invoices not be starting the clock?
Because the clock runs from receipt of a proper invoice containing all prescribed fields. A template that predates the legislation or was adapted from another jurisdiction may be missing a required field, in which case no statutory payment obligation is triggered. Reviewing the template against the applicable regulation is the cheapest fix available.
What changed in Ontario on January 1, 2026?
Amendments under Bill 216 and Bill 60, with O. Reg. 264/25, made Ontario the first province to require the 10% accrued statutory holdback be released annually on all construction contracts regardless of duration, contract price, or what the contract says. Private adjudicators are now permitted and adjudication availability expanded in time and scope.
When does my first annual holdback release fall?
For contracts entered before January 1, 2026, the relevant anniversary is the second anniversary date falling after that date. A contract dated December 15, 2025 therefore sees its first calculated release on December 15, 2027. Transitional measures sit in section 87.4 and should be read directly.
Does this apply everywhere in Canada?
No. Ontario, Alberta and Saskatchewan have regimes in force and were designated exempt from the federal Act on December 8, 2023. British Columbia's is upcoming. Manitoba's and New Brunswick's received Royal Assent in 2023 but are not yet in force, meaning the old law still governs there. No exemption is contemplated for Quebec.
What does interim adjudication actually change?
It moves money quickly and binds on an interim basis pending final determination, so the party wishing to overturn the outcome must fund the long proceeding. That reverses the traditional advantage held by whichever party has the deeper balance sheet, which is why it matters most at the bottom of the contracting pyramid.
IB

About The Insight Bureau Research Desk

The Insight Bureau is GSH Financial's research publication, written for Canadian business owners and the students who will eventually advise them. This article flags that it does not reproduce the prescribed content of a proper invoice, which is the detail its central argument depends on and which must be taken from the applicable regulation. See References below.

References

  1. Osler, Hoskin & Harcourt LLP. (2026, March 30). Canadian Prompt Payment and Construction Law Reforms, on the policy objective, the 28 and 14 day structure, Ontario's October 1, 2019 commencement, the January 1, 2026 amendments under Bill 216 and Bill 60, section 87.4 transitional measures, private adjudicators and expanded availability, Saskatchewan and Alberta reforms, New Brunswick awaiting proclamation, and the federal regulations. osler.com/en/insights/updates/canadian-prompt-payment-and-construction-law-reforms
  2. Bennett Jones. (2026, February 20). Updates to Prompt Payment Legislation in Ontario, British Columbia and Alberta, on the 28-day and 14-day rule, the monthly proper invoice requirement, the January 1, 2026 amendments, Ontario as the first province requiring annual release of the 10% accrued holdback, the transitional second-anniversary rule and its December 2025 example, Alberta's Act, and BC's upcoming regime. bennettjones.com/Insights/Blogs/Updates-to-Prompt-Payment-Legislation
  3. Global Law Experts. (2026, May 14). Ontario Construction Act Changes, on the redefined proper invoice with prescribed fields triggering the payment clock, the 7-day downstream cascade, O. Reg. 264/25, the mandatory annual holdback release, and recommended contract payment clause changes. globallawexperts.com/ontario-construction-act-changes
  4. Alexander Holburn Beaudin + Lang LLP. (2026, March 4). Prompt Payment Legislation Update, on New Brunswick's and Manitoba's statutes receiving Royal Assent in 2023 without being in force, the monthly proper invoice requirement, the 28, 14 and 7 day timelines in both, and section 21 adjudication provisions in Manitoba. ahbl.ca/prompt-payment-legislation-update-2
  5. Mondaq. (2026, February 27). Updates To Prompt Payment Legislation In Ontario, British Columbia And Alberta, on the scope of the reforms across payment, disputes, liens and holdbacks, Ontario's mandatory annual holdback release, and the Alberta change linking professional lien waiver to the owner's holdback obligation. mondaq.com/canada/real-estate/1750370
  6. Miller Thomson. (2026, February 27). Canada's Federal Prompt Payment Legislation Now in Force, on the Governor in Council exemption power, the reasonably similar standard, the December 8, 2023 designation of Ontario, Saskatchewan and Alberta, the Regulatory Impact Analysis Statement noting Nova Scotia and Manitoba, and the absence of a contemplated exemption for Quebec. millerthomson.com/en/insights/construction-and-infrastructure-law/canadas-federal-prompt-payment-legislation-now-in-force
  7. BLG. (2026, July). Canada's Prompt Payment Legislation: A National Perspective, on Manitoba's Builders' Lien Act exemptions for architects and engineers, the pre-existing provincial highway and Manitoba Hydro exceptions, and the extension of lien registration and holdback periods to 60 days applying to all contracts. blg.com/en/insights/perspectives/canadas-prompt-payment-legislation

This article discusses prompt payment and adjudication legislation and is provided for general informational purposes. It is not legal advice. Requirements derive from provincial and federal statutes and regulations that should be consulted directly, and the prescribed content of a proper invoice is not reproduced here. Legislative statuses change. Obtain construction law advice specific to your jurisdiction.