Construction Act: annual holdback release, proper-invoice deeming, broader adjudication
Ontario · Building Ontario For You Act (Budget Measures), 2024 (Bill 216, S.O. 2024, c. 20), Schedule 4 amending the Construction Act, R.S.O. 1990, c. C.30; O. Reg. 264/25 (adjudications)
What changes
All law updatesOwners must publish a notice within 14 days after each contract anniversary and release accrued holdback annually, and payers must pass it down the chain. An invoice is deemed proper unless the owner gives written notice of deficiencies within 7 days. Adjudication scope moves into regulation and expands, private adjudicators are allowed, adjudications can be consolidated, and adjudicators may correct a determination within 5 days.
- Law or regulation
- Building Ontario For You Act (Budget Measures), 2024 (Bill 216, S.O. 2024, c. 20), Schedule 4 amending the Construction Act, R.S.O. 1990, c. C.30; O. Reg. 264/25 (adjudications)
- Jurisdiction
- Ontario
- In force
- Jan 1, 2026
- Official source
- Legislative Assembly of Ontario
Who it affects and how
Owners & developers
People and companies who own the property and commission the work, including homeowners renovating
You must track contract anniversaries, publish annual holdback release notices and respond to invoice deficiencies within 7 days.
Contractors
General contractors, builders and construction business owners
Holdback flows yearly on multi-year jobs. Invoices count as proper unless challenged within 7 days, and more disputes can go to adjudication.
Trades
Subcontractors and trade contractors
Annual holdback must be passed down promptly, which improves cash flow on long projects.
Suppliers
Sellers of materials, products and equipment
Suppliers on long projects benefit from annual holdback release down the payment chain.
Designers
Architects, engineers and designers
Consultants under construction contracts can use the expanded adjudication for fee and scope disputes.
Not directly affected: homebuyers & customers, workers.
Plain-language summary by ArtBuild, checked against the official source on Oct 29, 2026. General information, not legal advice; you are responsible for how you use it. The official text governs: read it, and we recommend asking a lawyer or the regulator about your situation.