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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)

In force Prompt payment
Status In force In force since Jan 1, 2026
Where Ontario Prompt payment
Who is affected 5 of 7 groups listed below

What changes

All law updates

Owners 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.

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