Subcontractor Invoice Review Checklist

Subcontractor Invoice Review Checklist

Fast-Fact Summary Box

• Template Type: Commercial Subcontractor Invoice Review Checklist
• Governing Framework: Ontario Construction Act Prompt Payment Rules
• Target Trade: General Contractors & Project Administrators
• Primary Operational Risk: 7-day proper-invoice deficiency review and 28-day payment-clock control

Scope Boundaries (Who/What it applies to)

This checklist applies to all General Contractors, Project Managers, and Contract Administrators managing trade subcontractors on commercial, industrial, and institutional projects in Ontario. It governs the administrative intake, technical validation, and payment processing of progress draws, final invoices, and statutory declarations for all trade labour and material programmes. The scope is strictly bound to mitigating the risk of missing the statutory 7-day proper-invoice review window, ensuring that all subcontractor billing submissions are systematically vetted for compliance before the mandatory 28-day prompt-payment clock is triggered.

Mandatory Deliverables & Administrative Windows

• Pre-Billing Deliverables: Signed subcontract agreement, approved Schedule of Values (SOV), and active WSIB clearance certificate.
• Intake Window: Subcontractor submits invoice; Project Administrator must log the exact date and time of receipt to establish the statutory baseline.
• Deficiency Review Window: 7 calendar days from receipt to issue a formal written notice of deficiency if the invoice fails to meet "proper invoice" criteria.
• Monthly Deliverables: Signed Statutory Declaration (CCDC 9A) for progress payment two and onward, updated WSIB clearance, and progress photos.
• Closeout Window: Final statutory declaration, release of holdback application, and publication of Form 6 for multi-year contracts.

Ontario Regulatory Compliance Notes

All invoicing and payment administration must strictly adhere to the Ontario Construction Act, incorporating the January 1, 2026 amendments under Bill 216 and Bill 60:

• Proper Invoice Deeming: Invoices are legally deemed proper unless the owner gives a formal written notice of deficiency within 7 days after receiving the invoice. Missing the 7-day notice window forfeits the right to dispute invoice form or structure and starts the 28-day prompt-payment timeline.
• Annual Holdback Release: For contracts extending beyond one year, owners must publish a Notice of Annual Release of Holdback (Form 6) on an electronic construction trade news website within 14 days after each contract anniversary. Payment of the accrued basic holdback must occur no earlier than day 60 and no later than day 74 after publication, provided no liens are preserved.
• Repeal of Section 27.1: The former section 27.1 notice-of-non-payment mechanism for refusing holdback distribution due to deficient or incomplete work is repealed. Holdback use is restricted to formal contract abandonment or termination scenarios and preserved lien risk.
• Adjudication Window: Parties have a strict 90-day window after contract completion, abandonment, or termination to initiate interim binding adjudication through ODACC or a qualified private adjudicator.

Form/Sign-off Requirements

• Project Manager Sign-off: Mandatory signature and date confirming physical verification of work-in-place and material delivery.
• Subcontractor Representative Signature: Signed and notarized Statutory Declaration (CCDC 9A) attached to all progress draws after the first.
• Change Order Reconciliation: Written acknowledgement and sign-off of all approved Change Orders included in the billing cycle.
• WSIB Clearance Attachment: Current, valid WSIB clearance certificate attached to every invoice submission.
• Record Retention: Mandatory 7-year digital archiving of all invoices, deficiency notices, and payment receipts.

Official Verification Sources

• Ontario Construction Act, R.S.O. 1990, c. C.30
• O. Reg. 304/18 (Procedures and Forms)