Ontario Construction Act Jan 1 2026 — new 7-day "proper invoice" deeming rule; 28-day owner-to-contractor clock runs from deemed receipt

Claim: Bill 60 (Fighting Delays and Building Faster Act, 2025), in force January 1, 2026, adds a 7-day deeming rule to the Construction Act's prompt-payment regime: an invoice that does not meet the requirements of a "proper invoice" is now deemed proper unless the owner objects within 7 days. The 28-day owner-to-contractor payment clock then runs from deemed receipt.

This closes a previously-exploited loophole — owners could indefinitely delay the 28-day clock by claiming invoices weren't "proper."

Source: Robins Appleby LLP (2026), "Key changes to Ontario's Construction Act introduced by Bill 216 and Bill 60." https://www.robinsappleby.com/publication/key-changes-to-ontario-s-construction-act-introduced-by-bill-216-and-bill-60. See also Bennett Jones LLP, "Updates to Prompt Payment Legislation in Ontario, British Columbia and Alberta." https://www.bennettjones.com/Insights/Blogs/Updates-to-Prompt-Payment-Legislation

Confidence: Verified.

For Candid: The 7-day deeming rule shifts cash-flow risk slightly back toward owners but does not eliminate the underlying 28-day owner / 7-day sub mismatch that drives GCs' short time horizons. Long-payback marketing investments still compete against an empirically calibrated short-cash-cycle reference point ([[koszegi-rabin-2006-reference-dependent-preferences]]).

Cross-reference: Existing entry [[construction-act-prompt-payment-oct-2019-jan-2026]] gives the regime overview; this entry isolates the specific 2026 amendment.