Ontario Construction Act 2026

Ontario Annual Holdback Release 2026: What Contractors Need to Know

The new annual holdback cascade rules went live January 1, 2026. Here's exactly how they work and what deadlines you can't miss.

Ontario's Construction Act changes effective January 1, 2026 introduced a new annual holdback release process that every contractor and subcontractor needs to understand. Miss a deadline in this cascade, and you risk losing your payment rights.

This guide breaks down the new 2026 annual holdback rules in Ontario, explains the release timeline, and tells you exactly what dates to track.

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How the Ontario Annual Holdback Release Works in 2026

The annual holdback is the 10% of each progress payment that owners must retain under the Construction Act. Under the 2026 Ontario holdback release rules, this holdback is released annually through a specific cascade of deadlines.

Here's the sequence:

The Annual Holdback Cascade Timeline

1

Contract Anniversary

The anniversary of your contract triggers the holdback release process.

2

14 Days: Owner Publishes Notice

Within 14 days of the anniversary, the owner must publish a notice of intended holdback release.

3

60-74 Days: Owner Pays Holdback

The owner pays the holdback to the general contractor 60-74 days after notice publication.

4

14 Days: GC Pays Subcontractors

General contractor must pay subcontractors within 14 days of receiving the holdback.

The 14-Day Holdback Notice Requirement in Ontario

The construction holdback 14-day notice is a critical new requirement. Within 14 days of your contract anniversary, the project owner must publish a formal notice that they intend to release the holdback.

This notice starts the clock on the payment timeline. If you're a contractor, you need to track:

When Do the New Holdback Rules Apply?

The Construction Act 2026 amendments in Ontario include transition rules for existing contracts:

Transition Rule

For contracts signed before January 1, 2026, the first mandatory annual holdback release occurs on the second anniversary after January 1, 2026.

This means if you have a contract signed in 2024, your first mandatory annual holdback release under the new rules won't be until 2028 at the earliest.

What About Lien Rights Under the 2026 Rules?

Good news: Bill 60 originally proposed automatic lien expiration, but this provision was scrapped. Under the current 2026 rules:

This is important protection for contractors. The annual holdback release process is separate from your lien rights, and missing a holdback deadline doesn't automatically eliminate your right to file a lien.

Deadlines Ontario Contractors Must Track in 2026

Under the new rules, here's what you need on your calendar for each project:

Deadline Who's Responsible
Contract anniversary Track it yourself
Anniversary + 14 days (notice) Owner must publish
Notice + 60-74 days (payment) Owner must pay GC
Payment + 14 days (cascade) GC must pay subs

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Frequently Asked Questions: Ontario Annual Holdback 2026

When does Ontario holdback release in 2026?

Annual holdback release is triggered on your contract anniversary date. The owner has 14 days to publish notice, then 60-74 days to pay. For existing contracts, the first mandatory release is on the second anniversary after January 1, 2026.

What is the annual holdback cascade in Ontario?

The cascade is the sequence of deadlines: anniversary triggers the process, owner publishes notice within 14 days, owner pays holdback 60-74 days after notice, then the general contractor pays subcontractors within 14 days of receiving funds.

How does the 14-day holdback notice work in Ontario?

Within 14 days of the contract anniversary, the owner must publish a notice of intended holdback release. This starts the 60-74 day payment window. Your lien rights remain intact even if the owner misses this deadline.

Do Ontario lien rights expire automatically in 2026?

No. Bill 60's automatic lien expiration provision was scrapped. Your lien rights remain intact under the 2026 rules. You still need to preserve and perfect your lien within existing timeframes, but they don't expire automatically.

When do the new Ontario holdback rules apply to existing contracts?

For contracts signed before January 1, 2026, the first mandatory annual holdback release occurs on the second anniversary after January 1, 2026. This transition rule gives existing projects time to adjust.

Don't Miss a Single Deadline

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