Quebec prompt-payment calendar: public construction contracts in 2026

Does your contract fall into the September 2026 phase?

Identify the project owner and the main public contract first. Your direct customer may be a general contractor while the owner is a public body. Your own subcontract value does not, by itself, determine the applicable phase.

Section 94 of the regulation sets out the categories below. Public contract expenditure includes any options provided for in that contract.

Scroll horizontally to see all columns.

This table is an initial screen. Section 90 excludes public contracts already underway when the provisions begin to apply to their category, and contracts resulting from calls for tenders issued before that date. Related subcontracts follow the same exclusion. Signing a subcontract after September 8, 2026 does not, on its own, change the regime for an earlier tender.

Also check that the contract falls within the Act respecting contracting by public bodies, particularly sections 3 and 21.48.21. Public funding alone does not establish that scope. Do not automatically apply this calendar to a private, municipal, or federal contract.

Section 32 excludes emergency contracts entered into because of a threat to the safety of people or property, and certain contracts for Quebec representation activities abroad, from the payment scheme. Related subcontracts are also excluded. Section 33 excludes certain claims for lost profit, productivity, or business opportunity arising from a change. If your request combines these loss claims with billed work, ask a legal adviser to confirm how each part should be handled.

Three examples of the applicability screen

• A new $500,000 building contract: if the tender is issued on or after September 8, 2026, its category enters the second phase. Other scope conditions and exclusions still need checking.
• The same value, with a tender issued September 7, 2026: section 90 prevents applying the new calendar merely because the work starts later.
• A $40,000 electrical subcontract: use the main public contract’s category and expenditure. The smaller subcontract value does not, by itself, postpone application until 2027.

Prepare a request the recipient can assess

A payment request is the document your business sends to the party it contracted with to claim an amount. Sending it does not prove acceptance of the amount or receipt of payment. Creating an accounting invoice remains a separate step under your procedure.

Section 5 requires a written request, dated and signed by the contractor’s representative. It includes the business name and address; a detailed description of the work, expenses, and other items claimed; the corresponding periods; the total and its breakdown; and the name and contact details of the representative. The public contract number is required when the claim results from a public contract.

The general contractor must also identify its subcontractors and the amounts they claim in its own request. Under the regulation, a specialty contractor that holds the public contract and subcontracts some work can occupy this general-contractor role. Classify the parties by their contracts, not only by their trade.

Supporting documents are also governed by section 6. A public body may make validity conditional on documents specified in the public contract. Parties to a public subcontract must record such an agreement in writing. Documents required under that provision must be essential to assessing the request. Record the precise requirement and its source; a generic checklist cannot replace that check.

Separate completed work from forecast work

Section 5 allows a subcontractor to include work or expenses it expects to carry out or incur before the end of the month in which it sends the request. The contractor receiving it may carry those items into its own request. The official guide’s explanation of section 5 then illustrates checking completion before the general contractor’s request.

In your internal records, identify observed and forecast work separately. A photo taken on the 25th cannot establish that work planned for the 30th is already complete. If the forecast changes, flag the difference to the recipient and agree how to handle the request. Section 8 permits amendments agreed by both parties without creating a new request under the regulation; the initial sending date remains.

For calculations and progress evidence, use the construction progress-billing guide. The task here is to place each document correctly in the calendar.

Copy the calendar for a direct subcontractor

Before following the dates, distinguish three situations. A refusal disputes payment of all or part of the claim. A deduction subtracts an amount otherwise due for a permitted reason. A withholding keeps an amount otherwise due until the applicable release conditions are met. Section 14 and sections 16 to 29 govern these distinctions: a deduction or withholding ground cannot serve as a refusal ground.

Fictional example: an electrical business works directly for the general contractor on a covered public contract. Applicability has been confirmed. The electrician sends its September request on September 25, 2026, and the general contractor receives it that day. The general contractor sends its request to the public body, which receives it on October 1. Assume no refusal, deduction, or withholding changes the amount payable.

Sending rules come from section 5, refusal rules from section 10, and payment rules from section 15. A refusal deadline is not a payment date.

Scroll horizontally to see all columns.

The section 16 notices are a copy of the upstream refusal notice and a written notice stating the monetary amount of the deduction. This deduction concerns the amount the subcontractor claimed for the work covered by the upstream refusal, not another subcontractor’s work.

September is the month the electrician’s request is received. October is the first following month; November is the second. The rule does not mean “five days after the public body pays.”

Sections 1 and 2 govern holidays and time computation. A specified date falling on a holiday moves to the next working day. The definition includes Saturdays, January 2, and December 26, as well as the days covered by section 61 of the Interpretation Act. October 24 and 31 are Saturdays in this example. Check the applicable legal calendar before adjusting a date in your system.

If you also have a subcontractor

The table above is no longer sufficient. Section 5 retains the 25th as the limit for subcontractors in the chain. Coordinate sending dates early enough for each party to prepare its request. If the electrician hires another subcontractor, section 10 requires the electrician to communicate any refusal to that subcontractor no later than the day before sending its own request to the general contractor.

Under section 15, the electrician must pay that subcontractor no later than the 10th of the second month after the month it receives that subcontractor’s request. Each additional level beyond these two subcontracting levels adds five days. If the electrician deducts an amount based on an upstream refusal, section 16 requires it to send the notices to its own subcontractor within two days of receiving the deduction notice. Establish a calendar for each contractual relationship, including holiday rules; copying only the main customer’s date is insufficient.

Keep evidence for each event and version

The billing coordinator can copy these fields into the tracking system. This is Aplon’s suggested recordkeeping method, not a prescribed form.

Assign a stable identifier such as PR-09, then v1 and v2 to versions. Keep the file sent and its attachments. An agreed amendment becomes another internal version linked to the original; it does not replace the evidence of the original submission.

Create one event row for each notice, amendment, or payment. If three documents concern different amounts, keep three rows. The file can then show a sent request, partial refusal, and partial payment without compressing them into one “processed” status.

For the first cycle, establish the contract details and recipients. For later cycles, check those details, reuse them, and open a new request for the new period. Carry prior amounts forward according to the billing record without claiming them twice. The payment application tracker explains reconciliation between requested, accepted, invoiced, and paid amounts.

What if the sequence changes?

The portal blocks sending while authorization is pending. Keep evidence of the block and promptly clarify the sending channel with the recipient and your legal adviser. Section 9 prohibits an agreement that makes sending conditional on debtor authorization. Arrange internal approval early enough to meet the calendar.

The recipient asks for a correction. Section 7 allows the party that owes payment to permit correction of a deficiency. If that party does not challenge the request’s validity by its section 10 refusal deadline, the request is considered valid, except for a defect in the sending date. Record the correction request, agreement, and version sent; have the effects on your file checked.

The request was sent on the wrong date. Under section 7, if that defect makes the request invalid, the recipient must treat it as validly sent in the following month unless it decides to overlook the defect. This can move your calendar. Confirm the treatment and keep the supporting evidence before changing the tracked dates.

A notice reduces the amount. Identify the type of notice first. Refusal, deduction, and withholding follow different provisions. Section 11 describes a refusal notice’s required contents, including the amount, affected items, and detailed grounds. Compare it with the relevant request and refer questions about challenging it to a legal adviser. This guide does not calculate a remedy deadline.

A date passes without payment. Check receipt of the request, notices, and actual payments. An administrative reminder does not replace a required notice or remedy. Have the available next steps reviewed promptly instead of waiting for another billing cycle.

Check before the first request

Sources and next step

Consult regulation C-65.1, r. 8.001, the Secrétariat du Conseil du trésor’s explanatory guide, in French, and the government prompt-payment page, in French. The regulation takes precedence over this summary. Example dates are illustrative and do not determine your contract’s dates.

Start with one request: confirm the regime, assign responsibilities, and record the evidence. That gives your team a clear basis for preparing the package and tracking the customer’s response.

Connect your request to its follow-up.

See how Aplon connects progress, verification, approval, sending evidence, and collection tracking.

A person still approves every external commitment.See how Aplon controls the cycle