A contractor invoice check for Ontario's 7-day rule: not open yet

Section 6.1(2) of the Ontario Construction Act took effect on January 1, 2026. It deals with contractor invoices to an owner (as defined in section 1 of the Act) that miss required items. We plan a check for this. It would read each invoice against the Construction Act and your contract. It would list the items from section 6.1 or your contract that it could not find on the invoice, with each reference. It does not write notices.

Ask to be told when it opens

The service is not open, and we do not accept any invoices or contracts yet, so please attach none. Email support@aokenlabs.com with your company name and roughly how many contractor invoices you receive a month. We store your email like any other support email, as described on our privacy page. We use it only to reply and to tell you once, by email, when the check opens. We have no opening date yet.

What the Act says

Section 6.1(1) of the Ontario Construction Act (on e-Laws, the official law site) lists what a proper invoice must contain:

• the contractor's name and address
• the invoice date, and the period, milestone or other payment entitlement it bills for
• what identifies the contract, such as its contract number, line item number or purchase order number
• a description of the services or materials, with quantities where appropriate
• the amount payable and the payment terms
• the name, title, mailing address and phone number of the person or office to send payment to
• any information the owner reasonably requests for its accounts payable system
• anything else the contract specifies

Under section 6.1(2), an invoice that misses any of these is deemed to be a proper invoice unless, no later than 7 days after receiving it, the owner notifies the contractor in writing. The notice must name the deficiency and what is required to address it. The forms regulation, O. Reg. 303/18, has no form for this notice.

Under section 6.4, an owner who disputes a proper invoice may refuse to pay all or part of it by giving the contractor a notice of non-payment, in the prescribed form, no later than 14 days after receiving the proper invoice.

Section 87.4(2) says the 2026 amendments apply to an improvement from the day they took effect, with the exceptions in that section. Section 87.3(4) sets limits on Part I.1, the prompt payment part that holds section 6.1. Part I.1 does not apply to contracts entered into before October 1, 2019. It also does not apply where the owner started the procurement before that date.

What the check would do

• Read each contractor invoice against the items above, the invoice requirements in your contract, and the accounts payable requests you give us.
• List each section 6.1 or contract item it could not find on the invoice, with its reference.
• Put price and quantity differences on a separate list for your staff. The check does not decide whether they are missing items or disputes.
• We plan to accept PDF invoices. We have not tested PDFs or scans yet: the test below used typed text.

What it does not do

• It does not draft or send notices. We do not act for you.
• It is not legal advice. Ask your lawyer about your contracts and any dispute.
• It does not judge whether the work was done or valued correctly.
• It does not judge whether your contract terms or accounts payable requests are reasonable or apply.
• It covers invoices from a contractor to an owner only. Section 6.1 is about proper invoices given to the owner.
• An empty list is not a finding that the invoice is a proper invoice under the Act.
• It does not decide which version of the Act applies to your contract.

How we tested it

On October 11, 2026 we tested the invoice check on 30 invoices we wrote ourselves. Each came with a made-up contract summary and an owner's accounts payable letter. 22 invoices had 41 missing or wrong items we had added on purpose; 8 had none.

• 38 of the 41 items were found (about 93%).
• Nothing was reported that we had not added, and the check listed no missing items for any of the 8 complete invoices.
• The 3 misses were 1 HST number the accounts payable letter asked for, and 2 unit prices that differed from the contract. The planned check would put unit prices on the separate list. We have not tested that list yet.

The invoices were typed text, not PDFs or scans, and no real invoice was used. This test says nothing about real invoices yet. Email us if you want to see the test cases.

Planned price

• CAD 9 per invoice, or CAD 149 a month for up to 30 invoices and CAD 5 for each invoice after that. Prices are before HST.
• The price may still change before the service opens. Nobody pays anything now.
• Before we accept any invoice, we will publish how invoices are stored and when they are deleted.
• For questions, email support@aokenlabs.com or see the contact page.