Payment demand letter for unpaid construction invoices
A lawyer's demand letter for unpaid progress invoices, with a warning about lien and adjudication deadlines.
What is included
- Works out lien, holdback and notice deadlines from your project dates
- Prepares and registers the claim for lien and perfects it in court
- Sends prompt payment demands and answers notices of non-payment
- Advises owners, lenders and contractors on holdback, trust and priority rules
- Moves to vacate a lien by posting security or paying into court
- Makes claims on payment or performance bonds
What is not included
- Reports from engineers, schedulers or quantity surveyors, and other disbursements
- Court, adjudication or arbitration filing fees
- Appeals unless added to the retainer
- Project management or site inspections
Who this service is for
- Contractors, subcontractors and suppliers who have not been paid
- Owners and lenders dealing with a registered lien
- Contractors closing out a project
Information to have ready
- 1The contract and the last date you supplied services or materials
- 2Unpaid invoices and payment history
- 3The property address and owner's name
- 4Any bond, holdback or lien notices received
How a referral works
- 1Tell us in a few words what the matter is about, and who else is involved, so we can check for a conflict of interest.
- 2We recommend an Ontario lawyer for your matter, and at least one other you could choose instead.
- 3The lawyer runs their own conflict check, confirms the scope and quotes the fee, normally in a written retainer agreement.
- 4You pay the lawyer's fee to the lawyer. Any referral fee comes out of it, is disclosed to you in writing, and never increases what you pay.
NEO Legal Services Professional Corporation is a licensed paralegal firm, not a law firm. Every step of a referral, and your rights
Frequently asked questions
What does the lawyer charge?
A typical Ontario fee for this service is $400–$1,200, plus HST. The lawyer quotes the actual fee before any work starts. You pay the lawyer directly; the referral itself costs you nothing.
What is the holdback?
Owners and payers usually must keep back part of each payment to protect subcontractors and suppliers further down the chain. The Construction Act sets when it must be released, and those rules changed on January 1, 2026, so the lawyer will check which apply to your contract.
What is prompt payment?
Under the Construction Act, owners usually must pay a proper invoice within set times unless they give a notice of non-payment, and payment then flows down to subcontractors within set times. Disputes can go to adjudication.
General information only, not legal advice. NEO Legal Services Professional Corporation is a licensed paralegal firm regulated by the Law Society of Ontario.
Important limitations
- No outcome can be guaranteed
- Statutory and contract deadlines keep running during a referral
- The lawyer confirms the scope, fee and steps in a written retainer before starting
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