Hiring a subcontractor in Québec: RBQ licence, CCQ and CNESST — what to check before paying

RBQ licence and subclass, wages owed (CCQ), CNESST premium, GST-QST and T5018: what the laws say and what the attestations are really worth.

Hiring a subcontractor means buying work. In Québec, it also means taking on a share of their risks: the wages of their workers, their CNESST premium, and the licence that allows them to do the work. Three laws deal with it, each in its own way, and they have one thing in common: you look at them before signing and before paying, not on the day a problem shows up.

This guide goes through what the texts say, the documents that inform you — the CCQ status letter, the CNESST attestation, the RBQ register — and their limits, because none of them removes the risk on its own. For the other side of the table, the subcontractor who wants to get paid, see Getting paid in Québec.

The overview at a glance

Before signing: the licence, and the right subclass

Section 46 of Québec's Building Act is short. Its first paragraph prohibits acting as a contractor without a licence; the second one is aimed directly at you: no contractor may use, for the performance of construction work, the services of another contractor who does not hold a licence for that purpose.

"For that purpose" matters. A licence only covers its subclasses: a contractor licensed for wood framing is not, for that reason alone, licensed for excavation or roofing. The RBQ repeats it in every warning: before signing, make sure the contractor holds a valid licence and the appropriate subclasses. Its online register of licence holders shows it, along with the claims against the bond and the compensation paid over the last five years.

Their workers' wages: solidarity under Act R-20

Section 54 of Act R-20 makes the wages owed by a subcontractor a solidary obligation between them and the contractor they contracted with — and, further up the chain, with the subcontractor who hired them, the contractor and any intermediate subcontractor. In practice: if your subcontractor does not pay their workers, the CCQ can claim those wages from you.

• When your subcontractor holds their licence, that solidarity ends six months after the end of their work — unless, before that deadline, an employee has filed a complaint with the CCQ, a civil action has been brought, or the CCQ has sent a claim.
• When they do not, the solidarity also extends to the client who contracted with them, directly or through an intermediary, for the wages owed by that contractor and by each of their subcontractors.

The CCQ status letter

This is the document that informs you about that risk. Your subcontractor requests it for their own file, in the CCQ online services, if they are registered as an employer; it costs $30. It is requested for bidding purposes or for the work on a specific job site, and it shows, among other things, the status of their monthly reports, civil claims, work-stoppage orders, penal convictions and whether they hold an RBQ licence.

Their CNESST premium: section 316

The Act respecting industrial accidents and occupational diseases goes further. Its section 316 allows the CNESST to require the employer who retains the services of a contractor to pay the premium owed by that contractor. It may even compute it from the part of the agreed price that corresponds to labour, rather than from the wages declared.

Two sentences of the same section work in your favour. If you pay that premium, you are entitled to be reimbursed by the contractor, and you may withhold the amount from the sums you owe them. And when you show that you retain their services, the CNESST may tell you whether a premium is owed.

What the attestation is worth

Your subcontractor can ask the CNESST for a compliance validation: the answer can be used to bid or to show their compliance to a third party. But the CNESST form says it plainly: the answer does not release a principal from paying the premium owed by the contractor, under section 316.

Comparing prices on the same scope

Many bad surprises start at the bid, when two prices do not cover the same thing. Before comparing, bring every offer back to the same scope:

• the same drawings and addenda, named in the offer;
• what is included and what is excluded, line by line — the lowest offer is sometimes the one that excludes the most;
• the schedule and how long the price is valid;
• taxes: a price before taxes and a price including taxes cannot be compared.

The written contract then restates that scope, the price, the schedule and the holdback. On a private job site, no law sets a holdback percentage: the 5% or 10% holdback you know exists because the contract provides for it. On the client's side, the Civil Code only speaks of a "sufficient amount" for the claims of workers and of those who declared their contract to the client — the details, with releases, are in Getting paid in Québec.

When paying

• The attestations, still valid on the payment date. An attestation that expired the day before no longer tells you anything.
• The release, collected as you pay. Their suppliers and their own subcontractors who declared their contract to the owner are entitled to the legal hypothec on the immovable, and the owner may withhold from what they owe you until they have the release of those claims.
• GST and QST numbers. The CRA puts it simply: use its GST/HST registry to confirm that the business charging you the tax is registered; otherwise, you will pay the tax without being able to claim input tax credits. Revenu Québec, for its part, offers a service to check the validity of a QST registration number.
• The T5018. If more than half of your business activity is construction, the CRA requires a T5018 slip for each subcontractor you paid more than $500 for construction services in the period, not including GST/HST. Payments for goods only are not reported. The return is filed within 6 months after the end of the period you chose: the calendar year or your fiscal period.

An example, end to end

Fictional figures, real sequence. A general contractor hires a roofer for a $38,000 contract before taxes on a commercial building.

• At the bid — they look the roofer up in the RBQ register: licence in force, roofing subclass on file, no recent claim. They ask for their CCQ status letter for bidding purposes and their CNESST compliance validation.
• At signing — the contract restates the drawings, the two addenda, the exclusions, the schedule and a 10% holdback released with the final release. They check the GST and QST numbers once.
• At the third payment — the CNESST attestation expired a week ago. They ask for the new one before paying; it arrives two days later.
• At the last payment — they get the CCQ letter for this job site and the final release, then release the holdback.
• The following year — their reporting period is the calendar year: they file their T5018 slips by June 30.

None of this takes long. What is costly is doing it after the fact: an attestation requested three months after the payment says nothing about the situation on the day you paid.

What BatiCore does, and what it does not

BatiCore checks nothing with the RBQ, the CCQ or the CNESST: it keeps what you enter, or what your subcontractor uploads, and reminds you at the right moment. In practice:

• one record per company, in the directory: RBQ number, CNESST attestation and liability insurance with their validity dates, reused by every project;
• the CCQ status letter noted for each project, and a Compliance column showing who is up to date, who expires within 30 days and who has expired;
• when recording a payment, a reminder of what is missing — expired attestation, missing letter, expired insurance. BatiCore does not block: you may have the document in hand;
• releases and the holdback released with the final release, on paper on every plan, and signed online by the subcontractor in their portal from the Business plan;
• calls for bids (Business plan): one price request to several companies, and their offers compared on the same scope, with a warning when the lowest excludes what others include;
• the year's total paid to each company, across all projects — the basis of your T5018 slips.

The BatiCore team

We build BatiCore, management software for Québec construction contractors — estimates, job sites, CCQ payroll, compliance. Our articles cite dated public sources; when a fact comes from a regulator or a competitor, we say which one and when. Spotted an error? Write to us, we fix it.

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