T5018 Filing Requirements: The Construction Subcontractor Payment Return
Who has to file a T5018, the more-than-50-percent construction test, the $500 per-subcontractor threshold, what goes in the payment box, holdback timing, the six-month deadline, and the penalties for filing late. Written by a licensed Canadian CPA who works with contractors.
A T5018, Statement of Contract Payments, must be filed by any business whose primary source of income is construction, for each Canadian-resident subcontractor it paid more than $500 for construction services in the reporting period, including GST/HST. The return is due six months after the end of the chosen reporting period, and the amount reported is the gross tax-inclusive amount actually paid, not billed. It is the construction industry's version of the T4, and the CRA uses it to trace subcontractor income.
What the T5018 Is and Why It Exists
The T5018 is an information return, part of the CRA's Contract Payment Reporting System, that reports the payments a construction business makes to its subcontractors. The construction industry has long been a CRA concern for unreported income, particularly where payments are made in cash, so the T5018 exists as a reporting control: it gives the CRA a payment trail even when the payer's own tax balance is unaffected. In practice, the CRA cross-references your slips against each subcontractor's own return, which is why accuracy matters. It sits within our construction accounting work.
Who Has to File
The obligation turns on a single test: whether more than fifty percent of your business's income-earning activities are construction. If they are, and you paid subcontractors for construction services, you file. If construction is a minor part of your business, you generally do not, even if you do significant construction work.
| Situation | T5018 Required? |
|---|---|
| Construction is more than 50% of business income | Yes, for qualifying subcontractor payments |
| Construction is 50% or less of business income | Generally no (non-construction fees may go on T4A) |
| Payment to a non-resident subcontractor | No, use T4A-NR instead |
| Wages to an employee | No, use T4 instead |
The $500 Threshold and What Goes in the Box
You must report a subcontractor when the total you paid them for construction services in the period was more than five hundred dollars, and two details catch people out.
The $500 test is per subcontractor, per period, and includes GST/HST. Several small payments that add up across the year still cross the threshold. And the amount you report is the gross, tax-inclusive amount actually paid, not the net expense and not the amount billed.
- Per subcontractor, per period: pay a framing sub $300 in spring and $350 in fall, and the $650 total means a slip is required.
- Tax-inclusive: the threshold test and the reported amount both include GST, HST and any provincial sales tax.
- Mixed invoices: where an invoice combines materials and services, it is reportable when the service component reaches $500, and the full amount, including materials, is then reported.
Payments, Not Billings, and the Holdback Rule
The T5018 reports amounts actually paid during the period, not amounts billed. This is what makes holdbacks straightforward once you know the rule: a statutory holdback that is still being retained at the end of the period is not yet a reportable payment. It enters the payment box in the later period, when the holdback is released and actually paid to the subcontractor. Reporting a holdback before it is paid, or missing it when it is released, are both common errors. Our holdback accounting in construction guide covers the mechanics; for the T5018, the rule is simply: report what you paid.
The Deadline and the Reporting Period
You elect to report on either a calendar-year or a fiscal-year basis, and once chosen you must keep using that period unless the CRA authorises a change in writing. The return is then due six months after the end of that period.
| Reporting Period Ends | Filing Deadline |
|---|---|
| December 31 (calendar year) | June 30 of the following year |
| March 31 (fiscal year) | September 30 |
| Business ceases operations | Generally within 30 days |
A Worked Example
Take a general contractor with a December 31 year-end who paid three subcontractors during the year.
- Finishing carpenter, $4,200 across six invoices: over $500, so a T5018 slip is required.
- Framing sub, $300 plus $350 on two jobs: $650 total, over $500, so a slip is required.
- One-time debris hauler, $475: under $500, so no slip is required for that subcontractor.
The contractor issues slips for the carpenter and the framing sub, files a T5018 summary totalling them, and files by June 30. Each reported amount is the gross, tax-inclusive amount actually paid.
Where contractors get the T5018 wrong: reporting the net-of-tax amount instead of the gross tax-inclusive figure, reporting billings instead of payments, missing a holdback when it is released, putting a non-resident subcontractor on a T5018 instead of a T4A-NR, mixing an employee's wages onto the slip, and forgetting that several small payments to one sub can cross the $500 line.
The Penalties for Getting It Wrong
Late filing carries a penalty of a set amount per day per slip, with a minimum and a maximum per slip, so a contractor with many subcontractors can accumulate a large total quickly. There are also penalties for failing to obtain a subcontractor's identification number and, at the serious end, for conspiring to avoid reporting. The exact figures are set by the CRA's current grid, which we confirm before filing, but the practical point is that these penalties are entirely avoidable by filing complete and on time. Filing above a certain number of slips must also be done electronically.
Why Accuracy Protects Your Subcontractors Too
The T5018 is not just a courtesy to your subcontractor; it is the document the CRA uses to verify that subcontractor's income. If your slip shows more than the subcontractor reported, the CRA may send them a review letter, and a pattern of mismatches across several subs can prompt a look at your own books. Filing accurate slips, built from reconciled payment records, protects everyone in the chain. That is why we build the T5018 from clean bookkeeping and coordinate it with your payroll compliance and remittances.
Case Study: General Contractor, Ontario
A contractor came to us after a CRA review letter revealed they had never filed T5018s, despite construction being their whole business and paying a dozen subcontractors each year. We confirmed the fifty-percent test was met, reconstructed the payments from invoices and bank records, separated out one non-resident sub who belonged on a T4A-NR and one worker who was partly an employee, corrected the gross tax-inclusive amounts, handled the holdback timing, and filed the outstanding returns, pursuing penalty relief where it was available. Going forward we file the slips and summary electronically each year by the deadline. The figures here are illustrative of the work we do, not a specific client file.
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