By Eric Caouette, VP Business Development of Coginov
On September 8, 2026, the Regulation respecting payments and the prompt resolution of disputes for construction work enters its second phase. For any public-sector organization managing construction projects, the question is no longer whether your supplier invoice processing times are reasonable. The question is whether they are compliant.
And if a supplier challenges a payment delay, can you demonstrate—with documented evidence—what was done, by whom, and when?
This is more than a change in pace. It’s a fundamental shift in expectations.
Historically, paying invoices on time was considered good financial management. For the past year, it has become a regulatory obligation. Failure to comply can now trigger financial consequences and a formal expedited dispute resolution process. Between 2025 and 2027, the regulation continues to expand its scope—covering more organizations, more projects, and increasing the level of exposure with every phase.
The Real Challenge Isn’t Legal—It’s Operational
Over the past few months, I’ve spoken with several finance leaders across public-sector organizations. One observation keeps coming back.
The supplier invoice process most organizations rely on today was never designed to meet strict regulatory deadlines.
Think about what typically happens.
An invoice arrives—by email, through the mail, or via a supplier portal. Someone opens it, saves it, perhaps prints it, then files it. It is forwarded to the project manager to verify that the work has actually been completed. It then returns to Finance for purchase order validation, accounting allocation, and ERP entry. Next comes the approval workflow based on delegated authority. Finally, the payment is issued.
Every one of these steps makes sense – None of them is unnecessary.
But when you combine them with back-and-forth exchanges, vacation periods, invoices sitting unnoticed in inboxes, missing supporting documents that need to be requested, and manual follow-ups, the real processing time quickly stretches into weeks.
Sometimes months.
The regulation, however, does not account for vacations.
It simply sets deadlines.
Where Is the Opportunity?
The obvious reaction might be to hire more people.
Add staff to Accounts Payable to absorb the additional workload.
In today’s public-sector budget environment, that’s rarely realistic—and frankly, it’s not the best solution.
The real time isn’t lost because people are making decisions.
It’s lost performing low-value administrative tasks: retyping information that’s already visible on the invoice, searching for the matching purchase order, manually forwarding documents from one mailbox to another, checking totals and taxes by eye.
Those are the activities that extend processing times.
The operational review performed by the project manager—the part that actually requires professional judgment—creates real value and should absolutely remain.
That’s precisely the problem we set out to solve when designing QoreCapture for municipal, government, and broader public-sector organizations.
The objective isn’t to replace human judgment.
It’s to eliminate the delays created by tasks where human judgment adds no value.
In practical terms, that means automatically processing invoices the moment they arrive—whether by email, portal, or already-digitized document—using cognitive document capture to extract key information such as supplier details, purchase order numbers, invoice amounts, and suggested accounting codes. It means automatically matching invoices against purchase orders and work receipts, routing them to the appropriate approvers based on configurable business rules, and—most importantly for regulatory compliance—maintaining a complete, timestamped audit trail for every action performed.
Across projects we’ve delivered, operational processing times have been reduced by as much as 90%.
That’s not a marketing claim.
It’s simply what happens when document-handling tasks are removed from the critical path.
What Doesn’t Work—And Needs to Be Said
Invoice automation is not a magic wand.
There are a few realities organizations need to acknowledge before moving forward.
First, the quality of extracted data depends heavily on the quality of the invoices themselves.
For recurring suppliers using consistent layouts, recognition rates are excellent.
For handwritten invoices, poor-quality scans, or highly variable subcontractor invoices, organizations should expect an initial calibration phase and accept that some documents will still require human review.
That’s not a limitation of the technology.
It’s simply the reality of the construction industry.
Second, the regulation is about more than speed.
It also requires complete traceability of decisions and timelines.
If you automate invoice processing without implementing comprehensive audit logs, you may gain efficiency while remaining vulnerable during a dispute.
Operational efficiency and regulatory compliance cannot be treated as separate initiatives.
They need to be designed together from day one.
Third—and this is probably the most overlooked point—implementation takes time.
A successful deployment involves ERP integration, approval workflow configuration, supplier calibration, business rule definition, and user training.
That doesn’t happen in a matter of days.
If your organization waits until the fall of 2026 to begin evaluating solutions, chances are you’ll still be implementing after the second phase of the regulation takes effect.
At that point, you’re already operating under increased regulatory exposure.
What Can Still Be Achieved Before the End of 2026
For organizations starting now, there is still a reasonable window to act.
Based on our experience with recent deployments, here’s how we would approach it.
Start by mapping your current invoice processing workflow from beginning to end, measuring actual processing times at every stage.
Many organizations discover that the real bottlenecks aren’t where they initially thought they were.
Next, identify the invoice categories most affected by the regulation—primarily construction-related invoices subject to regulatory payment deadlines—and focus the first phase of automation there.
Other invoice types can follow in a second wave.
Treat compliance and operational efficiency as one single project.
Audit trails, deadline tracking, exception management, and full traceability are the elements that protect your organization during a dispute.
They need to be part of the solution from the very first day of production—not added later.
Finally, choose a technology partner that truly owns and controls its platform and can adapt the solution to your organization’s business rules.
A reseller with no influence over the product will have limited ability to support you when complex or exceptional situations inevitably arise.
And they will.
The regulation introduces new obligations.
But it also presents an opportunity to modernize a process that, in all honesty, has been overdue for improvement across most public-sector organizations.
Public funds should not be spent paying avoidable penalties.
They should be used for what they were intended to do in the first place:
Deliver better public services.
Visit our new QoreCapture Solutions’ page.
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COGINOV is recognized as a world leader in semantic technologies and information management. We are a Canadian software company offering our customers innovative solutions for managing structured and unstructured information. Our head office is based in Montreal.
Coginov’s Qore platform technology enhances the information value chain, transforming unstructured content into highly contextualized, accessible and valuable information. Coginov’s solutions enable you to capture, analyze, engage, automate and manage your information assets, with unrivalled accuracy and efficiency.
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