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Progress billing for subcontractors

2026-09-04 · 6 min read

Geometric abstraction of a progress bar two-thirds filled green
A monthly rhythm, and a cut-off you never miss.

Progress billing is a calendar discipline before it is an accounting one. Here is the cycle, how to assess percent complete honestly, and what to do when a certified application goes quiet.

The billing cycle is a calendar, not a habit

Progress billing runs on a cycle the subcontract sets: a cut-off date, a review period, a certification, and a payment date. Miss the cut-off by a day and you do not lose a day — you lose a month, because the next window is the next cycle.

Put the cut-off in the calendar as a recurring task with a two-day lead. The most expensive billing mistake in construction is not an arithmetic error; it is a submission that arrived on the 6th when the cut-off was the 5th.

Geometric abstraction of two blocks joined by a rule
A bar two-thirds filled, on a fixed monthly rhythm.

Assessing percent complete

Percent complete is assessed per schedule-of-values line, not for the job as a whole. Walk each line, agree the number with whoever certifies it, and submit the figure you can defend rather than the figure you would like. A percentage that has to be revised downward next month costs more credibility than the cash it earned.

Stored materials are billed separately and carry conditions: suitably stored, insured, documented. Bill them only when you can attach the invoice and the certificate, or bill the material when it is installed.

What gets billed this period
ItemBillable nowEvidence
Work in placeYesField walk, agreed percentage
Stored materialsConditionallyInvoice + insurance certificate
Approved change ordersYesSigned change order, own SOV line
Pending change ordersNoBill when approved
RetainageNo — withheldReleased at closeout

What goes in the package

  1. The application summary, with all nine lines reconciled.
  2. The continuation sheet, totalling the contract sum.
  3. A conditional lien waiver for the net payable this period.
  4. Backup for any stored materials.
  5. Signed change orders for anything new on the sheet.

Sending the conditional waiver with the application, rather than after the general asks, removes the most common excuse for a delayed certification. Generate one on the conditional waiver generator.

When the payment does not come

A certified application that goes unpaid is a different problem from a rejected one, and it has a date attached. On federal construction work the progress payment is due 14 days after the designated billing office receives a proper payment request; an improper invoice must be returned within 7 days with reasons. If neither happened, the clock has been running.

Compute what is owed on the prompt payment interest calculator, and if the silence continues, follow the escalation ladder rather than sending a fourth copy of the same invoice.

Geometric abstraction of three rising bars with a red tick
Certified and unpaid is a dated problem, not a mood.

Sources

  • FAR 52.232-27(a)

    On a federal construction contract, a progress payment is due 14 days after the designated billing office receives a proper payment request; an improper invoice must be returned within 7 days with reasons.

    Read 2026-09-04

  • 31 U.S.C. § 3903(a)(6)

    Retained amounts on a federal contract must be released by the date the contract specifies or, if it specifies none, by the 30th day after final acceptance.

    Read 2026-09-04

  • U.S. Treasury, Bureau of the Fiscal Service - Prompt Payment interest rate

    The federal Prompt Payment interest rate for July 1 - December 31, 2026 is 4.75%. Treasury publishes a new rate every six months.

    Read 2026-09-04