Labour Tracking for ITC Compliance

Accurate, contemporaneous labour tracking is essential for qualifying for the enhanced Clean Economy ITC rate. This guide covers what to track, how to track it, and how to maintain CRA-ready documentation throughout construction.

What to Track

Hours worked by each worker, organized by trade and classification
Wages paid, including benefits, compared against applicable CBA rates
Apprenticeship status, registration numbers, and ratios by trade
Contractor and subcontractor workforce data, down to the individual worker level
Site-specific versus off-site labour distinctions (only on-site construction work counts)

Best Practices

Implement tracking systems before construction begins — retroactive reconstruction is costly
Use standardized certified payroll forms that capture all required data fields
Require all subcontractors to use the same tracking format via EPC contract obligations
Conduct quarterly compliance reviews during construction to identify and correct gaps

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