The construction industry—whether building skyscrapers, bridges, or infrastructure—operates on a foundation of complex contracts. These agreements define the scope, budget, and timeline of projects while reflecting local laws, customs, and practices.
Because every region has different legal systems and market preferences, construction contracts can vary significantly worldwide. This blog provides a concise guide to some of the most widely used construction contracts across each continent.
North America
United States – ConsensusDocs
ConsensusDocs are developed through industry-wide collaboration, involving contractors, owners, subcontractors, and design professionals. They are widely used because of their focus on fairness and balanced risk-sharing.
Canada – CCDC Contracts
The Canadian Construction Documents Committee (CCDC) produces standard forms used nationwide. These contracts reflect Canadian law and construction practices, offering consistency and reliability.
Europe
United Kingdom – JCT Contracts
The Joint Contracts Tribunal (JCT) contracts dominate the UK market. They are detailed, versatile, and tailored to UK legal and industry standards, covering everything from large commercial projects to small residential builds.
Europe-Wide – FIDIC Contracts
Originating in Switzerland, FIDIC contracts are a cornerstone of international projects across Europe. Their structured approach makes them ideal for cross-border construction and projects financed by global institutions.
Asia
Singapore – PSSCOC
The Public Sector Standard Conditions of Contract (PSSCOC) is widely used in government projects, reflecting Singapore’s strict procurement and legal frameworks.
Malaysia – CIDB Contracts
The Construction Industry Development Board (CIDB) contracts are tailored to Malaysian legal requirements and construction norms.
Japan – ENAA Model Form
The Engineering Advancement Association of Japan (ENAA) model form is common in EPC (Engineering, Procurement, and Construction) projects, particularly in power and process plants, offering flexibility for technical works.
Additionally, FIDIC contracts are often adopted across Asia for projects involving international financing or multinational parties.
Africa
South Africa – JBCC Contracts
The Joint Building Contracts Committee (JBCC) contracts are among the most widely used in South Africa. They are designed to balance risk fairly and reflect the country’s legal practices.
Other African Nations – FIDIC
For projects financed by international banks or involving global stakeholders, FIDIC contracts are the preferred choice, thanks to their international recognition and clear framework.
South America
Brazil – ABNT NBR 15696
Brazilian construction contracts often follow the ABNT standards, which are set by the Brazilian Association of Technical Standards. They ensure alignment with local construction practices and legal requirements.
Argentina – CAMARCO Contracts
In Argentina, contracts from the Argentine Chamber of Construction (CAMARCO) are widely used, offering consistency and compliance with national standards.
Oceania
Australia – Australian Standard (AS) Contracts
Published by Standards Australia, these contracts are tailored to meet the legal and practical needs of Australian construction projects. They provide standardised guidelines to ensure fairness and clarity.
Antarctica
Antarctica is a special case. Construction is limited to research facilities, and contracts are governed by the procurement policies of the research organisations involved. These contracts are highly specific, reflecting the unique governance and logistical challenges of the continent.
Final Thoughts
From ConsensusDocs in the US to JCT in the UK and FIDIC worldwide, construction contracts reflect the diversity of legal systems, industry standards, and cultural practices across the globe.
For professionals working internationally, understanding these differences is essential. A strong grasp of global contract frameworks ensures smoother collaboration, fewer disputes, and more successful project outcomes across continents.
