ABSTRACT
It is to be noted that the Irish Act very clearly indicates that it relates not only to progress payments but also to the final payment due under the contract. Many of the non-European Acts refer to progress payments only leading to some confusion as to whether that expression could be interpreted to include the final payment due under the contract. Because of a subtle difference in wording between the NSW Act and the Singapore Act, which was in fact modelled on the NSW Act, the term progress payments was found in Singapore to include1 the final payment but in New South Wales was found not to do so.2
