Bank of Montreal (NOA) group reports 9.76% ownership in North American Construction

Rhea-AI Filing Summary

Bank of Montreal and affiliates report a large ownership stake in North American Construction Group Ltd. common shares. The filing shows beneficial ownership of 2,873,159 common shares, representing 9.76% of the class, as of the stated date. These shares are attributed across several related entities, including Bank of Montreal, Bank of Montreal Holding Inc., BMO Nesbitt Burns Inc. Wealth Management, BMO Asset Management Inc., BMO Nesbitt Burns Securities Ltd., and BMO Nesbitt Burns Inc.

The reporting persons have significant sole voting and dispositive power over most of these shares, with smaller amounts subject to shared voting and dispositive power. The securities are held in the ordinary course of business, primarily in prime brokerage and asset management accounts for clients who may have the right to receive dividends or sale proceeds. The group explicitly states the holdings are not intended to change or influence control of the issuer.

Insights

Equity ownership and regulatory filings analyst

Bank of Montreal entities disclose a near-10% passive stake in NOA.

The disclosure shows Bank of Montreal and several affiliated entities collectively beneficially owning 2,873,159 common shares of North American Construction Group Ltd., equal to 9.76% of the outstanding class. This positions the BMO complex as a significant shareholder under U.S. reporting rules, triggered once ownership exceeds 5%.

The filing breaks down sole versus shared voting and dispositive powers across the various BMO entities and notes that many of the securities are held in the ordinary course of business as prime broker or asset manager for underlying clients, who may receive dividends and sale proceeds. The certification states the position is not held for the purpose of changing or influencing control, which aligns with a passive institutional investment profile.

The document does not specify transaction dates or prices for building this position, focusing instead on ownership levels as of 12/31/2025. Subsequent ownership changes, if any, would be captured in future beneficial ownership reports once thresholds or filing triggers are met under the applicable rules.

SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

SCHEDULE 13G

UNDER THE SECURITIES EXCHANGE ACT OF 1934

(Amendment No. 1)

North American Construction Group Ltd.

(Name of Issuer)

Common Shares

(Title of Class of Securities)

656811106

(CUSIP Number)

12/31/2025

(Date of Event Which Requires Filing of this Statement)

Check the appropriate box to designate the rule pursuant to which this Schedule is filed:

Rule 13d-1(b)

Rule 13d-1(c)

Rule 13d-1(d)

SCHEDULE 13G

CUSIP No. 656811106

1

Names of Reporting Persons

Bank of Montreal

2

Check the appropriate box if a member of a Group (see instructions)

(a)
(b)

3

Sec Use Only

4

Citizenship or Place of Organization

CANADA (FEDERAL LEVEL)

Number of Shares Beneficially Owned by Each Reporting Person With:

5	Sole Voting Power 2,869,602.00
6	Shared Voting Power 2,807.00
7	Sole Dispositive Power 2,870,352.00
8	Shared Dispositive Power 2,807.00

9

Aggregate Amount Beneficially Owned by Each Reporting Person

2,873,159.00

10

Check box if the aggregate amount in row (9) excludes certain shares (See Instructions)

11

Percent of class represented by amount in row (9)

9.76 %

12

Type of Reporting Person (See Instructions)

HC

SCHEDULE 13G

CUSIP No. 656811106

1

Names of Reporting Persons

BANK OF MONTREAL HOLDING INC.

2

Check the appropriate box if a member of a Group (see instructions)

(a)
(b)

3

Sec Use Only

4

Citizenship or Place of Organization

CANADA (FEDERAL LEVEL)

Number of Shares Beneficially Owned by Each Reporting Person With:

5	Sole Voting Power 2,869,602.00
6	Shared Voting Power 2,807.00
7	Sole Dispositive Power 2,870,352.00
8	Shared Dispositive Power 2,807.00

9

Aggregate Amount Beneficially Owned by Each Reporting Person

2,873,159.00

10

Check box if the aggregate amount in row (9) excludes certain shares (See Instructions)

11

Percent of class represented by amount in row (9)

9.76 %

12

Type of Reporting Person (See Instructions)

BK

SCHEDULE 13G

CUSIP No. 656811106

1

Names of Reporting Persons

BMO NESBITT BURNS INC. WEALTH MANAGEMENT

2

Check the appropriate box if a member of a Group (see instructions)

(a)
(b)

3

Sec Use Only

4

Citizenship or Place of Organization

CANADA (FEDERAL LEVEL)

Number of Shares Beneficially Owned by Each Reporting Person With:

5	Sole Voting Power 2,791,402.00
6	Shared Voting Power 2,807.00
7	Sole Dispositive Power 2,792,152.00
8	Shared Dispositive Power 2,807.00

9

Aggregate Amount Beneficially Owned by Each Reporting Person

2,794,959.00

10

Check box if the aggregate amount in row (9) excludes certain shares (See Instructions)

11

Percent of class represented by amount in row (9)

9.49 %

12

Type of Reporting Person (See Instructions)

BD

SCHEDULE 13G

CUSIP No. 656811106

1

Names of Reporting Persons

BMO ASSET MANAGEMENT INC.

2

Check the appropriate box if a member of a Group (see instructions)

(a)
(b)

3

Sec Use Only

4

Citizenship or Place of Organization

ONTARIO, CANADA

Number of Shares Beneficially Owned by Each Reporting Person With:

5	Sole Voting Power 2,483,004.00
6	Shared Voting Power 0.00
7	Sole Dispositive Power 2,483,004.00
8	Shared Dispositive Power 0.00

9

Aggregate Amount Beneficially Owned by Each Reporting Person

2,483,004.00

10

Check box if the aggregate amount in row (9) excludes certain shares (See Instructions)

11

Percent of class represented by amount in row (9)

8.43 %

12

Type of Reporting Person (See Instructions)

IA

SCHEDULE 13G

CUSIP No. 656811106

1

Names of Reporting Persons

BMO NESBITT BURNS SECURITIES LTD.

2

Check the appropriate box if a member of a Group (see instructions)

(a)
(b)

3

Sec Use Only

4

Citizenship or Place of Organization

CANADA (FEDERAL LEVEL)

Number of Shares Beneficially Owned by Each Reporting Person With:

5	Sole Voting Power 0.00
6	Shared Voting Power 0.00
7	Sole Dispositive Power 0.00
8	Shared Dispositive Power 750.00

9

Aggregate Amount Beneficially Owned by Each Reporting Person

750.00

10

Check box if the aggregate amount in row (9) excludes certain shares (See Instructions)

11

Percent of class represented by amount in row (9)

0 %

12

Type of Reporting Person (See Instructions)

BD

SCHEDULE 13G

CUSIP No. 656811106

1

Names of Reporting Persons

BMO NESBITT BURNS INC.

2

Check the appropriate box if a member of a Group (see instructions)

(a)
(b)

3

Sec Use Only

4

Citizenship or Place of Organization

CANADA (FEDERAL LEVEL)

Number of Shares Beneficially Owned by Each Reporting Person With:

5	Sole Voting Power 78,200.00
6	Shared Voting Power 0.00
7	Sole Dispositive Power 78,200.00
8	Shared Dispositive Power 0.00

9

Aggregate Amount Beneficially Owned by Each Reporting Person

78,200.00

10

Check box if the aggregate amount in row (9) excludes certain shares (See Instructions)

11

Percent of class represented by amount in row (9)

0.26 %

12

Type of Reporting Person (See Instructions)

BD

SCHEDULE 13G

Item 1.
(a)	Name of issuer: North American Construction Group Ltd.
(b)	Address of issuer's principal executive offices: 27287 100 AVENUE, ACHESON, ALBERTA, CANADA T7X 6H8
Item 2.
(a)	Name of person filing: Bank of Montreal BANK OF MONTREAL HOLDING INC. BMO NESBITT BURNS INC. WEALTH MANAGEMENT BMO ASSET MANAGEMENT INC. BMO NESBITT BURNS SECURITIES LTD. BMO NESBITT BURNS INC.
(b)	Address or principal business office or, if none, residence: 1 First Canadian Place Toronto, Ontario, Canada M5X1A1
(c)	Citizenship: Bank of Montreal - CANADA (FEDERAL LEVEL) BANK OF MONTREAL HOLDING INC. - CANADA (FEDERAL LEVEL) BMO NESBITT BURNS INC. WEALTH MANAGEMENT - CANADA (FEDERAL LEVEL) BMO ASSET MANAGEMENT INC. - ONTARIO, CANADA BMO NESBITT BURNS SECURITIES LTD. - CANADA (FEDERAL LEVEL) BMO NESBITT BURNS INC. - CANADA (FEDERAL LEVEL)
(d)	Title of class of securities: Common Shares
(e)	CUSIP No.: 656811106
Item 3.	If this statement is filed pursuant to §§ 240.13d-1(b) or 240.13d-2(b) or (c), check whether the person filing is a:
(a)	Broker or dealer registered under section 15 of the Act (15 U.S.C. 78o);
(b)	Bank as defined in section 3(a)(6) of the Act (15 U.S.C. 78c);
(c)	Insurance company as defined in section 3(a)(19) of the Act (15 U.S.C. 78c);
(d)	Investment company registered under section 8 of the Investment Company Act of 1940 (15 U.S.C. 80a-8);
(e)	An investment adviser in accordance with § 240.13d-1(b)(1)(ii)(E);
(f)	An employee benefit plan or endowment fund in accordance with § 240.13d-1(b)(1)(ii)(F);
(g)	A parent holding company or control person in accordance with § 240.13d-1(b)(1)(ii)(G);
(h)	A savings associations as defined in Section 3(b) of the Federal Deposit Insurance Act (12 U.S.C. 1813);
(i)	A church plan that is excluded from the definition of an investment company under section 3(c)(14) of the Investment Company Act of 1940 (15 U.S.C. 80a-3);
(j)	A non-U.S. institution in accordance with § 240.13d-1(b)(1)(ii)(J). If filing as a non-U.S. institution in accordance with § 240.13d-1(b)(1)(ii)(J), please specify the type of institution:
(k)	Group, in accordance with Rule 240.13d-1(b)(1)(ii)(K).
Item 4.	Ownership
(a)	Amount beneficially owned: 2,873,159
(b)	Percent of class: 9.76 %
(c)	Number of shares as to which the person has:
	(i) Sole power to vote or to direct the vote: Bank of Montreal - 2,869,602 BANK OF MONTREAL HOLDING INC. - 2,869,602 BMO NESBITT BURNS INC. WEALTH MANAGEMENT - 2,791,402 BMO ASSET MANAGEMENT INC. - 2,483,004 BMO NESBITT BURNS SECURITIES LTD. - 0 BMO NESBITT BURNS INC. - 78,200
	(ii) Shared power to vote or to direct the vote: Bank of Montreal - 2,807 BANK OF MONTREAL HOLDING INC. - 2,807 BMO NESBITT BURNS INC. WEALTH MANAGEMENT - 2,807 BMO ASSET MANAGEMENT INC. - 0 BMO NESBITT BURNS SECURITIES LTD. - 0 BMO NESBITT BURNS INC. - 0
	(iii) Sole power to dispose or to direct the disposition of: Bank of Montreal - 2,870,352 BANK OF MONTREAL HOLDING INC. - 2,870,352 BMO NESBITT BURNS INC. WEALTH MANAGEMENT - 2,792,152 BMO ASSET MANAGEMENT INC. - 2,483,004 BMO NESBITT BURNS SECURITIES LTD. - 0 BMO NESBITT BURNS INC. - 78,200
	(iv) Shared power to dispose or to direct the disposition of: Bank of Montreal - 2,807 BANK OF MONTREAL HOLDING INC. - 2,807 BMO NESBITT BURNS INC. WEALTH MANAGEMENT - 2,807 BMO ASSET MANAGEMENT INC. - 0 BMO NESBITT BURNS SECURITIES LTD. - 750 BMO NESBITT BURNS INC. - 0
Item 5.	Ownership of 5 Percent or Less of a Class.
	Not Applicable
Item 6.	Ownership of more than 5 Percent on Behalf of Another Person.
	If any other person is known to have the right to receive or the power to direct the receipt of dividends from, or the proceeds from the sale of, such securities, a statement to that effect should be included in response to this item and, if such interest relates to more than 5 percent of the class, such person should be identified. A listing of the shareholders of an investment company registered under the Investment Company Act of 1940 or the beneficiaries of employee benefit plan, pension fund or endowment fund is not required. The securities reported herein are held in the ordinary course of business of the Reporting Person acting as prime broker on behalf of certain clients who have the power to direct the receipt of dividends from, or the proceeds from the sale of such securities.
Item 7.	Identification and Classification of the Subsidiary Which Acquired the Security Being Reported on by the Parent Holding Company or Control Person.
	If a parent holding company has filed this schedule, pursuant to Rule 13d-1(b)(ii)(G), so indicate under Item 3(g) and attach an exhibit stating the identity and the Item 3 classification of the relevant subsidiary. If a parent holding company has filed this schedule pursuant to Rule 13d-1(c) or Rule 13d-1(d), attach an exhibit stating the identification of the relevant subsidiary. See Documents
Item 8.	Identification and Classification of Members of the Group.
	If a group has filed this schedule pursuant to §240.13d-1(b)(1)(ii)(J), so indicate under Item 3(j) and attach an exhibit stating the identity and Item 3 classification of each member of the group. If a group has filed this schedule pursuant to §240.13d-1(c) or §240.13d-1(d), attach an exhibit stating the identity of each member of the group. Each reporting person may be deemed to be a member of a group with respect to the issuer or securities of the issuer for the purposes of Section 13(d) or 13(g) of the Act. Each reporting person declares that neither the filing of this statement nor anything herein shall be construed as an admission that such person is, for the purposes of Section13(d) or 13(g) of the Act or any other purpose, (i) acting (or has agreed or is agreeing to act) with any other person as a partnership, limited partnership, syndicate, or other group for the purpose of acquiring, holding, or disposing of securities of the issuer or otherwise with respect to the issuer or any securities of the issuer or (ii) a member of any syndicate or group with respect to the issuer or any securities of the issuer.
Item 9.	Notice of Dissolution of Group.
	Notice of dissolution of a group may be furnished as an exhibit stating the date of the dissolution and that all further filings with respect to transactions in the security reported on will be filed, if required, by members of the group, in their individual capacity. See Item 5. Each reporting person may be deemed to be a member of a group with respect to the issuer or securities of the issuer for the purposes of Section 13(d) or 13(g) of the Act. Each reporting person declares that neither the filing of this statement nor anything herein shall be construed as an admission that such person is, for the purposes of Section13(d) or 13(g) of the Act or any other purpose, (i) acting (or has agreed or is agreeing to act) with any other person as a partnership, limited partnership, syndicate, or other group for the purpose of acquiring, holding, or disposing of securities of the issuer or otherwise with respect to the issuer or any securities of the issuer or (ii) a member of any syndicate or group with respect to the issuer or any securities of the issuer.

Item 10.

Certifications:

By signing below I certify that, to the best of my knowledge and belief, the securities referred to above were acquired and are held in the ordinary course of business and were not acquired and are not held for the purpose of or with the effect of changing or influencing the control of the issuer of the securities and were not acquired and are not held in connection with or as a participant in any transaction having that purpose or effect, other than activities solely in connection with a nomination under ?? 240.14a-11.

SIGNATURE

After reasonable inquiry and to the best of my knowledge and belief, I certify that the information set forth in this statement is true, complete and correct.

Bank of Montreal

Signature:	Kathryn Cenac
Name/Title:	Managing Director - Regulatory Solutions Group
Date:	01/08/2026

BANK OF MONTREAL HOLDING INC.

Signature:	Kathryn Cenac
Name/Title:	Managing Director - Regulatory Solutions Group
Date:	01/08/2026

BMO NESBITT BURNS INC. WEALTH MANAGEMENT

Signature:	Kathryn Cenac
Name/Title:	Managing Director - Regulatory Solutions Group
Date:	01/08/2026

BMO ASSET MANAGEMENT INC.

Signature:	Kathryn Cenac
Name/Title:	Managing Director - Regulatory Solutions Group
Date:	01/08/2026

BMO NESBITT BURNS SECURITIES LTD.

Signature:	Kathryn Cenac
Name/Title:	Managing Director - Regulatory Solutions Group
Date:	01/08/2026

BMO NESBITT BURNS INC.

Signature:	Kathryn Cenac
Name/Title:	Managing Director - Regulatory Solutions Group
Date:	01/08/2026

FAQ

What ownership stake does Bank of Montreal report in North American Construction Group Ltd. (NOA)?

Bank of Montreal and its affiliates report beneficial ownership of 2,873,159 common shares of North American Construction Group Ltd., representing 9.76% of the outstanding class as of 12/31/2025.

Which Bank of Montreal entities are included in this NOA Schedule 13G/A filing?

The filing lists Bank of Montreal, Bank of Montreal Holding Inc., BMO Nesbitt Burns Inc. Wealth Management, BMO Asset Management Inc., BMO Nesbitt Burns Securities Ltd., and BMO Nesbitt Burns Inc. as reporting persons for the NOA common shares.

How many NOA shares does BMO Asset Management Inc. specifically report owning?

BMO Asset Management Inc. reports an aggregate beneficial ownership of 2,483,004 common shares of North American Construction Group Ltd., with sole voting and sole dispositive power over the same number of shares.

Is Bank of Montreal seeking to influence control of North American Construction Group Ltd.?

No. The certification states the securities were acquired and are held in the ordinary course of business and were not acquired and are not held for the purpose of or with the effect of changing or influencing the control of North American Construction Group Ltd.

Who ultimately receives dividends or sale proceeds from the NOA shares reported by Bank of Montreal?

The filing explains that the reported securities are held in the ordinary course of business by the reporting person acting as prime broker on behalf of certain clients, and those clients may have the power to direct the receipt of dividends and the proceeds from the sale of such securities.

Why is a Schedule 13G/A being filed for North American Construction Group Ltd. (NOA)?

A Schedule 13G/A is required because the reporting persons exceed the 5% beneficial ownership threshold in NOA common shares. The amendment updates their reported holdings and confirms their status as passive, ordinary-course holders under the applicable rules.