Integrity Provisions

When you bid on federal government contracts, you're required to declare that neither you nor your directors have been convicted of certain serious offences—and if you have, you could be barred from federal contracting for up to a decade. These are integrity provisions, the enforcement mechanism of Canada's Ineligibility and Suspension Policy, administered by the Office of Supplier Integrity and Compliance (OSIC). They're mandatory in virtually all federal procurement above basic acquisition thresholds.

How It Works

Here's the thing: integrity provisions aren't just boilerplate language you click through. They require active disclosure. When you submit a bid to any department—whether it's PSPC, DND, or SSC—you must provide the names of all directors and owners, and declare whether any of them have been charged with or convicted of specified offences. Those offences include bribery, fraud, forgery, theft, fraud against the government, money laundering, and various corruption-related crimes under the Criminal Code or the Corruption of Foreign Public Officials Act.

If you're convicted of a listed offence, OSIC can declare you ineligible to contract with the federal government for 10 years. That prohibition applies across the board—not just to traditional procurement contracts, but also to supply arrangements, standing offers, and even real property transactions with any department or agency listed under Schedule I, I.1, and II of the Financial Administration Act. The 10-year period can be reduced to five years, but only if you cooperate fully with law enforcement and undertake specific remedial actions to address the underlying issues.

The disclosure obligation is ongoing. You're required to inform the Contracting Authority within 10 working days if you or any of your directors are charged with or convicted of a listed offence during the contract period—yes, even if it happens after you've won the bid. The government can verify your declarations at any time and request supporting documentation. These clauses are detailed on the Ineligibility and Suspension Policy clauses page, which includes the specific contractual language that appears in solicitations.

Key Considerations

• Corporate changes trigger new declarations. If your ownership structure changes—new directors, new controlling shareholders—you need to reassess your disclosure obligations. What was true six months ago may not be true today.

• Charges count, not just convictions. While ineligibility typically flows from conviction, you must disclose charges as well. Failing to disclose can result in contract termination and potential suspension even if the charges don't lead to conviction.

• Successor liability is real. If you acquire a company or merge with one that has integrity issues, those problems can follow the new entity. Due diligence matters before corporate transactions.

• This applies beyond PSPC. Every major federal department incorporates these provisions. The Canada Revenue Agency even has its own Supplier Integrity Directive that mirrors the broader policy framework.

Related Terms

Code of Conduct, Conflict of Interest, Standing Offer

Sources

• Office of Supplier Integrity and Compliance (OSIC)

• Ineligibility and Suspension Policy Clauses

• Government of Canada Supply Manual

If you're unsure about your disclosure obligations, get legal advice before submitting your bid. A false declaration is grounds for immediate disqualification and potential suspension—consequences far worse than withdrawing from a single competition.