Get convicted of bribery, fraud, or collusion, and you're normally locked out of federal contracts for ten years. That's the standard penalty. But an Integrity Provisions Remediation Plan can cut that ban in half—if you can prove to the government that you've genuinely fixed the problem and won't let it happen again.
How It Works
Under the Ineligibility and Suspension Policy, certain convictions trigger an automatic 10-year ban from federal contracting. No bids to PSPC, SSC, DND, or any other federal department. The remediation plan is your way out—or at least your way to shorten the sentence. Submit a plan that convinces the Office of Supplier Integrity and Compliance (OSIC) you've actually reformed, cooperate with law enforcement, and you can reduce your ineligibility to five years.
What does OSIC want to see? Concrete corrective measures. New compliance systems, updated policies, employee training programs, monitoring mechanisms that actually function. They want evidence, not vague promises about doing better. Your plan needs to demonstrate that the conditions that allowed the original misconduct no longer exist. As outlined in Supply Manual Annex 8.1 - Integrity Provisions, contractors acknowledge their obligations under this policy every time they sign a federal contract. The remediation process isn't automatic—OSIC reviews your submission and decides whether you've done enough to earn a second chance.
Acceptance isn't guaranteed. The Minister or OSIC must be satisfied that your organization has fundamentally changed, that taxpayer dollars are safe in your hands. Some offences—particularly frauds committed directly against the government—can result in permanent bans where no remediation plan will help. The current regime has been in place since July 3, 2015, with updates in April 2016, and applies to goods and services contracts as well as real property transactions.
Key Considerations
- Cooperation is mandatory. You can't just submit a remediation plan and expect results. The five-year reduction requires documented cooperation with law enforcement during their investigation. If you stonewalled investigators, you're stuck with the full decade regardless of how impressive your plan looks.
- The clock starts from conviction, not submission. Many suppliers assume they can wait a few years, submit a plan, and reduce their remaining ban period. Doesn't work that way. The ineligibility period begins when you're convicted, so the plan must be accepted early enough to actually matter.
- This isn't a negotiation. OSIC administers the policy with considerable discretion, but they're not interested in creative arguments about why the rules shouldn't apply to you. They want evidence of systemic change: new leadership, restructured oversight, third-party audits, whatever proves the problem is genuinely fixed.
- Your plan becomes part of your record. Once accepted, the government expects you to follow through. Win back your eligibility and then fail to implement the measures you promised? You're facing potential suspension under the same policy.
Related Terms
Integrity Regime, Ineligibility and Suspension, Office of Supplier Integrity and Compliance (OSIC), Supplier Declaration of Compliance
Sources
- Supply Manual - Annex 8.1 Integrity Provisions
- Ineligibility and Suspension Policy (PSPC)
- Office of Supplier Integrity and Compliance
If you're facing ineligibility, don't wait. The remediation process takes time, and the sooner you can demonstrate genuine reform, the sooner you can get back to competing for federal work.