Integrity Regime

The Integrity Regime is Public Services and Procurement Canada's framework for protecting the integrity of federal contracting. It makes suppliers subject to integrity-related eligibility, disclosure, ineligibility and suspension requirements. It applies to suppliers bidding on, contracting for, or entering into certain real-property agreements with the Government of Canada, as set out in PSPC's guidance on replacement entities and completing contractors.

In practice, suppliers meet the regime as a set of clauses and forms inside a solicitation. The wording usually refers to the Integrity Provisions, the Ineligibility and Suspension Policy, and a declaration or verification form that a bidder completes and returns. Understanding these documents early helps a bid team avoid losing a compliant proposal on a paperwork failure.

Who administers the Integrity Regime and who applies it

PSPC administers the Integrity Regime under the federal Ineligibility and Suspension Policy and related integrity provisions. Procurement notices describe it this way, including a National Research Council Canada notice of proposed procurement.

Other organizations adopt it for their own contracting. The National Research Council Canada states that it has adopted the PSPC-administered Integrity Regime and applies its integrity provisions to NRC contracting activities, as shown in a further NRC notice of proposed procurement. National Defence solicitations also carry the regime through their standard clauses.

Forms and clauses suppliers will see in solicitations

Canadian procurement documents commonly use these terms:

• Integrity Provisions, found in the Standard Instructions for federal solicitations.
• Ineligibility and Suspension Policy, the policy that the provisions rest on.
• Integrity Declaration Form, which concerns criminal charges or convictions covered by the policy.
• Integrity Verification Form, tied to the names needed for verification.
• Declaration of Convicted Offences, used in defence solicitations.

A federal request for proposal can require the applicable Integrity Declaration Form with the bid. An invitation to tender explains that the form concerns criminal charges or convictions covered by the Ineligibility and Suspension Policy.

National Defence solicitations include a clause titled "Integrity Provisions – Declaration of Convicted Offences". A set of RFP clauses shows this wording, and a defence bid solicitation directs bidders to provide the applicable declaration under the Integrity Regime.

Real-property agreements and contract defaults

The regime is not limited to procurement contracts. It also covers specified real-property agreements, and the applicable policy requires information when bidding, contracting or entering into such an agreement. A request for quote shows this language in use.

It also reaches beyond the original supplier. PSPC applies the regime to a replacement entity, completing contractor, surety and relevant first-tier subcontractors when they assume or complete work after a supplier defaults. A firm that steps in to finish a defaulted contract can therefore become subject to the same integrity requirements.

The Integrity Regime compared with NATO's integrity principle

The Integrity Regime is a distinct Canadian framework. NATO's Procurement Manual separately states that the highest standards of integrity must be maintained throughout procurement. It stresses honesty, trust, professional conduct and avoiding even the appearance of conflicts of interest. See the NATO Procurement Manual. Suppliers working on both Canadian and NATO opportunities should treat them as separate sets of expectations.

What the Integrity Regime means for a supplier

Read the integrity clauses in every solicitation and identify which forms apply to your firm. Depending on the solicitation and your circumstances, you must provide required integrity information, including the names needed for verification and a declaration concerning relevant offences.

Submit the forms with the bid or offer when they apply. Failure to provide required documentation can prevent the bid from receiving further consideration. Because the regime appears across general federal, defence, NRC and real-property procurement, build the forms into your standard bid checklist instead of treating them as occasional extras.