Integrity Regime

Canada's Integrity Regime is the federal government's mechanism for keeping convicted or dishonest suppliers out of public procurement. Get caught in fraud, corruption, or other serious offences, and you can be barred from bidding on federal contracts for up to a decade. The framework applies government-wide to contracts and real property agreements above $10,000, administered by PSPC's Office of Supplier Integrity and Compliance (OSIC) through the Ineligibility and Suspension Policy.

How It Works

The regime operates through two main components: the Ineligibility and Suspension Policy and mandatory Integrity Clauses that get incorporated into federal contracts. When you submit a bid, you're certifying that neither your company nor its affiliates have been convicted of listed offences or are currently ineligible. False certification? That's 10 years of ineligibility.

Here's how the timelines break down. A conviction for a listed offence in Canada—or a similar offence abroad—triggers a standard 10-year ineligibility period, but you can potentially reduce that by up to 5 years if you cooperate with authorities or implement remedial measures that satisfy OSIC. Subcontracting with an ineligible first-tier subcontractor gets you 5 years. And if you're charged with or admit guilt to a listed offence, OSIC can suspend you for up to 18 months while the case plays out.

Fraud against the Government under the Criminal Code or Financial Administration Act carries permanent ineligibility unless you obtain a record suspension. The policy applies to all departments and agencies listed under Schedules I, I.1, and II of the Financial Administration Act, though it excludes transfer payments like grants and contributions, as well as contracts under foreign military sales programs. The Supply Manual references these requirements as foundational to maintaining supplier standards across federal procurement.

Key Considerations

• The $10,000 threshold matters: Contracts below this amount are exempt, but once you cross it, all Integrity Regime requirements apply. Don't assume small contracts give you a pass on disclosure obligations if you're bidding on larger opportunities elsewhere.

• Affiliate status extends liability: Ineligibility doesn't just affect the convicted entity. OSIC examines corporate relationships, so parent companies, subsidiaries, and affiliated entities can all be caught depending on ownership and control structures.

• Voluntary disclosure can help: If you discover compliance issues before OSIC does, coming forward with remedial action plans can influence whether and how long you're declared ineligible. The 5-year reduction provision exists specifically for suppliers who take responsibility.

• Real property agreements count too: This isn't just about goods and services contracts. Leasing property to the government or involved in real estate transactions with federal departments? Same rules apply.

Related Terms

Procurement Integrity, Standing Offer, Supply Arrangement, Supplier Registration, Contract Security

Sources

• Supplier Integrity and Compliance (Government of Canada)

• Government of Canada Supply Manual

• Government of Canada Integrity Regime Documentation (OAS)

If you're bidding on federal contracts, check your certification obligations carefully. The consequences of getting this wrong extend far beyond losing one opportunity.