Integrity Regime Declaration

An Integrity Regime Declaration is the Integrity declaration form that a supplier submits to the Government of Canada when it cannot certify compliance with the Ineligibility and Suspension Policy as part of its bid or offer. The form provides information about relevant charges, convictions, or other circumstances involving the supplier, its affiliates, or its proposed first-tier subcontractors. Public Services and Procurement Canada (PSPC) publishes it with its supplier integrity forms.

The declaration is conditional. A supplier that can make every required integrity certification does not need to complete it. It is a bid-submission document for suppliers whose circumstances prevent them from certifying in full, not a routine form required from every bidder.

From the Integrity Regime to the Ineligibility and Suspension Policy

The term comes from Canada's former Integrity Regime. That framework is now administered through PSPC's supplier-integrity framework under the Ineligibility and Suspension Policy. The declaration sits alongside related concepts: integrity provisions, supplier ineligibility and suspension, certifications, affiliates, and proposed first-tier subcontractors. PSPC's supplier guidance collects these requirements in one place.

When a supplier must submit the declaration

By submitting a bid or offer, a supplier certifies that it has read and understands the Ineligibility and Suspension Policy. The supplier then certifies compliance directly in the bid. If it cannot provide all of the required certifications, it must submit a completed Integrity declaration form to the Office of Supplier Integrity and Compliance. PSPC sets this out on its required information page.

• In ordinary procurement contracts, the standard integrity clauses require an offeror that cannot provide the prescribed certifications to submit the completed form at the time of its offer. See the procurement contract clauses.
• PSPC applies equivalent requirements to real-property transactions.
• A supplier that can certify compliance as part of its bid or offer does not need to complete the form.

How the declaration appears in solicitations

Federal departments and agencies incorporate the PSPC integrity provisions into their solicitations. A CanadaBuys bid solicitation for National Defence states that bidders must provide the declaration form, where applicable, for the bid to receive further consideration. The RCMP solicitation for Haines Junction is another example of a federal solicitation that carries these provisions.

Accuracy, due diligence and each-bid requirements

Suppliers must provide the applicable certifications or declaration with each bid or offer. This applies even where the supplier has submitted another bid or is involved in a separate integrity determination. The supplier is responsible for ensuring that its certifications and declarations are accurate, complete, and not misleading. PSPC expects due diligence concerning the supplier, its affiliates, and its proposed first-tier subcontractors. Its guidance on misleading certifications explains these expectations.

What it means for a supplier bidding on Canadian public contracts

Check your integrity position before every federal bid, not once a year. Review the supplier, its affiliates, and each proposed first-tier subcontractor against the certifications in the solicitation. If you can certify everything, no declaration is needed. If you cannot, complete the Integrity declaration form and include it with the bid or offer, because a National Defence solicitation makes it a condition of further consideration. Build this check into your bid process so that the form is ready before the closing date.