Every bidder on federal contracts must sign an Integrity Regime Declaration before award, confirming they haven't been convicted of specified criminal offences and aren't currently suspended from contracting. This isn't a formality. Lying on this declaration can get you banned from federal contracting for up to a decade, even if you've already won the contract.
How It Works
The declaration requires you to disclose convictions for specific offences: corruption, bribery, fraud, money laundering, terrorist financing, and certain other criminal activities. You're also confirming that you're not currently suspended or declared ineligible under the Ineligibility and Suspension Policy. According to the Government of Canada Supply Manual, this applies to all procurement over $10,000—which means virtually every competitive opportunity on Buy and Sell.
Here's the thing: departments like PSPC and DND don't just take your word for it. They maintain a consolidated list of suspended and ineligible suppliers, and contracting officers verify declarations against this database before awarding contracts. If you're a subcontractor providing goods or services worth more than $10,000, you need to complete the declaration too. The prime contractor is responsible for collecting these from their supply chain.
Most standard Request for Proposals include the declaration as an attachment or embedded form, which you sign as part of your bid submission. If circumstances change after you've submitted—say, your company gets convicted of fraud—you have an ongoing duty to inform the contracting authority immediately. Silence becomes misrepresentation.
Key Considerations
- Corporate vs. individual scope: The declaration covers offences committed by your organization, but also by directors, officers, and in some cases, employees acting on behalf of the company. A conviction against your CFO can trigger disclosure requirements.
- Foreign convictions count: If your company or its principals were convicted of equivalent offences in other countries, you still need to disclose them. The assessment looks at the conduct, not just Canadian court records.
- Timing matters for subcontractors: Many bidders forget to collect declarations from their major subs before contract award. You can't wait until after you win—the prime contractor needs these on file when the declaration is submitted.
- Self-reporting is mandatory: If you discover after award that information in your declaration was incomplete or incorrect, report it immediately. Voluntary disclosure may reduce penalties, but staying silent guarantees severe consequences when discovered.
Related Terms
Conflict of Interest and Post-Employment Declaration, Ineligibility and Suspension Policy, Standing Offer Agreement
Sources
- Government of Canada Supply Manual - Public Services and Procurement Canada
- Canada Buys - Federal Procurement Portal
- Buy and Sell - Government of Canada Tender Opportunities
Treat this declaration as seriously as the contract itself. The federal government has shown it will pursue enforcement, and the reputational damage from suspension extends well beyond lost revenue.