Integrity verification response

An integrity verification response is the result returned by the Government of Canada's integrity-verification process after a buyer checks an offeror or contractor against the Registrar of Ineligibility and Suspensions. It tells the buyer whether the supplier can receive the contract or other procurement instrument under consideration.

The check belongs to the federal Integrity Regime, which operates under the Ineligibility and Suspension Policy and is administered through Public Services and Procurement Canada (PSPC). CanadaBuys sets out the possible results under the heading "Verification responses" in its guidance for buyers on elements to consider at award.

The two results a buyer can receive

CanadaBuys identifies two responses. Each one leads to a different outcome for the supplier.

• "Integrity result – The offeror is not ineligible (No match)": the offeror does not match anyone who is ineligible or suspended, and the buyer may proceed with the award or related procurement action.
• "Ineligibility confirmed": the offeror is ineligible or suspended. It cannot ordinarily receive the contract, standing offer, supply arrangement, or placement on a pre-qualified business list.

Where the result is "Ineligibility confirmed", an exceptional Public Interest Exception may be available, as described in the CanadaBuys buyer guidance.

When the verification is required

Buyers must verify that an offeror or contractor is eligible and not suspended before awarding a contract. The same duty applies before issuing a standing offer or supply arrangement, or publishing a pre-qualified business list. It covers a purchase order of $10,000 or more including GST/HST, according to CanadaBuys.

Real-property agreements subject to the Ineligibility and Suspension Policy are also covered. Federal departments and agencies that use the Integrity Regime carry out the check, and PSPC operates the integrity-verification function.

Other organizations run similar programs. The Canada Revenue Agency has a Contracting Integrity Verification Program that checks individuals or companies that may receive, or already hold, CRA contracts. It uses PSPC's integrity database and, where necessary, RCMP criminal-record checks, as described in the CRA privacy impact assessment summary.

What suppliers submit so the check can run

For a solicitation subject to the policy, the supplier generally provides the following with its bid or offer:

• A list of names for integrity verification, containing the information required by section 13 of the policy.
• The required certifications about itself, its affiliates, and its proposed first-tier subcontractors.
• An Integrity declaration form, if it cannot certify all of the required statements.

Suppliers must keep this information current and notify the Office of Supplier Integrity and Compliance if relevant details change. PSPC explains the requirements in its supplier guidance on required information. The standard wording appears in the integrity clauses for procurement contracts.

Transactions outside the Integrity Regime

Contracts, subcontracts, and real-property transactions below $10,000 are excluded from the Integrity Regime. Procurement and real-property authorities do not have to perform an integrity verification for them, according to the PSPC integrity directive on transactions below $10,000.

The term should not be confused with NATO's Building Integrity policy. NATO uses "integrity" in a governance sense, promoting integrity, transparency, and accountability in the defence and security sector. It is a separate matter from the Canadian supplier check.

What it means for a supplier bidding on Canadian public contracts

The response is decided at award, but a supplier's bid sets it up. Submit a complete list of names with every bid or offer subject to the policy. Failure to provide the required information can make a bid non-compliant or disqualify the supplier from contract award, as the PSPC supplier guidance states.

If you cannot make every required certification, include the Integrity declaration form. A "No match" result lets the buyer proceed, while "Ineligibility confirmed" ordinarily bars the award. Review your affiliates and first-tier subcontractors before you bid, and tell the Office of Supplier Integrity and Compliance when your information changes.