Proactive Disclosure

Proactive disclosure is the mandatory public release of government contract information to promote transparency and accountability. If you're working with federal departments, understanding these reporting requirements matters—not just for compliance, but because this data shapes how Canadians and industry stakeholders view government procurement practices.

How It Works

Under Part 2 of the Access to Information Act, federal departments must publish information on contracts and amendments valued over $10,000. Very few exceptions exist. The disclosure happens quarterly, within one month after each fiscal quarter ends. So if PSPC awards a $50,000 contract in January, details must appear online by the end of April.

Here's what gets published: vendor name, contract value, description of goods or services, contract date, and delivery date. For service contracts valued at $1 million or more—a threshold that took effect October 1, 2023—departments face additional reporting requirements. Contracts under $10,000 get lumped together in an annual report showing total volume and cumulative value, due by May 30 of the following calendar year.

The Guide to the Proactive Publication of Contracts lays out the technical details. Standing offers and supply arrangements also require disclosure for transparency purposes, even though they're not contracts themselves. The Directive on the Management of Procurement makes senior designated officials personally responsible for ensuring this information gets published—it's in Appendix C.2.1 if you want to check the exact wording.

Key Considerations

• Amendments count too. Many people forget that contract amendments over $10,000 trigger the same disclosure requirements as original contracts. A small initial contract with a significant amendment? Both need reporting.

• Timing is strict. That one-month window after quarter-end isn't a suggestion. Departments that miss deadlines face scrutiny, especially since this data feeds into trade agreement reporting obligations under agreements like CETA and CUSMA.

• The $1 million threshold changes things. Since October 2023, high-value service contracts face enhanced reporting. If you're a contractor on these larger deals, expect more information about your engagement to become public.

• It's not just about compliance. According to the Guidelines on the Proactive Disclosure of Contracts, this data serves multiple purposes: transparency for citizens, meeting international trade obligations, and evaluating whether policy instruments actually work as intended.

Related Terms

Standing Offer, Supply Arrangement, Contract Amendment, Trade Agreement Compliance

Sources

• Guide to the Proactive Publication of Contracts - Treasury Board Secretariat

• Guidelines on the Proactive Disclosure of Contracts - Treasury Board Secretariat

• Access to Information Act - Part 2

Whether you're a vendor tracking opportunities or a departmental procurement officer, proactive disclosure shapes the information ecosystem you work in. Get familiar with what gets published and when—it affects your competitive intelligence and compliance obligations alike.