Registrar of Ineligibility and Suspension

The Registrar of Ineligibility and Suspension is an independent Government of Canada position. The Registrar determines whether a supplier is ineligible or suspended, sets the applicable periods, and enters into administrative agreements with suppliers, according to the Ineligibility and Suspension Policy.

The Registrar is the designated authority for suspending suppliers, declaring them ineligible and determining how long an ineligibility lasts. Public Services and Procurement Canada reports on these actions in its annual misconduct and wrongdoing disclosures. For suppliers, the Registrar is the official whose decisions determine whether they can do business with the federal government.

What the Registrar can decide

The Registrar can take two principal types of administrative action:

• Suspend a supplier or declare it ineligible to do business with Canada.
• Require a supplier to enter into an administrative agreement as a condition of continuing to do business with Canada.

The Registrar also sets the period of each suspension or ineligibility. The authority covers awards of federal contracts and real-property agreements, so a supplier can be barred from receiving either. These authorities are delegated from the responsible federal minister, as described in the departmental briefing materials. The delegation is intended to keep the official who makes debarment decisions independent from the officials who administer procurement and real-property authorities.

Where the role sits in the federal structure

The Registrar operates within the Office of Supplier Integrity and Compliance (OSIC) at Public Services and Procurement Canada. OSIC administers the federal Ineligibility and Suspension Policy, and its work is described on the Supplier Integrity and Compliance page. The policy covers suppliers that may be suspended or declared ineligible from doing business with the Government of Canada.

Verification before a contract is awarded

Federal contracting authorities must check with the Registrar before they commit to a supplier. The CanadaBuys buyer's guide requires them to verify that the offeror is not ineligible or suspended before they:

• award a contract;
• issue a purchase order;
• issue a standing offer or supply arrangement;
• publish a pre-qualified supplier list.

The check applies across these instruments, not only to standard contracts.

Other organizations that refer to the Registrar

The Registrar's role extends beyond Public Services and Procurement Canada. The Canada Revenue Agency Supplier Integrity Directive incorporates the same Registrar role and responsibilities, including determinations of ineligibility and suspension and administrative agreements. Defence Construction Canada's Procurement Code of Conduct directs inquiries about ineligible or suspended individuals to the Registrar.

What it means for a supplier bidding on Canadian public contracts

An ineligible or suspended status blocks awards, because contracting officers must verify eligibility with the Registrar before they award. A supplier that receives a notice of intended suspension or ineligibility can contact the Registrar through the OSIC contact page. Suppliers may submit information, certifications and validations for review, and may request a limited review of an eligibility determination. Bid teams should treat any such notice as urgent and respond within the process the Registrar sets out.