Treasury Board Approval (TB Approval)

Treasury Board Approval is the formal authorization you need from Canada's Treasury Board when your procurement exceeds your department's delegated spending authority or carries significant policy implications. When your contracting authority isn't enough, you're going up the chain. The Treasury Board Contracts Directive establishes these approval authorities and the thresholds that trigger this requirement.

How It Works

Not every contract needs TB Approval. Your department has delegated authority up to certain limits—typically $2 million for services advertised on the Government Electronic Tendering Service (GETS), $400,000 for competitive contracts, and $100,000 for non-competitive procurements. Exceed these thresholds? You'll need to prepare a formal submission for the Treasury Board.

The approval process requires a detailed Treasury Board submission that outlines your procurement rationale, cost estimates, market analysis, and any policy implications. PSPC (Public Services and Procurement Canada) often plays a coordinating role for major procurements, though individual departments maintain responsibility for their submissions. Important to note: the Government of Canada Supply Manual, particularly section 6A.001, specifically prohibits contract splitting—breaking up requirements into smaller contracts just to stay under your delegated authority and avoid TB Approval. This is taken seriously under TB Contracting Policy Subsection 11.2.7.

In practice, the submission process can add significant time to your procurement timeline. You'll need to account for Treasury Board Secretariat review cycles, potential requests for additional information, and formal approval meetings. For particularly complex or sensitive procurements—think major IT systems or defence acquisitions—this process takes months, not weeks.

Key Considerations

• Threshold awareness matters early. If your preliminary estimate suggests you might approach or exceed your delegated authority, start planning for TB Approval from day one. Last-minute submissions rarely go smoothly.

• Mandatory instruments can bypass individual approvals. The TB Contracting Policy and TB Common Services Policy sometimes mandate use of specific standing offers or supply arrangements. When you're required to use these pre-approved vehicles, you typically don't need separate TB Approval for individual call-ups within the established parameters.

• Different rules for different departments. While Treasury Board sets baseline thresholds, PSPC and individual departments may establish more restrictive internal limits. The Office of the Procurement Ombudsman noted that PSPC's rationale for reducing certain limits from TB-approved levels isn't always transparent to client departments.

• Non-competitive contracts face tighter scrutiny. The $100,000 threshold for non-competitive procurements is significantly lower than competitive thresholds, reflecting Treasury Board's preference for open competition and value for money.

Related Terms

Contracting Authority, Delegated Financial Signing Authority, Treasury Board Secretariat, Contract Splitting

Sources

• Treasury Board Contracts Directive - Treasury Board of Canada Secretariat

• Government of Canada Supply Manual - Public Services and Procurement Canada

• Chapter 5: Methods of Supply - Office of the Procurement Ombudsman

Bottom line: know your limits and plan accordingly. The time invested in a proper TB submission beats explaining why you tried to split a contract.