Treasury Board Approval (TB Approval)

Treasury Board approval, often shortened to TB approval, is approval from the Treasury Board of Canada. It is generally required before a federal department enters into or amends a contract or contractual arrangement whose estimated value is above the limit the department's contracting authority has been delegated.

It is an internal government control. The buying department seeks it, not the supplier, and it comes from the federal contracting-approval framework set out in Treasury Board policies and directives. The Directive on the Management of Procurement assigns contracting authorities the responsibility to seek TB approval when the applicable approval limits are exceeded.

What triggers the requirement for TB approval

TB approval is required for contracts or amendments that exceed predetermined limits. Those limits sit in Appendix A of the Directive on the Management of Procurement, and the Treasury Board requirements for contracting approval state that approval is needed before entering into or amending a contract when the value goes above them. Contracts within the applicable delegated limit may be entered into without TB approval, subject to the Directive's conditions and limits.

When a department tests a contract against its limit, it must count more than the base price. The estimated value includes:

• the contract's estimated value;
• applicable taxes;
• expected amendments;
• follow-on contracts or contractual arrangements.

The same logic applies to acquisition instruments. TB approval may be required before a department enters into or amends a contract issued under a standing offer or supply arrangement when its estimated value exceeds the limit approved for that instrument.

Timing: approval comes before the contract and the work

Required TB approval must be obtained before the proposed contract or amendment is entered into and before the associated work begins, according to CanadaBuys guidance on Treasury Board submissions. A department cannot start the work first and regularize it afterwards.

CanadaBuys award guidance adds a related control. No contractual commitment may be made if it would be the first step of a procurement that may later require TB approval. For that reason, a department can complete an evaluation and still hold off on any binding commitment until the approval is in place.

Advance approval and ceiling amounts

Departments do not always wait until final contract details are known. Based on the procurement strategy or plan, a department may seek advance Treasury Board approval. This can include approval of a ceiling amount when the eventual contract value is not yet known. The Directive on the Management of Procurement provides for this option, so a major procurement can receive approval at the planning stage rather than at the point of award.

The Treasury Board submission

The vehicle for seeking approval is the Treasury Board submission, or TB submission. It is an official document submitted by a minister on behalf of a department to seek approval from Treasury Board ministers when required. The contracting authority prepares the documentation. Treasury Board Secretariat publishes guidance for drafters of Treasury Board submissions for the officials who write them.

Special case: former public servants

PSPC guidance sets a specific threshold for certain suppliers. TB approval is required before issuing a call-up or contract to specified former-public-servant suppliers when the total value, including amendments, exceeds $100,000, as described in the PSPC supply arrangement guidance.

What TB approval means for a supplier

You do not apply for TB approval, and you do not prepare the submission. Your job is to comply with the solicitation. Be aware that a bid, a negotiation or a notice that you have been selected is not a contract until the government has obtained all required approvals. Do not commit resources or begin work before you hold a signed contract or amendment.

On large opportunities, and on contracts likely to be amended or followed by further work, expect the approval step to sit between selection and contract signature. Contracts whose estimated value includes expected amendments and follow-on work are the ones most likely to cross a department's limit.