CFTA vs CITT bid-challenge timelines

Two clocks govern bid challenges in Canadian federal procurement. The Canadian Free Trade Agreement (CFTA) sets a floor: every supplier must get at least ten days from when the grounds of challenge became known to prepare and submit a challenge (Article 518). The Canadian International Trade Tribunal (CITT), the designated complaint authority for federal procurements, runs a stricter, procedural schedule inside that floor.

The two frameworks

The CFTA is the trade agreement: it requires each Party to designate an impartial review authority and guarantees at least ten days to challenge. For Government of Canada procurements covered by the CFTA and other trade agreements, that authority is the CITT, operating under section 30.11 of the CITT Act and its Procurement Inquiry Regulations. In other words, the CFTA tells you the minimum window; the CITT rules tell you the exact deadline and what happens after you file.

The CITT clock, step by step

Per the Tribunal's regulations and annual reports: you have 10 working days after the day you became (or should have become) aware of the grounds to file a complaint — or to object first to the government institution, which then gives you another 10 working days after its denial of relief. In exceptional circumstances (cause beyond your control, or a systemic issue raised in good faith), the Tribunal may accept a complaint up to 30 calendar days after the basis became known. Once filed, the Tribunal decides within 5 working days whether to hold an inquiry; the government institution files its report in 25 days; you get 7 working days to comment; and the Tribunal must issue findings and recommendations within 90 days of filing — 45 days if the express option is granted, 135 days maximum with an extension. Review of the Tribunal's findings goes to the Federal Court of Appeal.

Why the difference matters

Working days vs. calendar days matters: the CITT's 10 working days is often longer than CFTA's bare ten days, but the Tribunal's exception window is only 30 calendar days total. Missing the filing deadline is fatal — the regulations require the Tribunal to dismiss late complaints, and unlike other time limits, filing deadlines cannot be extended. If you think a process was unfair, note the date you knew, and file or object within 10 working days.

Common questions

Does the CITT handle provincial and municipal CFTA complaints?

No. The CITT reviews designated federal contracts. For CFTA-covered purchases by other parties, each provincial and territorial government designates its own independent review authority under Chapter 5 of the CFTA.

Is there a dollar minimum for CITT complaints?

Only designated contracts qualify — procurements covered by at least one trade agreement the Tribunal administers, such as CFTA-covered federal buys above the CFTA thresholds, as adjusted from time to time.

Related definitions

CITT bid-challenge process · CFTA thresholds · Sole-source justification