Integrity Regime

The Integrity Regime is the Government of Canada’s rules-based debarment system, introduced in 2015 and administered centrally by Public Services and Procurement Canada (PSPC) for federal procurement and real property transactions. It exists to keep suppliers convicted or charged of integrity offences — fraud, bribery, bid-rigging, tax evasion and similar — from doing business with the federal government.

What it is

Per PSPC, the central component of the regime is the Ineligibility and Suspension Policy, which sets out when and how a supplier may be declared ineligible or suspended. A supplier that, in the past three years, has been convicted in Canada of a listed offence — or of a similar offence abroad — is declared ineligible for 10 years. A supplier charged with a listed offence can be suspended for up to 18 months, extendable while legal proceedings continue. The regime applies to federal departments and agencies listed in Schedules I, I.1 and II of the Financial Administration Act, and other federal entities such as Crown corporations can adopt it voluntarily.

Other ineligibility grounds

Per the policy, a supplier is also ineligible for 10 years for providing a false or misleading declaration or certification about its eligibility, and for 5 years for entering into a contract with an ineligible or suspended first-tier subcontractor where the information was reasonably available. Suppliers must disclose, at bid time, relevant charges and convictions of the supplier, its affiliates and first-tier subcontractors, and continue disclosing during the contract — a conviction mid-contract can lead to termination for default.

Reduction and administrative agreements

Determinations are made by the registrar of ineligibility and suspension, an assistant deputy minister-level position within PSPC, after the supplier has an opportunity to make written submissions. Ineligibility periods can be reduced by up to 5 years through an administrative agreement, available at minimum 5 years into the ineligibility period, where the supplier demonstrates cooperation with law enforcement or remediation of the causes of the misconduct. The names of ineligible and suspended suppliers — and administrative agreements — are published on PSPC’s website.

Common questions

How is this different from the older Ineligibility and Suspension Policy?

The policy is the operative instrument of the regime itself — the 2015 Integrity Regime replaced the previous 2008 policy with broader grounds, a 3-year lookback, 10-year default ineligibility and the administrative agreement pathway. Buyers verify supplier status through integrity verification requests run by PSPC. See our page on supplier suspension and debarment for the mechanics.

Does bid-rigging trigger the regime?

Yes — convictions under Competition Act cartel provisions, including bid-rigging (section 47), are listed offences: automatic 10-year ineligibility with a possible reduction through an administrative agreement. See bid rigging under the Competition Act.

Related definitions

Code of conduct for procurement · Procurement integrity declaration · Controlled Goods Program