New Federal Integrity Regime: Two Steps Forward, One Step Back

 On July 3, 2015, Public Works and Government Services Canada (PWGSC) announced the implementation of a new government-wide Integrity Regime for all federal government procurement, effective immediately.

The Integrity Regime replaces the Integrity Framework initially introduced by PWGSC in 2012 and amended in March 2014, which was heavily criticized as being unfairly harsh for its lack of due process and failure to account for remedial actions taken by many companies subject to its application. The Integrity Regime is a definite improvement on its predecessor, particularly insofar as it eliminates automatic debarment for the actions of affiliated companies and also allows for a reduction in the debarment period for companies that undertake appropriate remedial conduct. Where it falls short, however, is the Integrity Regime continues to impose a lengthy mandatory debarment period, which for some companies could be akin to a death sentence, no matter what lengths these