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ARTICLE · 30 JULY 2024

Canada's New Debarment Policy – Increased Scope Paired With Increased Flexibility

McCarthy Tétrault
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Long-awaited changes to Canada's Integrity Regime - the suite of policies and contractual terms that underpin Canada's system to defend the integrity...

CanadaInternational Law
Terms Of Trade
Terms Of Trade
Robert Glasgow
Robert Glasgow
John Boscariol
John Boscariol
Andrew Matheson
Andrew Matheson
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Long-awaited changes to Canada's Integrity Regime - the suite of policies and contractual terms that underpin Canada's system to defend the integrity of the government procurement process and debar certain bidders from being eligible for government contracts - came into force on May 31, 2024. The Canadian government has established a new Office of Supplier Integrity and Compliance (the “OSIC”) as part of its overhaul to the old Integrity Regime, and to administer a revised Ineligibility and Suspension Policy (the “Debarment Policy”) which forms the core of the commitments and obligations of suppliers to maintain certain ethical standards.

The new Debarment Policy had its genesis in a proposal in 2018 to implement a Canadian deferred prosecution agreement framework that would be accompanied by a revised Integrity Regime. While the deferred prosecution agreement framework was implemented in the form of Remediation Agreements (discussed in our client alerts here, here 

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