Buy Canadian Procurement Policy Framework: What Section 9 Requires of Departments and Agencies
- Jul 24
- 2 min read
The federal government's Buy Canadian Procurement Policy Framework took effect on December 16, 2025. It sets the foundation for prioritizing Canadian suppliers, materials, and content across federal procurement, and it comes with a set of concrete obligations for departments and agencies. Section 9 of the Framework, titled "Requirements," is where those obligations are spelled out. Here is what it says and what it means in practice.
The core obligations
Under Section 9, departments and agencies must:
Integrate Canadian prioritization requirements into procurement planning. This means Statements of Work, technical specifications, and evaluation criteria all need to reflect the scope and conditions of the relevant policy instrument from the outset, not bolted on after the fact.
Apply the prescribed measures consistently and concurrently. Where more than one policy instrument applies to a procurement, both must be applied together rather than treated as alternatives.
Obtain offeror certifications, declarations, or attestations where required. Suppliers will need to formally attest to Canadian content or origin as defined in the supporting instruments.
Invoke exceptions only within defined conditions and approval processes. Departments cannot opt out of the Framework informally; any exception has to follow the approval process set out in the relevant policy instrument.
Ensure Canadian prioritization measures appear in Statements of Work, technical specifications, and evaluation criteria, including when a common service provider like PSPC or Shared Services Canada is running the procurement on their behalf. In that case, the requesting department must give the service provider enough information to apply the Framework correctly.
Reassess Canadian capability when exercising contract options with non-Canadian suppliers. Even though the option itself is governed by existing terms, departments should consider whether domestic capacity has grown since the original award and whether re-procurement would better serve Canadian preference objectives.
Apply overlapping policies concurrently. Where a procurement falls under both the Policy on Prioritizing Canadian Materials in Federal Procurements and the Policy on Prioritizing Canadian Suppliers and Canadian Content in Strategic Federal Procurements, both apply unless an exception has been formally approved.
Why this matters
Section 9 is the operational core of the Framework. The preceding sections set out purpose, context, and roles; Section 9 is where those intentions become procurement-desk reality. For any organization bidding on federal work, or any department running a procurement, this section is the practical checklist: what has to be in the solicitation documents, what certifications to expect, and how narrow the exceptions actually are.
Combined with Section 10's monitoring and reporting obligations, departments will also need to keep documentation ready to demonstrate compliance, not just apply the measures once and move on.
The bottom line
The Requirements section leaves little room for informal workarounds. Canadian prioritization has to be built into planning documents, applied consistently across overlapping policies, backed by supplier certifications, and revisited even at the point of exercising contract options. Organizations working with the federal government, and the officials running these procurements, should treat Section 9 as the compliance backbone of the entire Framework.
