Contracting Policy Notice 2025-4: Amendments to the Directive on the Management of Procurement to add a risk-based exceptional limit
Date: May 28, 2025 (updated on January 16, 2026)
To: Senior Designated Officials for the Management of Procurement and Functional Heads of Procurement, Administration and Finance units at all departments
Subject: Amendments to the Directive on the Management of Procurement to add a risk-based exceptional limit for Public Services and Procurement Canada
Overview
The Directive on the Management of Procurement was amended to add a new risk-based exceptional limit for Public Services and Procurement Canada (PSPC) in Appendix A.2, effective December 12, 2024.
Namely, subject to approval by the appropriate governance committee, Treasury Board approval is not required for contracts and contractual arrangements that PSPC undertakes on behalf of the Department of National Defence (DND), including the Canadian Coast Guard, that:
- have a low or medium complexity and a low risk according to a risk analysis undertaken by a departmental official who is not otherwise involved in the procurement
- are structured to allow for future competition for the good or service, where possible
- demonstrate that sufficient planning was undertaken, to the extent possible, to avoid the need for urgent approval
Updates new
The Directive on the Management of Procurement was amended to expand the risk-based exceptional contracting limit outlined above. Effective September 18, 2025, PSPC, including the Defence Investment Agency, may, without Treasury Board approval, enter into contracts and contractual arrangements on behalf of DND, including the Canadian Coast Guard, that have a medium risk level.
Treasury Board of Canada Secretariat (TBS) concurrence is required before PSPC can proceed with non-competitive contracts and contractual arrangements with overall medium-risk. Treasury Board approval will continue to be required for high-risk and high-complexity proposals, per requirements outlined in Appendix A.2 of the directive.
Application
TBS may request that any procurement be brought to the Treasury Board at any time.
An Assistant Deputy Minister, to whom the Minister of Public Services and Procurement has delegated decision-making authority, may decide whether or not to exercise the risk-based exceptional limit.
A governance framework that involves PSPC and TBS provides for oversight of the use of the risk-based exceptional limit.
Questions about this policy notice or the directive should be directed to TBS Public Enquiries at questions@tbs-sct.gc.ca.
Samantha Tattersall
Assistant Comptroller General, Investment Management Sector
Treasury Board of Canada Secretariat