Contracting Policy Notice 2025-7: Buy Canadian Policies and associated amendments to the Canadian International Trade Tribunal Inquiry Regulations and Directive on the Management of Procurement

Date: December 17, 2025

Overview

The Government of Canada is implementing measures to become our own best customer, moving from “best efforts” to a clear obligation to buy Canadian and use more Canadian steel, aluminum, wood products and other Canadian materials, products, technologies and services in federal purchasing. This includes release of a new Buy Canadian Policy.

As announced on December 16, 2025, Public Services and Procurement Canada (PSPC), as the exclusive authority for procurement for the Government of Canada, has developed the Buy Canadian Procurement Policy Framework, which took effect on December 16, 2025. It provides an overarching foundation for Buy Canadian procurement policies to strengthen Canada’s economic resilience and industrial capacity, and support domestic businesses and workers, by prioritizing Canadian suppliers, materials and content in federal procurements.

The following policy instruments are issued under this Buy Canadian Procurement Policy Framework. Each policy establishes specific requirements that support the implementation of Buy Canadian measures in federal procurement:

• Effective December 16, 2025, the Policy on Prioritizing Canadian Materials in Federal Procurement mandates the use of Canadian steel, wood products and aluminum in federal defence and construction procurements valued at $25 million or more that contain at least $250,000 worth of steel, wood products or aluminum and where Canadian supply exists.
• Effective December 16, 2025, the Policy on Prioritizing Canadian Suppliers and Canadian Content in Strategic Federal Procurements requires that procurements involving sectors and commodities that advance Canada’s economic, industrial and innovation priorities preference Canadian suppliers by applying a discount to their bid price during the bid evaluation process. Additionally, the policy also directs that additional points be awarded to suppliers’ bids based on the percentage of Canadian content they commit to providing in their bid. The policy will initially apply to all procurements valued at $25 million and up, and by June 15, 2026, the threshold will be lowered to $5 million and up.
• Effective July 14, 2025, the Interim Policy on Reciprocal Procurement limits access to federal procurements to suppliers from Canada and from our reliable trading partners that provide reciprocal access to suppliers from Canada through trade agreements (see Contracting Policy Notice 2025-5: Reciprocity in Federal Procurement and Amendments to the Canadian International Trade Tribunal Procurement Inquiry Regulations).

The Buy Canadian Procurement Policy Framework applies to all departments and agencies as listed in Schedules I, I.1 and II of the Financial Administration Act, R.S.C., 1985, c. F-11. Crown corporations and their subsidiaries, as federal entities, are encouraged to align with this framework and its related instruments in a manner consistent with their mandates.

Amendments to the Canadian International Trade Tribunal Procurement Inquiry Regulations

Complementary amendments have also been made to the Canadian International Trade Tribunal Procurement Inquiry Regulations, effective December 15, 2025, to facilitate the implementation of the Buy Canadian Policy. The amendments modify the scope of the matters that the Canadian International Trade Tribunal (CITT) is able to review with respect to federal procurement processes.

Specifically, after the amendments come into force, the CITT shall not examine any measures in the procurement process that:

• restrict participation to, or favour, Canadian suppliers
• require or favour the use of Canadian goods, services, materials or subcontractors
• require bids to provide benefits to Canada or include a minimum Canadian value added, or favour bids based on their benefits to Canada or their Canadian value added
• restrict participation to small businesses

The amendments and their explanation are outlined in the Canada Gazette.

Amendments to the Directive on the Management of Procurement

The Directive on the Management of Procurement was also amended to reflect the new Buy Canadian requirements in the roles and responsibilities of business owners and contracting authorities:

• Business owners are required to ensure that intended outcomes of the procurement are aligned with government priorities (section 4.2.7), such as those articulated in the Speech from the Throne, the budget process and mandate letters.
• Business owners, where appropriate, must consider opportunities to support Canadian economic interests (section 4.2.7.5), such as the Buy Canadian Procurement Policy Framework.
• Contracting authorities are now required to provide advice and recommend options to business owners on procurement strategies, including how to leverage procurement to support Canadian economic interests (section 4.3.4.15), such as the Buy Canadian Procurement Policy Framework.

The Buy Canadian Procurement Policy Framework is now reflected in Appendix D.7, which requires that:

• PSPC develop, maintain and implement the Buy Canadian Procurement Policy Framework, including issuing associated policy instruments, programs, guidance materials, tools and training, as appropriate, to ensure consistent interpretation and application
• senior designated officials implement the Buy Canadian Procurement Policy Framework in their organization and ensure that records regarding its application are accurate and complete
• contracting authorities adhere to the requirements set out in the Buy Canadian Procurement Policy Framework in procurements, document decisions regarding its application, and respond to PSPC requests for data concerning its application

Other considerations

Departments are advised to update their departmental procurement management framework to reflect these changes and are encouraged to engage their internal audit function to support compliance. As a reminder, departments are required to:

• justify and document all decisions taken with respect to a procurement, including decisions that affect prioritization of Canadian suppliers, goods, services, materials, or small businesses. Contracting authorities must keep and maintain accurate and complete procurement documentation in the procurement file.
• ensure that proper controls, oversight, and processes are in place to support compliance.

Contracting authorities are also advised that they will be expected to enhance their understanding of the availability and capability of Canadian suppliers in their market analysis and industry engagement activities.

Additional tools and guidance to facilitate implementation of the Buy Canadian Procurement Policy Framework and its policies will be developed and communicated to departments by PSPC and the Treasury Board of Canada Secretariat (TBS) as aligned with their mandates.

Enquiries

Enquiries about the Buy Canadian Procurement Policy Framework and related policies can be directed to the organizational unit in your department responsible for this subject matter. For interpretation of the Buy Canadian Procurement Policy Framework, contact spac.paachetezcanadien-apbuycanadian.pspc@tpsgc-pwgsc.gc.ca.

Questions about this policy notice or the directive should be directed to TBS Public Enquiries at questions@tbs-sct.gc.ca.

Questions about the amendments to the Canadian International Trade Tribunal Procurement Inquiry Regulations should be directed to the Department of Finance Canada at fin.simaconsult-lmsiconsult.fin@fin.gc.ca.