ARTICLE
10 March 2026

Public Procurement 2025 Year In Review

MT
McCarthy Tétrault LLP

Contributor

McCarthy Tétrault LLP provides a broad range of legal services, advising on large and complex assignments for Canadian and international interests. The firm has substantial presence in Canada’s major commercial centres and in New York City, US and London, UK.
From significant case law to major policy reforms and expanded integrity oversight, 2025 brought meaningful changes to how public entities buy and how suppliers compete.
Canada Government, Public Sector
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What critical developments shaped public procurement in 2025?

From significant case law to major policy reforms and expanded integrity oversight, 2025 brought meaningful changes to how public entities buy and how suppliers compete. Public Procurement 2025 Year in Review distills these developments into clear, actionable insights for organizations operating in Canada's procurement ecosystem.

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A Preview of the Topics We Explore

Our Public Procurement 2025 Year in Review chapters cover developments across Canada.

Key Developments at the Federal Level

How did federal procurement rules and oversight evolve in 2025?

In 2025, federal procurement entered a period of accelerated change. Key themes included the rollout of the Buy Canadian Policy, a major overhaul of defence procurement through the new Defence Investment Agency, the increasing use of AI in procurement governance, and important decisions from the Canadian International Trade Tribunal clarifying the duties of both procuring entities and suppliers.

Why it matters: Federal purchasing now operates within a tighter, more strategic, and more accountability‑driven framework. Understanding how domestic‑content rules, national security considerations, and emerging verification obligations interact will be essential for suppliers and public entities navigating major federal opportunities in 2026.

Key Developments in Ontario

How are Ontario's procurement priorities shifting in response to economic and policy pressures?

Ontario's 2025 reforms brought sweeping changes: new restrictions on U.S. suppliers, major legislative moves to accelerate infrastructure and critical‑minerals projects, modernization efforts through Supply Ontario, and a strengthened provincial framework favouring domestic sourcing. Jurisprudence also clarified when procurement decisions can (and cannot) be challenged in court.

Why it matters: Ontario continues to evolve into one of Canada's most interventionist procurement jurisdictions. Purchasers must adapt their processes to stricter policy direction, while suppliers — especially cross‑border companies — must reassess eligibility and risk.

Key Developments in Quebec

What did Quebec's courts and integrity authorities signal for public purchasers in 2025?

Quebec saw a series of influential Court of Appeal and Superior Court decisions addressing the duty to inform, unilateral termination, bidder qualification, and the scope of a public body's good‑faith obligations. The Autorité des marchés publics continued to play a defining role, issuing decisions that clarified how integrity standards are assessed and when corrective measures must be considered.

Why it matters: Quebec continues to lead in procurement jurisprudence, with decisions that set national expectations for risk allocation, bidder responsibilities, and the conduct required of public authorities. Suppliers must understand how tightly Quebec enforces compliance requirements, and public entities must ensure their processes are well‑documented and legally defensible.

Key Developments in Western Canada

What were the most influential developments across Western Canada's procurement landscape in 2025?

The Western provinces experienced significant movement: Alberta's high‑profile Alberta Health Services procurement investigations exposed systemic governance challenges; British Columbia advanced a centralized, fast‑track model for major infrastructure projects; Manitoba continued active enforcement against bid‑rigging in public contracts; and Saskatchewan's debate over foreign‑sourced digital systems reignited conversations about local supplier priorities.

Why it matters: Western Canada remains a dynamic region for infrastructure, health procurement, and competition law enforcement. Public bodies and suppliers must understand each provinces' distinctive approach to risk allocation, transparency, and procurement oversight to compete and operate effectively.

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