Canada 2026: All Canada, All The Time

Significant shifts have occurred over the past year in Canadian procurement at all levels of government. While our outlook for 2025 was shaped largely by the United States' America First Trade Policy, our outlook for 2026 reflects a clear pivot: it is now All Canada, All the Time.

2025: America First Policy

At the start of 2025, significant shifts in U.S. trade policy under the new U.S. administration occurred. Executive Orders, such as the America First Trade Policy, prioritized U.S. domestic workers, farmers, manufacturers, and businesses; with the use of tariffs signalling a change in how the U.S. would approach its trading relationships.

In response, federal, provincial and municipal governments collaboratively worked to reduce internal trade barriers and to promote internal trade, including substantive modifications to their purchasing processes to protect and support Canadian industry and facilitate opportunities for Canadian businesses.

2026: All Canada, All the Time

Below, we highlight some of the major strategic procurement policy developments for the federal government that will continue to evolve and impact government procurement for 2026.

Canada/EU Strategic New Partnership and Defining "Canadian Enough"

June:

• Canada signed the Security and Defence Partnership with the European Union. For more information, see our bulletin, United for Security and Defence: Canada and the EU Join Forces in a Strategic New Partnership.
• Amendments to the Canadian International Trade Tribunal Procurement Inquiry Regulations (CITT Regulations) implemented additional conditions for launching an inquiry, limits on compensation awards, and new definitions for "procurement process" and "potential suppliers". For more information, see our bulletin, More Than Meets The Eye: Recent Canadian International Trade Tribunal Procurement Inquiry Regulations Amendments Go Beyond Responding to Restrictive Trade Practices.

July:

• The federal government released Contracting Policy Notice 2025-5 (Reciprocity in Federal Procurement and Amendments to the Canadian International Trade Tribunal Procurement Inquiry Regulations), and the Interim Policy on Reciprocal Procurement. The policy provided definitions for "Canadian supplier" and "supplier of an applicable trading partner," beginning to define what constitutes "Canadian enough".

Defence and the Defence Investment Agency

June:

• Prime Minister Mark Carney appointed the Honourable Stephen Fuhr as Secretary of State (Defence Procurement).
• Legislation was tabled in the House of Commons to move the Canadian Coast Guard under the purview of the Minister of National Defence.
• Information surrounding the creation of a Defence Investment Agency appears.
• For more information, see our bulletin, Something Old, Something New, and Uncharted Waters – the Defence Procurement Agency, a New Secretary of State (Defence Procurement), and Moving the Canadian Coast Guard under the Department of National Defence.

September:

• The Canadian Coast Guard transitioned to the Department of National Defence.

October:

• The Defence Investment Agency (DIA) is created, led by Chief Executive Officer Doug Guzman, and overseen by the Honourable Stephen Fuhr.
• For more information, see our bulletin, FASTER, But to Where? The Defence Investment Agency's Murky Mission.
  January (2026)
• Canada releases its most profound Defence strategy update in decades. If implemented as described, Canadian defence procurement will undergo a significant shift in how, and from whom, Canada will acquire its defence supplies.
• For more information, see our bulletin, If You Build It, They Will Come -Canada's Defence Industrial Strategy and the Build-Partner-Buy Approach.

The Buy Canadian Framework

December:

• The Government of Canada released the much anticipated Buy Canadian Procurement Policy Framework (Buy Canadian Framework). Comprised of four main policy instruments, the Buy Canadian Framework provide the overarching structure for the shift towards prioritizing Canadian suppliers, content, and goods in federal procurements.
• The government released further amendments to the CITT Regulations. These new amendments remove the ability of the CITT to investigate a portion of a complaint relating to measures in a procurement that require or prefer Canadian suppliers, goods, or services

So, What's Next for 2026?

The roll out of the Defence Industrial Strategy and the implementation of the Buy Canadian Framework (those elements that are to be finalized in 2026) will be front of mind for federal procurement in 2026.

Outside of Canadian policy developments, there are also notable U.S. related milestones to watch out for in 2026, including the scheduled review of CUSMA, which will unfold against the backdrop of continuing developments in the U.S.-Canada trade relationship, making it critical for suppliers to monitor developments closely and position themselves strategically within the new and evolving procurement landscape (including whether Canada will sign the CUSMA procurement chapter or not).