Public Procurement 2025 Year in Review

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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Public Procurement 2025 Year in Review

Clear, practical insights to help purchasers and suppliers navigate the evolving landscape of Canadian public procurement — and prepare for what’s ahead.

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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.

About McCarthy Tétrault’s Procurement Group

Our Procurement Group consists of more than 25 lawyers nationally. Our principal areas of practice include Project Development, Technology, Energy, Infrastructure, International Trade & Investment, Tax, and Public Law. Our procurement lawyers provide end-to-end legal support for both buyers and sellers, ensuring compliance, mitigating risks, and securing cost savings. We assist private sector companies and government entities at all levels in drafting RFPs, negotiating contracts, and handling bid disputes. Whether you’re selling to or purchasing from Canadian markets, we help you navigate procurement agreements, optimize contracts, and resolve challenges efficiently.

Procurement is evolving rapidly, with increasing regulatory complexity, heightened competition, and greater scrutiny from shareholders, management, and the media. As governing bodies continually change procurement rules, businesses must navigate these changes strategically to minimize risks and maximize opportunities.

About McCarthy Tétrault

McCarthy Tétrault LLP provides a broad range of legal services, providing strategic and industry-focused advice and solutions for Canadian and international interests. The Firm has a substantial presence in all of Canada’s major commercial centres as well as in New York and London.

Built on an integrated approach to the practice of law and delivery of innovative client services, the Firm brings its legal talent, industry insight and practice experience to help clients achieve the results that are important to them.

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For further information on McCarthy Tétrault or any of the above, please contact media@mccarthy.ca