This article will continue to be updated with new information.
On March 30, 2026, the Ontario government released a provincial and municipal procurement directive under the Buy Ontario Act, 2025 that mandates prioritization of Ontario and Canadian goods and services in public procurements. In force since April 13, 2026, these requirements apply to new procurements that have not been issued as of that date.
The “Buy Ontario Procurement Directive” sets out the requirements public-sector organizations must follow to prioritize Ontario and Canadian goods and services in procurement. Its strategic categories are fleet vehicles and capital infrastructure.
As part of the new Directive, “construction bidders” are now required to submit a Domestic Supply Chain Plan (DSCP) to verify if the goods and services they plan to use are from Ontario, Canada, or elsewhere. The Directive sets out how DSCPs may be used to help evaluate a bid. To learn more about the DSCPs and to read the new Directive, visit the Ontario government page. For more information and resources on Buy Ontario, read this article on the OAA Website.
As public-sector clients/procurement teams and the construction industry assess the impacts of the Buy Ontario Directive, OAA practices and their consultants should keep lines of communications open. Members may need to meet with their legal counsel to assess impacts on professional services contracts currently in place.
Considerations for Practices under the Buy Ontario Directive
Practices and their consultants should familiarize themselves with the Buy Ontario Procurement Directive as public-sector clients may start requesting additional support when preparing and reviewing RFPs, which may also include request for substitutions.
Anticipate construction cost impact and delays. Members should help clients understand that supply-chain demands for Canadian-made goods may drive construction cost and create construction project delays.
Consider the impact on contracts for professional services. Review your contracts as this legislation change may affect the scope of work related to construction document production, tendering, and office-related construction services.
Note the additional procurement-linked obligations placed on consultant teams. Public-sector clients may begin asking practices to structure specifications, evaluation criteria, or procurement‑related documents in ways that align with the Buy Ontario Procurement Directive. Even though OAA members are not the buyer, the practices' work often forms the backbone of clients’ procurement packages.
Prepare for additional review/research time around material and product selection and requests for substitutions. As public-sector clients adopt domestic‑preference requirements, OAA members and their design teams may be asked to justify why certain materials, systems, or manufacturers are specified. It is also likely there may be an increase in substitution requests. Navigating the expectations may require additional documentation and careful communication between client/contractors and other key stakeholders, particularly to ensure code-compliance is met.
Be aware of additional administrative or documentation requests. OAA members should be mindful of requests to provide documentation, attestations, or compliance confirmations related to Buy Ontario Directive. These examples may fall outside what is deemed usual and customary scope of architectural services and could create unintended liability if not clearly defined, limited, and contractually scoped.
OAA and Pro-Demnity Resources
Practice Advisory article, March 2026: “Buy Ontario Act: Initiatives to promote Economic Development”
Practice Tip PT.15 Consulting Contracts, Managing Changes, and Scope Creep
“Dealing with Substitutions to Your Design” (Pro-Demnity) December 31, 2016
Third-Party Resources
Various groups are offering resources that explore the Buy Ontario Act and the new Procurement Directive under it. These are shared below for informational purposes and may not necessarily reflect the views of the OAA or its governing Council.
Guides
Supply Ontario features a Buy Ontario page that provides detailed information and guides for public sector buyers on the capital infrastructure policy and fleet vehicle policy along with FAQs and webinar sessions. Supply Ontario is a government agency whose mandate is to strengthen supply chain management and procurement across the public sector, ensuring that Ontario ministries, provincial agencies, hospitals, school boards, and children's aid societies have access to high-quality, timely, reliable products at the best value.
Events
“CDAO Procurement Day – Recorded Replay” (CDAO) – the panel on Buy Ontario Procurement Policy begins at 1:05
Articles
“Municipal Buy Ontario: Key impacts for municipal procurement” (Gowling WLG) May 21, 2026
“Decoding the 2026 Buy Ontario Procurement Directive” (Dentons) May 6, 2026
“The First Buy Ontario Act Directives Now in Force” (McCarthy Tetrault) April 27, 2026
“Buy Ontario Procurement Directive: key requirements for public sector procurements” (Torys LLP) April 21, 2026
“Ontario’s New Buy Ontario Procurement Rules” (WeirFoulds LLP) April 16, 2026
“A Guide to the Buy Ontario Procurement Directives” (Blake, Cassels & Graydon) April 9, 2026