Writing an Indigenous participation plan that holds up
Once a contract is awarded, the plan in your bid becomes an obligation that is tracked and enforced. Federal rules on what counts toward the target are getting stricter.
Photo by Peter Robbins on Unsplash
Most firms treat an Indigenous participation plan (IPP) as one more scored section of a federal bid. It earns points, someone signs it off, and attention moves to price. That habit misses what the plan becomes once the contract is signed.
Indigenous Services Canada (ISC) says federal departments may ask bidders to submit an IPP with their proposals. The same page is direct about what follows. On award, IPPs become contractual obligations that are tracked, reported on, and legally enforceable. A commitment written to win points is a commitment you will be asked to prove.
Our earlier post on Indigenous participation in public bids covers scoring at bid stage. This one covers delivery after award.
What an IPP commits you to
According to ISC, an IPP may include a bidder’s commitments to Indigenous subcontracting, employment, and training. A plan can support a limited bidding process. It can stand on its own where limiting bidding is not practical, or it can meet procurement obligations under a modern treaty.
Public Services and Procurement Canada (PSPC) says in its 2026 to 2027 Departmental Plan that it will keep implementing the mandatory minimum 5% Indigenous procurement target. Its tools include Limited to Indigenous Offers, IPPs, and unbundling opportunities. Your plan therefore feeds a number the department has to report.
Participation is rising. PSPC reports that Indigenous suppliers took part in 7% of its procurement processes in 2022-23, 10% in 2023-24, and 16% in 2024-25. Its target is at least 11% by March 31, 2027. Across government, ISC reports that more than $1.24 billion in contracts went to Indigenous businesses in 2023-24, or 6.1% of eligible contracts. About 40% of that went through set-asides under the Procurement Strategy for Indigenous Business (PSIB).
The rules on what counts are getting stricter
In March 2026 the Office of the Procurement Ombud published a review of contracts awarded to Indigenous businesses. It recommended that the amounts departments report toward the 5% target be updated right away. Those amounts should reflect only work that was paid for and clearly documented as carried out by Indigenous businesses. The Ombud’s announcement also pointed to weak oversight and audit practices, and to reporting that overstates the impact of the target.
ISC is reworking its approach. The review sets out ISC’s timeline. Engagement with PSPC, the Treasury Board of Canada Secretariat, and federal departments on the policy changes is scheduled for fall 2026, followed by Cabinet approval in winter. ISC expects to finalize the new policy and strategy in winter 2026 and to have them fully in place by April 1, 2027.
The final rules are not yet public, but the direction is clear enough to plan around. Departments will need to show paid, documented work, and they will ask contractors for the evidence.
A commitment written to win points is a commitment you will be asked to prove.
How to write an Indigenous participation plan that holds up
A plan holds up when each commitment can be checked against something outside the bid. Three habits make that possible.
State commitments in dollars and hours. A promise of “meaningful participation” cannot be measured. A subcontract value, a number of employment hours, or a count of training placements can. Tie each figure to a phase of the work so you can report progress as it happens.
Name businesses you can verify. For the 5% target, ISC’s definition of an Indigenous business includes businesses registered in the Indigenous Business Directory and businesses on a modern treaty beneficiary business list. Check every named subcontractor against one of these sources before you submit. ISC reviews directory listings about every two years and removes businesses that no longer meet the criteria. Check again before work starts.
Plan for genuine work. The Ombud’s review notes that post-award audits check whether businesses still meet the 51% Indigenous ownership and control criterion, along with the 33% Indigenous content criterion. A subcontractor that passes work straight through to others puts both that business and your plan at risk. Commit only to scopes the named business can perform with its own people and equipment. The business decides what it can take on. Your plan should record that conversation, not assume its outcome.
Your records will carry the weight
The weak point in most plans is not the commitment but the evidence. ISC’s report on the 5% target for 2023-24 records PSPC’s statement that its financial management tools cannot yet reliably and consistently track and report on subcontracting. If the department cannot produce the record, it will ask you for it.
Set up your tracking when the contract starts. For each commitment, keep:
- the signed subcontract and its value
- invoices and proof of payment to each Indigenous business
- hours worked by Indigenous employees, by reporting period
- training records, with dates and completions
Report against the plan at each reporting period, not only at closeout. Where you fall short, write down why and what you will do next. A shortfall with a documented reason and a recovery plan gets a different response than a gap found at audit. Ask your lawyer to review how the IPP clauses appear in the contract, including any remedies for shortfalls.
Modern treaties, defence, and BC work
Some contracts carry more than one set of obligations. The CanadaBuys Buyer’s Guide notes that Comprehensive Land Claims Agreements and the PSIB are separate frameworks, and some procurements may be subject to both. Read the solicitation to see which applies, and write the plan to meet each one.
Defence is worth watching. In May 2026, National Defence told the House Standing Committee on National Defence that the Defence Industrial Strategy seeks to strengthen Indigenous participation in defence supply chains, infrastructure, and procurement. That work builds on the 5% target. Firms in that supply chain should be ready for participation commitments.
In British Columbia, ISC’s figures for 2023-24 put the province at 2.9% of federal contract awards to Indigenous businesses, or $29.22 million. Provincial work has its own rules. The Province’s Indigenous Procurement Initiative is co-led by the Ministry of Citizens’ Services and the Ministry of Indigenous Relations and Reconciliation. Under the BC Procurement Plan 2024, buyers apply the Social Impact Purchasing Guidelines to services under $75,000. For all other purchases, they consider adding social, Indigenous, environmental, or economic criteria. The same record-keeping works under both federal and provincial rules.
Start with the plan you already have
Take the IPP from your most recent federal contract. For each commitment, find the record that proves it today: the subcontract, the payment, the hours. Where a record is missing, start keeping it now, before ISC’s new policy takes effect in April 2027.
For bids still in progress, our post on reading the evaluation grid like an evaluator covers the scoring side. Our Public Sector & Bids practice works with firms on plans they can deliver.
Sources
- “Learn how federal Indigenous procurement works”, Indigenous Services Canada. https://www.sac-isc.gc.ca/eng/1696513417823/1696513480139
- “Public Services and Procurement Canada’s 2026 to 2027 Departmental Plan”, Public Services and Procurement Canada. https://www.canada.ca/en/public-services-procurement/corporate/transparency/departmental-plan/2026-2027-plan.html
- “Facts about federal Indigenous procurement policies and practices”, Indigenous Services Canada. https://www.sac-isc.gc.ca/eng/1746637262900/1746637283564
- “Procurement Practice Review of Contracts Awarded to Indigenous Businesses”, Office of the Procurement Ombud. https://opo-boa.gc.ca/praapp-prorev/2026/epa-ppr-03-2026-eng.html
- “Procurement Ombud Calls for Stronger Indigenous Procurement Policy to Advance Economic Reconciliation”, Office of the Procurement Ombud, Government of Canada. https://www.canada.ca/en/procurement-ombudsman/news/2026/03/procurement-ombud-calls-for-stronger-indigenous-procurement-policy-to-advance-economic-reconciliation.html
- “Mandatory minimum 5% Indigenous procurement target”, Indigenous Services Canada. https://www.sac-isc.gc.ca/eng/1691786841904/1691786863431
- “Indigenous Services Canada’s Report on the Mandatory Minimum 5% Target - Fiscal Year 2023-24”, Indigenous Services Canada. https://www.sac-isc.gc.ca/eng/1761738280117/1761738313724
- “Indigenous considerations”, Buyer’s Guide, CanadaBuys, Government of Canada. https://canadabuys.canada.ca/en/buyer-s-portal/buyer-s-guide/plan/socioeconomic-considerations/indigenous-considerations
- “House Standing Committee on National Defence (NDDN): Defence Industrial Strategy - May 6, 2026”, National Defence, Government of Canada. https://www.canada.ca/en/department-national-defence/corporate/reports-publications/proactive-disclosure/2026/nddn-defence-industrial-strategy.html
- “Indigenous procurement”, Province of British Columbia. https://www2.gov.bc.ca/gov/content/bc-procurement-resources/procurement-strategies-and-initiatives/indigenous-procurement
- “BC Procurement Plan 2024”, Province of British Columbia. https://www2.gov.bc.ca/gov/content/bc-procurement-resources/procurement-strategies-and-initiatives/bc-procurement-plan-2024
