1. Effective date
- 1.1. These Guidelines take effect on April 1, 2018.
- 1.2. These Guidelines replace the existing documentation, Guidance Document: Proactive Disclosure of Grants and Contributions over $25,000, and Q’s and A’s For Internal Use Only – Proactive Disclosure of Grants and Contributions over $25,000.
- 2.1. To provide guidelines and guidance to managers and functional specialists on the identification, collection, and publication of Grants and Contributions (Gs and Cs) award information that is to be reported.
- 3.1. These Guidelines apply to departments and agencies that are subject to the Policy and Directive on Transfer payments, or are listed in Schedules I, I.1 and II of the Financial Administration Act.
- 3.2. These guidelines support the commitment made by the Secretary of the Treasury Board, stating that “beginning in the spring of 2006, the government will make information on Grants and Contributions available through proactive disclosure, initially for those above $25,000.”
- 3.3. Program Terms and Conditions (Ts and Cs) that provide exemptions to the reporting of awards for those programs that have been approved before the effective date of these Guidelines remain in effect until either their expiry date, or the date for approval for their continuation or amendment.
- 3.4. A three-wave approach to the updated disclosure requirements of Gs and Cs information is being adopted to permit departments and agencies to make the necessary adjustments to business processes. Information on these waves can be found in Appendix H.
- 4.1. On October 21, 2005, the Government of Canada announced its commitment to proactively disclose the awarding of Gs and Cs over $25,000 as part of its Management Improvement Agenda. Those new requirements represented a continuation of the phased introduction of proactive disclosure requirements that started with travel and hospitality expenses, contracts for goods and services, and position reclassification information.
- 4.2. In June of 2016, the Treasury Board of Canada Secretariat (TBS), as part of the Open Government Action Plan, submitted a commitment to increase the transparency and usefulness of Grants and Contributions data. The initiative was spearheaded by a TBS-led interdepartmental committee of 32 participating departments, agencies, and crown corporations, and entitled the Committee on Grants and Contributions Award Reporting.
5.1. General guidelines
- 5.1.1. All Gs and Cs awarded are to be reported, except those exempt by provisions set out in the Access to Information Act and the Privacy Act, or otherwise exempt as listed in these Guidelines under Appendix A – Exemptions.
- 5.1.2. The total signed amount of the Grant or Contribution awarded is to be reported, when the agreement has been signed. More specifically, it is the amount of the Grant or Contribution ultimately authorized by the responsible Minister, Deputy Head, or responsible delegated authority that needs to be reported.
- 5.1.3. Reporting frequency may take place at the discretion of the department. However, as a minimum, departments must report (except in instances highlighted in 5.1.4), within 60 days of the end of the reporting quarter, as indicated in the table below:
Reporting period Final deadline for posting Q1: April 01 – June 30 August 31 Q2: July 01 – September 30 November 30 Q3: October 01 – December 31 February 28 Q4: January 01 – March 31 May 31
- 5.1.4. In instances of Ministerial Announcements, Proprietary Information, or other valid causes for delay (determined at the discretion of the Deputy Head or delegated authority), departments may delay reporting on these agreements, provided they are disclosed within the same fiscal year, or within one (1) fiscal quarter if the report falls at the end of a fiscal year.
5.2. Identification of Grants and Contributions to be reported
- 5.2.1. Departments should report all Grant and Contribution awards and amendments, except where exceptions have been granted, as highlighted in Appendix A.
- 5.2.2. When a series of amendments to an award exists, they may be disclosed as one report, provided they occur in the same reporting period.
- 5.2.3. When a Grant or Contribution is awarded, and subsequently terminated, the report should be treated as an amendment, and reported as such.
- 5.2.4. When information is classified, the non-sensitive information is to be reported under the award reporting exercise; in these cases, departments may batch the information to protect the sensitive information. Additional information on batch reporting can be viewed in Appendix C.
5.3. Collection of Grant and Contribution data elements
- 5.3.1. The data elements as described in Appendix B were developed by the Committee on Grants and Contributions Award Reporting, in consultation with key external and internal stakeholders, to enable departments to provide consistent, useful, and useable information to the public. Departments are encouraged to follow the recommended approach for each data element and move towards the recommended reporting standard over time.
5.4. Publication of Grants and Contributions awards
- 5.4.1. Using templates provided by the Treasury Board of Canada Secretariat, departments and agencies are to report their respective Gs and Cs information on the open.canada.ca data portal.
- 184.108.40.206. Departments will begin reporting on open.canada.ca on the effective date of these guidelines.
- 5.4.2. When another department issues a Grant or Contribution on a department’s behalf, the department issuing the funds to the recipient should report on the award, noting in the “Additional Information” reporting field that another department partook.
- 5.4.3. When more than one department or agency is funding a proponent for a shared initiative, both departments should report the award in line with the amount of the Grant or Contribution awarded by their department. When this occurs, departments should communicate to ensure consistency of information, and include the name(s) of the other department(s) in the “Additional Information” field of the report.
- 5.4.4. When the posting deadlines fall on a weekend or statutory holiday, departments must post information by the first business days following the weekend or holiday in question.
- 5.4.5. A Grant and Contribution award or amendment not reported in the reporting period in which it was awarded may be indicated in the subsequent reporting period, or as soon as practical. Any belated reporting must be identified as such in the “Additional Information” section of the report.
- 5.4.6. Posted information may be modified when a material error (defined in Appendix D) was made in the data originally reported. Any modified information should be clearly indicated within the original report’s “Additional Information” field.
5.5. Monitoring of award reporting
- 5.5.1. In accordance with the Treasury Board Policy on Transfer Payments, departments and agencies are responsible for ensuring that the Gs and Cs authority (the Minister) is acting and seen to be acting within the letter and the spirit of the Treasury Board Policy on Transfer Payments. The department runs the risk of non-compliance if it does not ensure that Grant and Contribution award and amendment information is accurate, up-to-date, and posted in accordance with the Policy and Directive on Transfer Payments. The department’s deputy head is responsible for ensuring that data reported is appropriately validated, complete, and reported in a timely manner. It is a best practice for departments to clearly indicate any limitations associated with their reported data.
- 5.5.2. TBS will, as appropriate, engage in regular monitoring activities on departmental data for Gs and Cs Award Reporting, ensuring compliance with standards (as applicable). When a department does not have awards to be disclosed, departments will populate a different section of the reporting template, and the information will be placed on the open.canada.ca portal.
6.1. Relevant legislation
6.2. Treasury Board policies
6.3. Treasury Board standards
6.4. Additional references
- 6.4.1. Third Biennial Plan to the Open Government Partnership
- 6.4.2. TBS Committee on Grants & Contributions Award Reporting
- 7.1. For questions on this policy instrument, please contact firstname.lastname@example.org