More than a third of federal ‘nothing to report’ contract filings contradict the departments’ own disclosures

Federal organizations have filed 98 declarations stating they had no contracts to disclose for a given quarter, and in 37 of those cases the same organization published contract records for that exact quarter in the government’s main contracting file, an analysis of Treasury Board’s proactive publication data shows.

The 37 contradicted quarters account for 3,108 individual contract records with a combined reported value of about $1.36 billion. The declarations and the contract records sit side by side, uncorrected, in the same published dataset.

Federal entities are required to file what the Treasury Board of Canada Secretariat calls a nil report when a quarter passes without contracting activity. The department’s Guide to the Proactive Publication of Contracts states that “departments are to provide a nil report for any quarter or calendar year in which no contract or amendment is reported.” Those filings are published as a separate file, Proactive Publication of Contracts Nothing to Report, within the same dataset that carries the main record of contracts over $10,000.

The largest single discrepancy involves Fisheries and Oceans Canada. The department filed a nil report for the fourth quarter of 2021-22, the period covering Jan. 1 to March 31, 2022. The main contracts file contains 2,347 records that Fisheries and Oceans reported for that same quarter, with a combined reported value of $1.31 billion.

Those records are not a marginal or ambiguous set. Of the 2,347, some 2,234 carry a contract date falling inside the January-to-March window. The department’s own internal reference numbers for the records run in sequence from C-2021-2022-Q4-00001, a $19,090.58 contract with Ratio Architecture dated March 31, 2022, through the balance of the filing. The numbering scheme encodes the reporting period, meaning the department assigned each of those records to the fourth quarter at the time of filing.

The quarter was not unusual for the department. Fisheries and Oceans reported 1,742 contract records in the preceding quarter and 1,681 in the quarter that followed, according to the same file.

The $1.31-billion figure should be read with care. It includes 247 amendment records worth a reported $704.5 million, and amendment rows in the dataset restate a contract’s revised total rather than the incremental increase, so the sum is not a measure of new spending in the quarter. The remaining 2,094 records are new contracts with a reported combined value of $593.1 million. The largest entries are shipbuilding awards, including a $162.8-million contract with Vancouver Shipyards Co. Ltd. dated March 10, 2022, and a $129.4-million contract with Ontario Shipyards dated Feb. 25, 2022.

Thirteen federal organizations appear among the 37 contradicted quarters. The Natural Sciences and Engineering Research Council of Canada accounts for 10 of them and the Social Sciences and Humanities Research Council of Canada for nine, all falling between 2017-18 and 2019-20. The Farm Products Council of Canada accounts for seven, spread across eight years. The Canada Energy Regulator, the Canadian Grain Commission, the Parole Board of Canada, Polar Knowledge Canada, Crown-Indigenous Relations and Northern Affairs Canada, Pacific Economic Development Canada, the Patented Medicine Prices Review Board and the Law Commission of Canada each account for one.

Six of the 37 fall in quarters beginning on or after June 30, 2023, the date an updated version of the guide took effect. Contracting Policy Notice 2023-3, issued by then assistant comptroller general Samantha Tattersall on June 26, 2023, described the update as supporting “the new requirement for Senior Designated Officials for the management of procurement to establish risk-based internal controls to monitor the proactive publication of contracts.”

The most recent instances postdate that requirement. The Office of the Commissioner for Federal Judicial Affairs Canada filed a nil report for the first quarter of 2025-26 while also reporting 12 contracts worth $700,351 for the same period, including a $212,720 contract dated May 1, 2025. The Farm Products Council filed a nil report for the third quarter of 2025-26 while reporting a single $16,922.06 subscription contract with Urner Barry Publications Inc. dated Dec. 10, 2025.

There are explanations that would not involve any misstatement of contracting activity. An organization that genuinely had nothing to report at the filing deadline and later submitted contracts for that quarter would produce this pattern, and nothing in the published data indicates the nil filings were withdrawn or amended once the contracts were entered. Treasury Board attaches an explicit caveat to the dataset, warning that the information is unaudited and that “no warranty or other legal assurance as to the accuracy or completeness of this information is stated or can be implied.”

What the data does not show is any mechanism that reconciles the two files. The nil declarations remain published against quarters the same organizations have since populated with contracts.

The finding is consistent with earlier official criticism of the disclosure regime. In its 2024 Procurement Practice Review of ArriveCAN, the Office of the Procurement Ombud reported finding practices for the proactive publication of contract information that were “inconsistent with government policy” and that threatened the fairness, openness and transparency of federal procurement.

This story is developing. The analysis rests on the published data as it stood on Sept. 7, 2026, and the dataset is updated quarterly, so the counts above may change as organizations revise their filings.

Sourcing note

Every figure in this piece was derived from the public records listed below. The two contract files were queried through the CKAN datastore API on open.canada.ca on Sept. 7, 2026.

1. Proactive Publication – Contracts, Treasury Board of Canada Secretariat, dataset record d8f85d91-7dec-4fd1-8055-483b77225d8b, record modified Sept. 6, 2026.
2. Proactive Publication – Contracts Nothing to Report (nil reports), resource fa4ff6c4-e9af-4491-9d4e-2b468e415a68. Full contents retrieved: 98 records. Earliest period 2016-2017-Q3, latest 2025-2026-Q3.
3. Contracts over $10,000, resource fac950c0-00d5-4ec1-a4d3-9cbebf98a305, 1,173,325 records. Each of the 98 nil declarations was matched against this file on the pair of owner_org and reporting_period. 37 returned one or more contract records.
4. Guide to the Proactive Publication of Contracts, Treasury Board of Canada Secretariat. Source of the nil-report requirement.
5. Contracting Policy Notice 2023-3, June 26, 2023. Source of the internal-controls requirement and the June 30, 2023 effective date.
6. Procurement Practice Review of ArriveCAN, Office of the Procurement Ombud, 2024.

The 37 contradicted organization-quarters