$500 idea · Updated yesterday · Canada · Edition 002
Ottawa can hand one person $40,000 of work without soliciting a single bid.
Section 6(b)(iv) of the Government Contracts Regulations (SOR/87-402) lets a contracting authority enter into a contract without soliciting bids where the estimated expenditure does not exceed $40,000 for “any other contract to which these Regulations apply” — which is to say, services. For goods the figure is $25,000. There is no competition to lose, because there is no competition.
The starting capital this week is CAD $712.15 (USD $500 at 1.4243, Bank of Canada, 1 October 2026) and the target is CAD $7,121.50 a month (USD $5,000). Sixty dollars of the capital is a business-name registration. None of the rest buys information, because the state is under a statutory duty to publish the only market research that matters: what it bought, from whom, for how much.
Who is on the other side of the trade: a contracting officer with a requirement, a ceiling of $40,000 and no obligation to run a process. The Ombud’s September 2025 review, signed by Procurement Ombud Alexander Jeglic, found that in 6 of 17 professional-services files examined, none of the people named in the winning bid did any of the work — and in 7 of 17, the substitutes were never assessed against the qualifications that won the contract. Ottawa is not buying firms. It is buying a named individual against a written requirement, and then not checking.
The evidence
6 findingsThe threshold under which no bid is required at all
“Notwithstanding section 5, a contracting authority may enter into a contract without soliciting bids where … (b) the estimated expenditure does not exceed (i) in the case of a goods contract, $25,000 … (iv) in the case of any other contract to which these Regulations apply, $40,000.”
The other three doors in section 6 are narrow and discretionary — pressing emergency, public interest, and only one person capable of performing the contract. Paragraph (b) is the only one that opens on a number rather than on a judgement, which is why it is the one a newcomer can plan against. Government Contracts Regulations, s. 6
Forty suppliers invited. One bid received
Of the May 2022 competitive contract worth $25.3 million awarded to GC Strategies Inc. under the TBIPS supply arrangement, the Ombud found the mandatory criteria “were also overly restrictive and favoured this existing CBSA supplier”; 40 pre-qualified suppliers were invited and GC Strategies’ bid “was the only one received”.
The same review found a June 2020 sole-source award of $11.1M for which there was “no written record of a request or non-competitive solicitation being sent to the supplier”, and an April 2020 award of $13.9 million to a contractor that did not hold the required Document Safeguarding Capability when the contract was signed. Procurement Practice Review of ArriveCAN
The government is buying a résumé and not checking whose
Across 24 procurements at ESDC, Global Affairs, IRCC, National Defence, Shared Services Canada and PSPC, with 17 contract files examined in full: in 6 of 17 files “none of the original resources worked on the contract when their category and level was required”, and in a further 3 only some did.
Paragraph 78: “in 7 of the 17 files, replacement resources were not evaluated as having met or exceeded the required experience or qualifications of the original resource.” The review was opened because the ArriveCAN work had already shown that in 76% of applicable contracts some or all of the people named in the winning bid did no work on it. “Bait and Switch” practice review
The price list the state is obliged to hand you
Every federal institution files its contract awards quarterly into one consolidated open dataset. Awards above $10,000 are listed individually with supplier name, department, description, value and solicitation procedure; awards below $10,000 are reported only as an aggregate total. The file is published as CSV, free, with a data dictionary and JSON schema, and was refreshed on 1 October 2026.
This is the asymmetry the band is built on: the purchases a single official may make on their own signature are the same purchases the Access to Information Act compels the institution to name. Proactive Publication — Contracts
Sixty dollars, and the identifiers are free
Registering a sole proprietorship business name in the Ontario Business Registry costs $60 online, immediate, with renewal at the same $60. A profile report on any registered business is $8. Registration in the federal supplier systems — the SAP Business Network used by CanadaBuys, and the Procurement Business Number that Public Services and Procurement Canada issues to identify a supplier — carries no fee. ServiceOntario fee table · CanadaBuys supplier registration
Two contracts and change
Capital: 500 × 1.4243 = CAD $712.15. Target: 5,000 × 1.4243 = CAD $7,121.50 a month, which is 7,121.50 × 12 = CAD $85,458.00 a year. At the section 6(b)(iv) ceiling: 85,458 ÷ 40,000 = 2.14 contracts a year. At the disclosure floor: 85,458 ÷ 10,000 = 8.55 contracts a year.
Diagram coordinates are that same division at each contract value — 85,458 ÷ 20,000 = 4.27, ÷ 25,000 = 3.42, ÷ 30,000 = 2.85, ÷ 50,000 = 1.71 — and the curve enters the top of the frame at 12 contracts a year, which is a contract value of 85,458 ÷ 12 = $7,121.50, one a month. Capital left after registration: 712.15 − 60.00 = $652.15. Bank of Canada FXUSDCAD
The ladder
From $500 to $5,000 a month · C$712 → C$7,120Open the Treasury Board proactive-publication contracts file, filter to awards between $10,000 and $40,000 over the last eight quarters, and read the description field. You are looking at every small purchase the federal government has already decided it wants, the department that wanted it, and the price it agreed to pay. No one has to give you this. The Access to Information Act already did.
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Download the answer key before you register anything
Open the Treasury Board proactive-publication contracts file, filter to awards between $10,000 and $40,000 over the last eight quarters, and read the description field. You are looking at every small purchase the federal government has already decided it wants, the department that wanted it, and the price it agreed to pay. No one has to give you this. The Access to Information Act already did.
cost of market research = $0.00 -
Register the cheapest legal person that can hold a contract
A sole proprietorship business name at the Ontario Business Registry is $60 and immediate; the equivalent registries in other provinces are in the same range. Do not incorporate. Nothing in section 6(b)(iv) asks whether you are a corporation, and the $40,000 ceiling is too low to be worth a company’s annual filings.
712.15 − 60.00 = 652.15 left -
Take the free identifiers in one sitting
A CRA business number, a GST/HST account, a supplier account on the SAP Business Network that CanadaBuys runs, and the Procurement Business Number PSPC uses to identify you on a contract. Each is free. This is the step most people assume costs money and skip, and it is the step that makes you findable to the officer holding the requirement.
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Price inside the band, deliberately
A proposal of $44,000 is not 10% better than one of $39,000; it is a different legal object, because it drags the officer into a solicitation they did not want to run. The useful number to quote is one that lets the purchase stay on a single signature. That is the whole commercial content of section 6(b)(iv).
quote ≤ 40,000 → no process -
Sell the named individual, not the firm
The Ombud’s evidence is that federal professional-services buying evaluates people, by category and level, against written criteria — and that firms routinely swap them out afterwards. A sole proprietor cannot swap anyone out, which is the one thing the Ombud spent two reviews complaining about. Put the résumé and the mandatory criteria side by side and answer them line for line.
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Know which door you are actually blocked by
It is not capital and it is not registration. It is personnel security screening, which a supplier cannot obtain unsponsored — a department or a contract has to initiate it. Start with the departments and the requirement types in the published file that do not carry a clearance condition, earn a first contract there, and let that contract sponsor the screening that opens the rest.
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Do not split a requirement, and do not let one be split for you
Contract splitting — carving one requirement into pieces to keep each under a threshold — is the abuse the Ombud looks for, and it is the officer’s problem that becomes yours. One requirement, one contract, under the ceiling on its own merits. An amendment that pushes a $38,000 contract past $40,000 is the same event wearing a different hat.
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Two contracts a year is the whole target
Not two a month. Two a year, at the ceiling, plus a seventh of a third. The entire difficulty of this ladder is concentrated in rung six, and the entire advantage is that the state publishes the names of everyone who cleared it, quarterly, in a file you can sort.
85,458 ÷ 40,000 = 2.14 contracts = USD $5,000 / month
Sources
7 primary documents- Government Contracts Regulations, SOR/87-402, s. 6 — Justice Laws Website
- Office of the Procurement Ombud — Procurement Practice Review of ArriveCAN, January 2024
- Office of the Procurement Ombud — "Bait and Switch": Review of Replacement Resources in Professional Services Contracts, September 2025 (Ombud Alexander Jeglic)
- Proactive Publication — Contracts, Treasury Board of Canada Secretariat, last updated 1 October 2026
- ServiceOntario / Ontario Business Registry — cost and time to register a business name
- CanadaBuys — how to register your business
- Bank of Canada Valet — FXUSDCAD daily average exchange rate