Act respecting contracting by municipal bodies (LCOM): An SME Guide to the New 2026 Rules

Julie runs a services SME in Trois-Rivières. Reading the documents of a municipal call for tenders, she comes across a reference to the "LCOM." Four letters she had never seen. She wonders: has a new act just changed the rules of the game? Does she have to relearn everything?

A new act has indeed existed since April 1, 2026, but it doesn't overturn your reference points. This guide covers what the LCOM is, what actually changes, and what it means when your business wants to land a municipal contract.

What is the LCOM?

Before the LCOM, municipal contracting rules were scattered across several statutes, notably the Cities and Towns Act, the Municipal Code of Québec and other municipal laws that applied depending on the type of body. The result: rules that sometimes differed from one body to another, and a framework that was hard to follow.

The LCOM brings all of that together and modernizes it in a single act. Its official goals: to modernize and simplify the regime, make it more understandable for bodies and for businesses, and ensure greater consistency with certain provisions of the Act respecting contracting by public bodies (LCOP), which governs provincial departments and agencies.

What does NOT change (your reference points hold)

The most important thing first: most of what you know stays valid.

• The public call for tenders threshold stays at $139,000. At or above that amount (equal or higher spending, in supply, services or construction), the municipality must use an open procedure. This threshold was set on January 1, 2026 and applies until December 31, 2027. We break down every tier in our article on public tender thresholds.
• Transparency on SEAO doesn't change. Notices tied to open procedures are still published on SEAO. And the body must publish there a list of the contracts it has entered into of $25,000 and more (section 99 LCOM). Note: this list serves transparency after the award; it is not a call for tenders notice to bid on.
• The minimum deadlines for receiving bids don't change (with one exception, below): generally 15 days for contracts under $368,000, longer above that, 8 days for a written invitation procedure.

Your SEAO monitoring, your compliance reflexes and your understanding of award methods therefore stay relevant.

What actually changes

The LCOM mainly brings structural and terminology changes on the municipal side, plus a few concrete additions:

Modernized terminology for award methods. The act reformulates the ways of awarding a contract to better reflect reality (open procedure, by invitation, by mutual agreement, and a new procedure below). The wording in tender documents may therefore differ a little from what you were used to.

A new procedure: the request for a quotation to qualified enterprises. The LCOM allows a body to award a contract by soliciting prices from pre-qualified enterprises, with the contract going to the lowest compliant price among them. The qualification is published on SEAO. A minimum deadline of 10 days applies, unless the body provides for a shorter deadline in the documents published for the qualification. For an SME, the message is clear: being qualified in advance with the bodies you want to work with can become a real advantage.

The deadline for insurance contracts goes from 8 to 15 days, for consistency with other service contracts.

Administrative streamlining. The spirit of the reform is to reduce the administrative burden on municipal bodies. In practice, it's mainly municipalities that benefit, but a clearer regime also helps the businesses that have to find their way through it.

When does a municipal contract go to public call for tenders?

That's the practical question that determines where your opportunities are. The general rule:

Below the $139,000 threshold, the rules depend on the amount and on the body's contract management by-law. In practice, contracts from $25,000 to under $139,000 generally go through a written invitation to at least two suppliers, unless specific rules or exceptions apply. A pure contract by mutual agreement remains possible in certain cases, but don't assume it: check the contract management by-law of the body concerned.

Section 33 of the LCOM and its implementing regulation also provide for special cases where a contract by mutual agreement or invitation remain permitted, even for higher amounts. These cases stay exceptions: when in doubt, the reference point that matters for you is the $139,000 threshold. Among the exceptions that may concern an SME:

• Supply or service contracts entrusted to a non-profit organization, below the CETA threshold ($368,000, or $736,000 for public transit bodies).
• Service contracts not covered by CETA awarded to a non-profit, whatever the amount.
• Contracts awarded to a solidarity cooperative (under $139,000, or designated by the minister, subject to specific conditions).
• Professional services of notaries or lawyers: by invitation from $139,000, by mutual agreement below that.
• Financial services (except insurance), professional services needed for a proceeding before a court, media space for an advertising campaign, bulk trucking of aggregates through a brokerage permit holder, and certain professional services in health and social services.

What the LCOM means for your SME

Three concrete actions to remember:

1. Keep up your SEAO monitoring for contracts from $139,000 up, and also watch qualification notices: some procedures may be reserved for already-qualified enterprises.
2. Get qualified and known with the municipalities in your region. With the new request for a quotation to qualified enterprises, and with all the invitation or contract-by-mutual-agreement cases below the threshold, already being on municipal buyers' radar becomes a real lever.
3. Read the terminology carefully in 2026 tender documents: the award method and the compliance rules may be worded differently from what you knew.

The LCOM is no reason to panic. It's an opportunity: while your competitors are still discovering the new rules, you can already bid with full awareness.

Sources

• Act respecting contracting by municipal bodies, CQLR c. C-65.01 (in force April 1, 2026; act assented to on March 25, 2025, 2025 chapter 4).
• Gouvernement du Québec, Ministère des Affaires municipales: Muni-Express bulletins no. 8 (LCOM explanatory guide), no. 4 (thresholds and deadlines) and no. 6 (awarding by written invitation or mutual agreement), March 11, 2026.
• Règlement sur le seuil et les délais applicables lors de l'attribution de certains contrats des organismes municipaux (Gazette officielle du Québec, 2026).
• Secrétariat du Conseil du trésor: trade-liberalization thresholds for public procurement, January 1, 2026 to December 31, 2027.