Act respecting contracting by public bodies (LCOP): Québec's Provincial Procurement Framework Explained

Sylvain runs an IT services firm in Québec City. He mostly bids on contracts from government departments and school service centres. Reading through a set of specifications, he keeps running into the acronym "LCOP" and references to "regulations" he's never opened. He's wondering: what does this law actually require of him, and is it the same as for municipal contracts?

The LCOP is the reference framework for provincial public procurement in Québec. It doesn't govern municipalities (which have had their own law since 2026), but it structures everything else: government departments, government bodies, health, education. This guide explains what it sets out, without the jargon.

What is the LCOP?

The law's purpose is laid out in its own text: to maintain public confidence in public procurement by ensuring transparency, the fair and honest treatment of suppliers, and accountability grounded in the responsibility of senior officers. For an SME, that translates into rules known in advance: who can bid, how a contract is awarded, and what must be made public.

The LCOP shares the same philosophy as the Act respecting contracting by municipal bodies (LCOM), which applies to the municipal world as of April 1, 2026. The two laws look a lot alike (thresholds drawn from the same trade agreements, the same public-procurement logic above a given amount), but they belong to separate legal frameworks and their thresholds are not uniform across bodies. Knowing which law your buyer falls under keeps you from assuming rules that don't apply.

Which bodies are covered by the LCOP?

That's the first thing to check, because the rules you have to follow depend on the type of body publishing the contract. The LCOP covers provincial public bodies, grouped into broad families:

• Government departments and most government bodies (Crown corporations included in many cases).
• The health and social services network: CISSS, CIUSSS, institutions.
• The education network: school service centres, CEGEPs, and university institutions.

The implementing regulations: one per type of contract

The LCOP sets the principles; the operational detail lives in its implementing regulations. Each broad category of contract has its own, and that's where you'll find the precise rules that concern you:

1. The Regulation respecting certain supply contracts of public bodies. It covers the purchase of goods (supplies, equipment, materials).

2. The Regulation respecting certain service contracts of public bodies. It covers services (professional, technical, of an intellectual nature). This is where the rules for quality-evaluation methods sit, which matter for services firms.

3. The Regulation respecting construction contracts of public bodies. It governs works (construction, refurbishment, infrastructure), with its own requirements for bonds and guarantees.

4. The Regulation respecting contracting by public bodies in the field of information technologies. For an IT firm like Sylvain's, this is often the main regulation: an IT contract falls under this regulation even if it looks like a purchase of goods or services. (Specific regulations also cover certain bodies listed in section 7 of the LCOP.)

At what point does a contract move to a public call for tenders?

This is the central mechanism, and it's the same as for the municipal side since it flows from the trade-liberalization agreements. Below a certain amount, the body has some latitude; above it, the public call for tenders becomes mandatory and the notice is published on SEAO.

Below the applicable threshold, the body can award the contract by mutual agreement or by invitation (it can also choose a public call for tenders). Above it, the public call for tenders is the rule, with strict exceptions provided by law (urgency, sole supplier, public interest), sometimes preceded by a notice of intention published on SEAO. We break down every tier, including the trade-agreement thresholds, in our article on public-tender thresholds.

Once the call for tenders is launched, it's the award method chosen by the body that determines how your bid will be evaluated: lowest compliant price, or a quality-price formula. That's a strategic decision for you, and we explain it in detail in our guide to award methods.

What changed in 2025

The LCOP's regulatory framework was amended in 2025, through several texts spread across the year, with adjustments that directly affect bidders. The most important:

• The adjustment parameter (parameter k) can now apply to certain construction work contracts, which allows quality, not only price, to be taken into account in contracts where that wasn't the case before.
• In the event of a tie, bodies can separate tenderers on quality criteria rather than by random draw, when the documents provide for it.
• The grounds for rejection tied to bid securities have been partly relaxed. Be careful, though: certain defects are no longer automatically fatal, but a missing, unsigned or non-compliant security can still lead to rejection. Never assume you'll be able to fix a security after the deposit.

These nuances can change your bidding strategy depending on the contract. The practical takeaway: don't assume the 2023 rules still hold in 2026, especially on securities and quality evaluation.

A useful clarification that isn't among the 2025 changes: for professional architecture and engineering services, selection is made first on quality, with the price then negotiated with the top-ranked firm (Regulation respecting certain service contracts).

The Autorité des marchés publics: the watchdog

You'll often run into the acronym AMP in the documents. The Autorité des marchés publics (AMP) is Québec's public procurement watchdog. It receives supplier complaints about how a call for tenders is run (generally after a first complaint to the body itself), can review award processes, and maintains the register of businesses authorized to contract with the State. That authorization is required above high thresholds that are separate from the tender thresholds: on the order of $1M for services contracts and $5M for construction or PPPs. If you feel a call for tenders was run unfairly, it's the channel provided by law, within strict deadlines. That said, plenty of rejections come down to an avoidable administrative non-compliance, not to buyer bias.

What the LCOP means for your SME

Three concrete habits to keep:

1. Identify the framework. Provincial body (department, health, education) = LCOP. Municipality = LCOM. The rules are similar, but don't confuse them: cite the right framework in your documents and check the requirements specific to each.
2. Read the right regulation. Supply, services or construction: it's the category of the contract that determines your obligations and how your offer will be scored.
3. Watch for updates. The framework shifts (2025 amendments, new thresholds every two years). Working with outdated habits means risking an avoidable non-compliance.

The LCOP isn't a text to read cover to cover before bidding. But understanding its logic, who it applies to, how a contract is awarded, and where to find the precise rules, is what separates an SME that bids with confidence from one that moves blindly.

Sources

• Act respecting contracting by public bodies, CQLR c. C-65.1, and its implementing regulations (supply contracts, service contracts, construction contracts, and contracts in the field of information technologies).
• Secrétariat du Conseil du trésor du Québec: normative framework for public procurement, 2026-2027 trade-liberalization agreement thresholds, March 2025 regulatory amendments.
• Autorité des marchés publics (AMP): oversight mandate and register of authorized businesses.
• Applicable agreements: Canadian Free Trade Agreement (CFTA), Québec-Ontario Trade and Cooperation Agreement (ACCQO), Canada-European Union Comprehensive Economic and Trade Agreement (CETA).