Public Accountability Bounty Act
Ontario text drafted 27 August 2026 · federal edition 29 August 2026, published in full 8 September 2026 · federal text for the House of Commons or the Senate · not yet introduced · before the Standing Committee on Government Operations and Estimates as a brief to the Comprehensive Expenditure Review
The state already pays outsiders for what it cannot see from the inside. The Ontario Securities Commission pays up to 5 million dollars for information about breaches of securities law. The Canada Revenue Agency pays an informant between 5 and 15 per cent of the offshore tax it recovers. A federal body that breaks an obligation it published itself is worth nothing to anyone outside it, and nobody outside it measures the breach. This Act puts a price on that, creates no office and asks for no money.
The defect
Compliance with a published federal service standard is assessed by the department that wrote the standard. There is no external measurement, and there is no channel through which a person outside government can report a departure and have it decided.
The incentive runs backwards. Whoever documents a defect carries the whole cost of documenting it and receives nothing. The body that caused it carries no cost and grades its own performance.
What the Act does
1. Anyone may submit a finding
Citizenship, immigration status, residence, age, language, disability and professional credentials are all irrelevant, and the Act says so in terms. No fee, in either official language.
2. An office that already exists decides it
The administrator receives findings, assesses them against published criteria, determines an award and maintains the registry. The Act creates no office, no position, no agency and no fund, and says that in a section of its own.
3. Four axes, published with every decision
How many people the defect reaches, the severity of the harm, the difficulty of obtaining a remedy, and how far it is entrenched in policy. Each scored from 0 to 3. The total sets the tier, and the tier sets the award, on the scale used in the registry. The assessment and the reasons for it are published.
4. The body at fault pays, out of its own appropriation
Awards are paid by the public body concerned, out of moneys appropriated by Parliament for the purposes of that body, and not out of a central fund. A department that keeps its own published standards pays nothing. The cost equals the volume of its own breaches.
5. Forty-five days to correct or to answer in writing
The body corrects the defect or gives written reasons why it is not one. The answer is published in full. Silence is recorded, and it raises the award by half.
6. A public registry, free and without an account
Every finding, every answer and every award, with running totals: how many findings, how many people affected, how much is determined and unpaid, how many defects corrected, and the longest period a body has gone without answering. Published in both official languages and in a form that meets the Accessible Canada Act.
7. A ceiling that turns unpaid amounts into a public debt
Awards paid by one body in a year are capped at 0.05 per cent of what Parliament appropriated for it. An amount above the ceiling is not cancelled. It stays payable, it is paid in the following year, and until then it stands in the registry as outstanding.
8. The person the defect was applied to is paid as well
A defect in a rule is one entry however many people it crossed. Every person it was applied to has an entry of their own, scored on their own harm, never less than a quarter of the award for the defect. A person who reproduces a defect independently receives a tenth, for the first 3 such reports. Ten affected people raise the reach of the defect by a point, and it is scored again, upward, for everyone already on it.
9. Entries recorded before the Act are assessed under it
A defect recorded in a public registry before the Act comes into force is accepted for assessment, if at the time of the entry that registry recorded the obligation relied on, the evidence, the date the body was notified, and the name or pseudonym of the reporter. That is why the registry exists now rather than after.
10. The administrator is measured too
Ninety days to assess. Where the administrator misses it, the finding stands in the registry as unassessed, with the time elapsed shown.
The two objections, answered by construction
A new bureaucracy. None. The Act forbids itself from creating an office or a position, and gives the work to an office that exists, is funded, and already receives information from people who are not public servants.
A cost to the treasury. None asked for. The body at fault pays from money Parliament has already voted it, under a ceiling, and a body that complies pays nothing.
The royal recommendation
This is what kills a private member’s bill before first reading, so the draft is built against it.
Section 54 of the Constitution Act, 1867 and Standing Order 79(1) forbid the House to pass a bill appropriating public revenue to a purpose not first recommended by the Governor General. A recommendation is required where a bill authorises new spending for a distinct purpose, extends the objects of an existing appropriation, relaxes its terms, or otherwise creates a new charge on the Consolidated Revenue Fund.
The draft answers all four. It authorises no spending: every payment is expressed as coming out of moneys appropriated by Parliament, so it depends on a future decision of Parliament and creates nothing. It extends no object, because keeping the standards a department published is already the purpose for which that department is funded. It relaxes no condition; it adds two, a written answer and a ceiling. And it creates no charge, because there is no new office, no new position, no new fund and no central source of payment.
The same drafting is required for a Senate public bill, because section 53 requires bills appropriating revenue to originate in the House of Commons.
Who administers it
The draft names one office and sets out the alternatives, because the choice belongs to the legislator. Only one option is refused, and it is the one that is not on the list: to go on not measuring.
| Office | For | Against |
|---|---|---|
| Public Sector Integrity Commissioner named in the draft | The only federal office with general jurisdiction over the whole public sector. Already receives information from people who are not public servants. Already pays individuals under its own statute. Reports to both Houses. | Its mandate is built around serious wrongdoing, and a defect is smaller than that. Small office. |
| Auditor General of Canada | Jurisdiction over every federal body, and reports that are cited in the House without anyone having to ask. | Audits, rather than deciding individual claims. Awarding money to named people sits badly with audit independence. |
| Procurement Ombud | Already built to receive complaints from outside, with a procedure and fixed periods. | Subject matter is narrow today and would have to be widened expressly. |
What there already is to measure against
The Act invents no obligations. It makes the published ones measurable from outside.
- Access to Information Act, section 7 and Privacy Act, section 14 — thirty days, counted from receipt by the institution.
- Policy on Service and Digital and the directive under it — departments must publish service standards and their performance against them. The department set the period itself.
- Official Languages Act, Part IV — service in both official languages, detectable by machine.
- Accessible Canada Act — accessibility plans and progress reports the bodies publish themselves.
- Published processing times and service standards of the large delivery departments, which produce the highest volume of findings.
The text as drafted
Model text. A member does not introduce another person’s draft as it stands: the intention goes to legislative counsel and is rewritten into form there. The point of publishing it in sections is that the argument starts with the content rather than with a blank page.
Preamble
Whereas public bodies publish, in Acts of Parliament, regulations, service standards and official guidance, the obligations they owe to the people of Canada;
Whereas compliance with those published obligations is measured almost entirely from inside the bodies that owe them;
Whereas Canada already pays members of the public for information about wrongdoing, the Canada Revenue Agency paying an informant between 5 and 15 per cent of the additional federal tax it collects under the Offshore Tax Informant Program, and the Ontario Securities Commission paying a whistleblower up to 5 million dollars;
Whereas a breach of securities rules is therefore worth money to the person who reports it, while a public body breaking its own published obligation to a person is worth nothing to anyone outside that body;
And whereas that gap can be closed without establishing any new office and without any new appropriation;
Now, therefore, His Majesty, by and with the advice and consent of the Senate and House of Commons of Canada, enacts as follows:
Short title
1. This Act may be cited as the Public Accountability Bounty Act.
Interpretation
2. (1) In this Act,
“Administrator” means the Public Sector Integrity Commissioner appointed under section 39 of the Public Servants Disclosure Protection Act;
“affected person” means a person to whom a defect was applied in a specific case;
“defect” means a verifiable difference between an obligation of a public body and its conduct, where the obligation arises from an Act of Parliament, a regulation, a published service standard, a published policy or directive, or official guidance published by or for that body;
“finding” means a report of a defect that meets the requirements of section 6;
“public body” means a portion of the public sector within the meaning of subsection 2(1) of the Public Servants Disclosure Protection Act, and any other body prescribed by the regulations;
“registry” means the public registry maintained under section 5;
“reporter” means a person who submits a finding.
(2) The obligation relied on in a finding is the obligation as it read on the day of the conduct complained of.
Program
3. (1) The Public Accountability Bounty Program is established.
(2) The Administrator shall operate the Program, receive findings, assess them, determine awards, and maintain the registry.
(3) No person is disqualified from submitting a finding by reason of citizenship, immigration status, residence, age, language, disability, or absence of professional credentials.
(4) A finding may be submitted in either official language, and no fee is payable for submitting a finding.
4. (1) No office, position, agency or fund is established by this Act.
(2) The Administrator shall carry out the functions conferred by this Act out of moneys appropriated by Parliament for the purposes of the office of the Public Sector Integrity Commissioner.
Public registry
5. (1) The Administrator shall maintain a public registry of findings.
(2) Each entry shall record the number of the finding, the public body concerned, the class of defect under Schedule 2, the assessed severity, the award determined, the date the body was notified, the date of any correction, and the status of payment.
(3) The registry shall publish, and update on each entry, the total number of findings, the total number of affected persons recorded, the total amount determined and unpaid, the number of defects corrected, and the longest period during which a public body has not responded.
(4) The registry is a public record, and shall be available without charge, without registration, in both official languages, and in a format that conforms to the requirements of the Accessible Canada Act.
(5) The registry shall not contain personal information about an affected person except with that person’s written consent, and the publication of an entry is a disclosure authorized by an Act of Parliament for the purposes of paragraph 8(2)(b) of the Privacy Act.
Findings
6. A finding shall
(a) identify the obligation relied on and its published source;
(b) state the version of that source in force on the day of the conduct;
(c) describe the conduct that departs from the obligation, with dates and file numbers where they exist; and
(d) include evidence sufficient for the Administrator to verify the departure independently.
7. (1) The Administrator shall notify the public body concerned of a finding that meets the requirements of section 6.
(2) The public body shall, within 45 days after being notified, correct the defect or give written reasons why it is not a defect.
(3) The Administrator shall publish the body’s response in the registry in full.
(4) A failure to respond within the period is recorded in the registry and increases the award payable under section 9.
Assessment
8. (1) The Administrator shall assess each finding on four criteria: the number of people the defect reaches, the severity of the harm it causes, the difficulty of obtaining a remedy for it, and the extent to which it is entrenched in a policy or practice.
(2) Each criterion is scored from 0 to 3, and the total determines the tier of the finding under Schedule 1.
(3) The Administrator shall publish the assessment and the reasons for it.
(4) The Administrator shall complete the assessment within 90 days after receiving the finding, and, if the assessment is not completed within that period, the finding is recorded in the registry as unassessed together with the time elapsed.
(5) The Administrator may refuse to assess a finding that does not meet the requirements of section 6, and shall give written reasons for the refusal.
(6) A reporter may request a reconsideration within 30 days after an assessment or a refusal, and the Administrator shall decide the request in writing.
Awards
9. (1) The Administrator shall determine an award for each verified finding in accordance with Schedule 1.
(2) The award is increased by 50 per cent where the public body does not correct the defect within the period under subsection 7(2).
(3) The award is doubled where the defect arises from a policy or practice applied to all persons served by a program.
(4) An affected person who establishes that a defect was applied to them is entitled to an award assessed on the harm in their own case, and in no case less than 25 per cent of the award for the defect.
(5) A person who independently reproduces a defect already recorded is entitled to 10 per cent of the award for the defect, for the first three such reports.
(6) Where 10 or more affected persons are recorded in respect of one defect, the Administrator shall reassess the reach of that defect and adjust the award accordingly, and the adjustment applies to every award already determined in respect of that defect.
(7) No award is payable to a person whose official duties included the detection or correction of the defect concerned.
Payment
10. (1) An award is paid by the public body concerned out of moneys appropriated by Parliament for the purposes of that public body, and not out of a central fund.
(2) Payment shall be made within 30 days after the determination.
(3) The total of the awards paid by a public body under this Act in a fiscal year shall not exceed 0.05 per cent of the total amounts appropriated by Parliament for the purposes of that body for that fiscal year.
(4) An amount that cannot be paid by reason of subsection (3) remains payable, is paid in the following fiscal year in the order in which it was determined, and is recorded in the registry as outstanding until it is paid.
(5) An award is not compensation, and does not affect any other right or remedy of the person, including any proceeding the person brings on their own behalf.
Findings recorded before coming into force
11. (1) This section applies to a defect recorded, before the day on which this Act comes into force, in a publicly accessible registry that recorded, at the time of the entry, the obligation relied on, the evidence, the date on which the public body was notified, and the identity or pseudonym of the reporter.
(2) The Administrator shall accept such an entry for assessment on the application of the reporter, and shall assess it and determine an award as if the entry had been made under this Act.
(3) Awards under this section are payable in respect of entries recorded on or after 27 August 2026.
Protection
12. (1) No public body shall refuse, delay, reduce or withdraw a service, benefit or decision by reason of a person having submitted a finding.
(2) No employer shall discipline, dismiss or otherwise penalize an employee by reason of the employee having submitted a finding based on publicly available information.
(3) A person may submit a finding under a pseudonym, and the Administrator shall not disclose the person’s identity without written consent.
Relationship to other Acts
13. (1) A finding under this Act is not a disclosure under section 13 of the Public Servants Disclosure Protection Act, and nothing in this Act prevents the same facts from being disclosed under that Act.
(2) The Administrator may treat information contained in a finding as information provided by a person who is not a public servant for the purposes of subsection 33(1) of the Public Servants Disclosure Protection Act.
(3) Nothing in this Act affects the jurisdiction of the Federal Court under section 18.1 of the Federal Courts Act.
Reporting
14. (1) Each public body shall publish annually the number of findings recorded against it, the number corrected, the average time from notification to correction, the total awards paid, and the total amount outstanding under subsection 10(4).
(2) The Administrator shall include in the annual report prepared under section 38 of the Public Servants Disclosure Protection Act a report on the operation of this Act.
Regulations, review, coming into force
15. The Governor in Council may make regulations prescribing public bodies in addition to those referred to in the definition “public body” in subsection 2(1), prescribing classes of defects, and amending Schedule 1.
16. The Administrator shall review the operation of this Act three years after the day on which it comes into force and report to both Houses of Parliament.
17. This Act comes into force on the day on which it receives royal assent.
Schedule 1 — Awards
| Total score under section 8 | Tier | Award |
|---|---|---|
| 10 to 12 | Critical | 1,500 CAD |
| 7 to 9 | High | 400 CAD |
| 4 to 6 | Medium | 100 CAD |
| 1 to 3 | Low | 25 CAD |
Schedule 2 — Classes of defect
| Class | Description |
|---|---|
| A | Failure to meet a period fixed by an Act or a regulation |
| B | Failure to meet a service standard published by the body |
| C | A policy, directive or published instruction that conflicts with an Act or a regulation |
| D | A service, form, document or page that does not meet a mandatory accessibility or official languages requirement |
| E | Published information that is false, obsolete or unusable |
| F | A condition of service that excludes persons on a ground protected by the Canadian Human Rights Act or the Canadian Charter of Rights and Freedoms |
| G | A procedural defect in a decision, including a decision given without reasons, without notice of the right of review, or by a person without authority |
Published in full so that it can be read, copied, criticised and filed by anyone. Nothing here has been introduced in any legislature. A member or a committee that wants it in bill form can have the working file on request. Four defects are already recorded and scored against 4 federal bodies in the registry, and section 11 is what makes those entries count on the day the Act comes into force.