Guidelines for Pooling

Large ITB investments may not always scale perfectly to a particular procurement and companies want to ensure that they will be fully credited for them. Pooling provides companies with the flexibility to divide a large transaction into separate pieces and apply each piece to different projects. In doing so, it encourages companies to make large-scale, high value investments in Canada.


"Pooling" is defined as the act of dividing a single ITB transaction into different portions and using each portion towards meeting the obligation associated with two or more different projects.


The following conditions will be fulfilled in order for pooling to take place:

  • The proposed transaction meets the eligibility criteria:
    • causality
    • incrementality
    • eligible donor
    • timing
  • The proposed transaction has a Canadian Content Value of not less than $50 million.
  • The proposed transaction involves strategic and long-term impacts on the Canadian recipient company, in areas such as: research and development, first purchase of innovative Canadian technologies, unique market leadership, world product mandate, global value chain, consortia, small- and medium-sized business, and/or technology advancement.
  • Pooled transactions are identified as such at the time of submission to Innovation, Science and Economic Development (ISED) Canada.


  • A Contractor will submit its proposed pooling transaction to the designated pooler at the ITB Branch (see contact below), using the standard transaction sheet template available on the ITB website.
  • At the time the transaction is submitted, the Contractor will clearly identify the specific obligations to which the pooled transaction would apply.
  • Should the proposed transaction be accepted by ISED as meeting both the eligibility and pooling criteria, the Contractor will then submit separate transaction sheets for each of the projects that are to receive a portion of the pooled transaction.
  • The commitment value assigned to each separate transaction sheet is at the Contractor's discretion, but Contractors will adhere to that value going forward. The total value of the separate transaction sheets will be equal to the total value accepted by ISED.
  • The region(s) specified on each separate transaction sheet will be the same as the region(s) accepted by ISED.
  • Pooled transactions are subject to the usual annual reporting and verification activities before credits are awarded. Contractors will report on the pooled transaction through their individual reporting processes for each of the projects involved.
  • Contractors will indicate at the outset the reporting approach they prefer and they will adhere to it going forward. For example:
    • Contractors can report on all portions of the pooled transaction simultaneously and proportionally each year;
    • Contractors can report on the pooled transaction consecutively, completing the commitment on one portion before beginning to report on the next.
    • Contractors may propose an alternate reporting approach, to be discussed and finalized with ISED.
  • ISED will ensure that verification activities on pooled transactions are well coordinated and timely.


  • Contractors may apply to bank a portion of a pooled transaction.
    • If the portion entering in the bank is valued at over $50 million, the contractor may make withdrawals in increments.
  • Contractors may apply to bank overachievements on pooled transactions; however, all of the separate portions of the pooled transaction will be completed before banking can take place.
  • All of the usual terms and conditions associated with banking overachievements will apply with respect to pooled transactions.

Value Proposition

  • Bidders may include a portion of a pooled transaction in their Value Proposition proposal at bid closing. However, this pooled portion must originate from the bank.
  • As with all banked activities, acceptance of a transaction or any pooled portion thereof into the bank does not in any way signal or guarantee Value Proposition points.

Contact the ITB pooler:

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