IESO's Long Lead-Time Request For Proposals: From Engagement To Active Procurement

In our article of March 31, 2026, we reported on the Independent Electricity System Operator’s (IESO) fourth stakeholder engagement session regarding its Long Lead-Time Request for Proposals (the LLT RFP). At that time, the IESO had released draft RFP documents and contracts for both the energy and capacity streams, and was awaiting a ministerial directive to formally launch the procurement.

Since that publication, the LLT RFP has transitioned from the engagement and draft phase to an active procurement. Final documents for both the LLT(e) and LLT(c) RFPs have now been posted, the procurement processes are underway, and the communications restrictions under the RFPs are in effect. We summarize the key developments and provide updated guidance for proponents.

The ministerial directive: Formal launch of the LLT RFP

The IESO has now received the ministerial directive formally authorizing the launch of the LLT RFP (the Directive). The Directive confirms key procurement parameters, including eligibility limited to new-build resources with development timelines of at least five years, a required commercial operation date no later than May 1, 2035, and contract terms of up to 40 years following commercial operation. Under the Directive, the IESO will hold separate procurements for energy and capacity resources, such as new hydroelectric and long-duration energy storage, respectively, and will offer evaluation incentives to projects that commit to sourcing a certain percentage of construction labour and materials from Canada. The Directive further provides that the IESO shall endeavour to conclude the procurement by offering the final contracts on or before June 30, 2027.

Final procurement documents

The IESO has posted the final LLT RFP documents for both the energy stream (LLT(e)) and the capacity stream (LLT(c)). Both procurement processes are now active.

The IESO has also released updated versions of certain prescribed forms, including the Evidence of Municipal Support forms (version 2, dated May 6, 2026), with clarifications to instructions and guidance. The IESO has indicated that use of the February 27, 2026, version of the form will not, on its own, invalidate a municipal resolution.

Of particular note in the final LLT RFP documents is the revision to the definition of “Qualifying Project,” which reduces the minimum nameplate capacity threshold from 10 MW to 1 MW. This materially broadens the range of eligible reference projects and lowers experience barriers for proponents. With respect to the proponent’s ability to achieve COD ahead of the Early Long-Lead COD, the IESO clarified that its consent shall be on a reasonableness basis rather than in its sole and absolute discretion.

Confirmed timeline and the contract award date

With the posting of final documents, the IESO has published the procurement schedule for the LLT RFP. Key milestones, applicable to both the LLT(c) and LLT(e) streams, include:

Practical guidance for proponents

The transition from engagement to active procurement carries immediate practical consequences for proponents:

Restricted communications: all proponents are reminded that the communications provisions set out in Section 3.5 of the LLT RFPs are now in effect until the conclusion of the LLT(e) and LLT(c) processes, including restrictions on communications in respect of “Excluded Purposes.” Failure to comply may result in disqualification or revocation of a proponent’s status. Proponents should review Section 3.5 of the applicable RFP and implement internal compliance protocols governing communications with the IESO, other proponents and third parties.

Pre-deliverability tests: the pre-deliverability test intake form is now available, with the first deadline having closed on April 28, 2026, a second deadline of June 30, 2026, and a third deadline of September 9, 2026. Prospective proponents can also now schedule deliverability consultations directly with the IESO. These consultations will be offered until two weeks prior to the proposal submission deadline.

Municipal elections: with registration opening on September 23, 2026, and the October 2026 municipal elections creating a compressed window for obtaining council resolutions, proponents should begin municipal and Indigenous community engagement immediately. The pre-engagement confirmation notice required for project sites on Indigenous lands and/or municipal project lands must be delivered to the IESO at least 60 days prior to the date of the required support confirmation.

Canadian content: Proponents will need to carefully evaluate whether to make a voluntary Canadian content commitment. Such commitments are binding and may carry liquidated damages of up to CA$5 million if the committed percentage is not achieved at commercial operation. The graduated incentive structure (1% reduction for ≥60% Canadian content, up to 3% for 100%) should be weighed against supply chain realities and the risk of non-compliance.

Contract term: Proponents should assess the financial feasibility of their projects against both the 40-year contract duration and the delivery timeline, including the Early Commercial Operation restrictions (no commercial operation before Year 5, IESO consent required between Years 5–7 due to deliverability considerations) and the end of the federal Clean Technology Investment Tax Credit in 2034.

Conclusion

The IESO's LLT RFP has moved rapidly from concept to active procurement. With both procurement streams now active and Section 3.5 communications restrictions in effect, the window for informal engagement with the IESO on procurement design matters has closed. Proponents will now be focused on project-level execution: reviewing the final documents, scheduling deliverability consultations, securing site access rights, engaging municipalities and Indigenous communities, and preparing proposal materials for the November 26, 2026, deadline.

We will continue to monitor developments in this procurement, including the IESO's responses to questions and comments, and any addenda issued by August 13, 2026.