Changes to the Federal Lobbying Act
On January 19, 2026, new registration rules for organizations and corporations under the Federal Lobbying Act take effect. These include updated thresholds for what the federal government considers a “significant part of duties,” meaning the amount of staff time spent on lobbying activities.
The current threshold requires organizations to register lobbying activities if they amounted to 32 hours of activity in any month-long period of time.
As of January 19, organizations or corporations will be required to file an in-house registration in the Registry of Lobbyists if their staff is collectively spending 8 or more hours per month communicating with federal public office holders or the public (what constitutes lobbying is listed below).
More Information:
There is an upcoming webinar on December 16th with the Commissioner of Lobbying, Nancy Bélanger. They will be explaining when registration is required, and what ethical standards must be followed.
Other resources:
What’s included in lobbying?
Communications from an employee to a public office holder or appeals to the public about:
The development of any legislative proposal by the Government of Canada or by a member of either the Senate or House of Commons;
The introduction, passage, defeat or amendment of any Bill or resolution in the Senate or the House of Commons;
The making or amendment of any federal regulation;
The development or amendment of any federal government policy or program; and
The awarding of any grant, contribution or other financial benefit by or on behalf of the Government of Canada.
Topics of communication that only apply to consultant lobbyists include:
The awarding of a contract
Arranging a meeting between an official and any other person
What’s NOT included in lobbying?
The following are not considered lobbying activities:
Oral or written submissions to parliamentary committees in proceedings that are a matter of public record. *
Oral or written communications to a public office holder concerning the enforcement, interpretation or the application of any Act of Parliament or regulation.
Oral or written communications made to a public office holder that are restricted to requests for information.
Communications that employees have with public office holders on behalf of their employer about the awarding of a contract by or on behalf of the Government of Canada (See the FAQ section for the difference between a grant and contract.)
*Oral or written submissions consist of formal proposals, reports, presentations or other representations. These submissions to parliamentary committees are excluded from the Lobbying Act because they are typically published on the committee's webpage with a record of the committees' work.
The purpose of the Act is to provide greater transparency between the government and the public. Parliamentary proceedings are described in sufficient detail and records are maintained so that it is easily accessible to the public. For that reason, these submissions are not regulated in the Act.
How to calculate the Significant Part of Duties registration threshold:
When one or more employees communicates with a federal office holder or appeals to the public on behalf of their employer about any of the included topics for more than 8 hours within a consecutive 4-week period, it is considered a significant part of duties. Communications are listed as any of the following:
Oral, verbal, spoken, etc. (developing content, lobbying in person, by phone, virtual meetings, events.)
Written, text-based, printed, etc. (developing content, letters, emails, reports, research, text)
Appeals to the public, advertising, online posts, etc. (developing campaigns, content, posting material, fostering public engagement)
For example, the significant part of duties registration threshold would be met and the most senior paid officer would be required to file an in-house registration in the Registry of Lobbyists if, between January 16 and February 12:
One employee spends 3 hours drafting a letter sent to a public office holder (3 hours)
One employee spends 2 hours drafting and another employee spends 1 hour editing and finalizing an information package that is provided to the public office holder (3 hours)
Four employees each spend 30 minutes in a face-to-face meeting with a public office holder (2 hours).
What nonprofits should know:
Keep track of your organizations lobbying activities, including your interactions with federal public officials or to the public.
If your employees are performing the activities and they meet the threshold, you must register your activities in the Registry of Lobbyists.
If you have hired an external consultant to perform lobbying activities on behalf of your organization, make sure that they follow the requirements for registration. They are automatically required to register – there is no threshold for consultants.
If you’re unsure about what you must document and submit to the registry, contact the Office of the Commissioner of Lobbying directly for clarification.
Registering in the Registry of Lobbyists:
The most senior paid officer has 2 months from the date the threshold is met to file a registration return in the Registry of Lobbyists.
You must follow all the disclosure requirements and timelines within the Lobbying Act and its regulations. Failure to file information or to file on time is an offence with financial or legal penalties.
How to Register: https://lobbycanada.gc.ca/en/registration-and-compliance/how-to-register-and-report-your-lobbying-activities/
Background Information / FAQ
What is lobbying?
Communicating with federal public office holders directly, either written or spoken, or indirectly, by appealing to the public, about a federally regulated matter on behalf of a client (consultant lobbyist) for money/value exchange, or for an employer (in-house lobbyist) for work-related duties.
Regulated matters include:
Legislative proposals, bills/resolutions, or regulations at any point of the legislative process.
Policies or programs in development or amendment
Awarding of a grant, contribution or other financial benefit
Regulated matters that only apply to consultant lobbyists include communications about:
Awarding of a contract
Arranging a meeting between an official and any other person
Who is a public office holder?
Almost all federal employees, officers, executives
Members of the armed forces and RCMP
Staff of parliamentarians
All designated positions
All parliamentarians (senate and house of commons – PM, Ministers, and ministers of state)
Ministerial Staff
Senior Executives – deputy ministers, CEOs, associate and assistant deputies
Additional positions set by regulation
Consultant vs. In-House Lobbyists
Consultant Lobbyists
Individuals: external board members paid to lobby on behalf of a client
In-house Lobbyists
Employees who lobby on behalf of their employer
Who needs to register?
Consultant lobbyists must register by default, there is no threshold. They must register individually for each client in the Registry of Lobbyists.
In-house lobbyists must be registered once collective lobbying reaches the registration threshold for employers. The employer must register the employee in a single registration.