Canada’s new lobbying rules, effective January 19th, 2026, significantly lower the bar for charities and nonprofits to register as lobbyists, requiring registration if staff spend just eight hours on federal lobbying in a rolling four-week period. We explored these changes in our recent CharityVillage Connects podcast episode, Navigating the New Lobbying Rules: Avoiding Pitfalls and Accelerating Advocacy, we sat down with legal and advocacy experts, as well as veteran sector leaders, to discuss how these changes will impact charities and nonprofits across the country.
We were also very pleased to have the opportunity to interview Canada’s Commissioner of Lobbying, Nancy Bélanger, who was responsible for this change in interpretation of the lobbying rules. Commissioner Bélanger was appointed in 2017 and reappointed in 2024, and brings over 35 years of legal and public sector service experience to her role. Here is a short excerpt of her full interview.
What actually is lobbying? We asked Commissioner Bélanger to explain.
Commissioner Bélanger: What does lobbying mean under the Lobbying Act? It means communicating with federal officials. Those are public servants, ministers, members of parliament, senators, and their respective staff. Orally or in writing…so you’re doing it for your boss, or you’re doing it because you’ve been hired by somebody from the outside to do it, about a regulated matter, which is an ask, either a development or an amendment to a legislation, a regulation, a policy, a program, or to get money, for example. So you have to dissect all sorts of elements to get there, but that’s how the Lobbying Act works.
So if you’re simply reacting and providing an opinion in the public domain, that’s not lobbying. This is not what is meant to be regulated by the Lobbying Act. But if you, in fact, communicate, you provide your opinion to officials about the budget, which is a bill, you would likely have to register if it’s part of your job to do that. That’s really the element. You’re actually communicating with an official about something you want changed with respect to that bill.
And who initiates the communication is somewhat irrelevant for the purposes of registration. So if there’s a public consultation going on, there is an exception in the Lobbying Act that if it’s a public consultation, but it’s truly public, so there’s transparency about who’s communicating and what is being said in that communication, then there’s an exclusion. We’ve issued a bulletin about that issue, and I would highly recommend your audience to communicate with our office if they’re not sure, because we can help them navigate this. But I think when a budget comes out, and you’re actually communicating about it, assume that you need to register.
Commissioner Bélanger went on to explain the changes that took effect in January of 2026.
Commissioner Bélanger: The most senior person in an organization is the one that is responsible to enter the lobbying activities of its employees in the registry. And they have this obligation once they meet the threshold, the “significant part of duties” threshold. Once they meet that threshold, they have 60 days to go and do a registration.
The significant part of duties threshold has been interpreted by previous commissioners to be 32 hours in a monthly period. That is a lot of lobbying that is occurring without transparency. And so I’ve decided, and it’s in my authority to do so, to reduce what that means in order to meet the objectives of the Act, which is transparency of lobbying. So the new threshold will now be eight hours in a four-week period.
The Act requires that what you calculate is the collective lobbying of all of your employees. So you need to look at who has as their duties to communicate with officials, and you add all of that up. And once it amounts to eight hours, you have to register. It used to be 32, now it’s going to be eight.
We were curious as to whether these requirements are the same for all organizations, or whether there are any exemptions.
Commissioner Bélanger: It applies to anybody. The law applies equally to all organizations, irrespective of their status. Some are already registered, so this will mean nothing to them. This is really going to affect those who were under the 32 hours, knew for sure that they were under the 32 hours, but were doing about 20, 25 [hours]. They will need to register. And one of the examples I can give is lobby days.
The number of lobby days on the Hill for which the organizations are not registered is quite high. And so I think it’s important that there be more transparency about the communications they’re having.
I think the lobby day is the perfect example because if you send two or three employees for four or five hours, you probably were okay to stand under 32 and not register. Now you’ll clearly meet the threshold. So to me, that is sort of the perfect example.
Others could be when there’s a push, like for example, if there is a push with respect to a budget, and now you’re doing one month of lobbying and away you go, and it’s really an extensive activity, that would probably bring you over the threshold as well, while in the past it wouldn’t.
Commissioner Bélanger gave her advice to organizations who may not have been in compliance since the changes took effect in January.
Commissioner Bélanger: Lobbying while not registered, lobbying while you’re prohibited from lobbying are offences under the Lobbying Act. But I tell people, put yourself in compliance. We have never refused someone who calls us and says, “my goodness, I should have registered six months ago, and I wasn’t”. We encourage people to call us. I’m not into gotcha moments.
This is all about transparency and putting organizations, corporations, and consultant lobbyists in compliance with the Lobbying Act. If you come forward and you register, I’m not going to investigate because I only investigate when I have reason to believe it’s necessary to ensure compliance. If somebody calls in and says, I want to be in compliance and I realize I probably should have done this a while back, we will accept that registration.
The issue is when I receive allegations of unregistered lobbying, and I start an investigation because someone hasn’t come forward, and then I realize that organization or corporation should have been registered, that’s when the Act requires me to suspend and send to the RCMP. I’ve sent 18 of those files during my eight years so far. But we do accept weekly late registrations, and so I would highly, highly encourage people to call us.
Want to hear more from Canada’s Commissioner of Lobbying, Nancy Bélanger? Listen to her full interview in the video below.
Listen to Commissioner of Lobbying Nancy Bélanger and other sector experts explore the new lobbying guidance and how it will impact nonprofits and charities across the country in our new podcast episode. Click here to listen.
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