Admin
March 27, 2026
In the world of government relations, “transparency” is more than a buzzword, it is a legal mandate that is currently undergoing its most significant evolution in a decade.
On March 9, 2026, Commissioner of Lobbying Nancy Bélanger appeared before the House of Commons’ Standing Committee on Access to Information, Privacy and Ethics (ETHI) to kick off the long-awaited statutory review of the Lobbying Act (the Act). Her message was clear: while the current framework has served Canada well, it is time for a “coherent evolution” to meet contemporary digital and political realities.
At Lobium Law, we are closely monitoring these developments. For our clients in the corporate, non-profit, and advocacy sectors, these potential changes represent a fundamental shift in how “business as usual” is documented and reported.
The Commissioner’s 21 Recommendations: A Blueprint for Transparency
Drawing on eight years of experience, Commissioner Bélanger presented 21 specific recommendations aimed at closing loopholes and harmonizing rules across the federal potential regime. These proposals have already received a “clear endorsement” from the Lobbyists Registrars and Commissioners Network (LRCN), signaling a unified front among Canada’s federal, provincial, and municipal regulators.
Key highlights from the recommendations include:
1. Registration by Default
Perhaps the most transformative proposal is the elimination of the “significant part of duties” test for in-house lobbyists. Instead of calculating hours (a process fraught with complexity for laypersons), the Commissioner recommends that organizations and corporations be required to register by default if they engage in lobbying, unless they meet a narrow, objective exemption.
2. Harmonized Disclosure Requirements
Currently, the rules for “organizations” (non-profits) and “corporations” (for-profits) differ in confusing ways. The Commissioner aims to bridge this gap by:
- Requiring all employees who lobby to be listed, regardless of their title or the amount of time spent.
- Forcing corporations to disclose any entity that “controls or directs” their activities and has a direct interest in the lobbying outcome, bringing corporate transparency in line with the non-profit sector.
- Harmonizing the deadline for filing consultant and in-house registrations by adopting a
single deadline of 10 calendar days after lobbyists begin to lobby. The current deadline for in-house registrations is 60 days after the requirements for registration are met.
- Disclosing all funding provided to support an entity’s lobbying activities.
- Monthly activity reports would include all communications about registrable matters with designated public office holders, replacing the “oral” and “arranged” requirement under the current Act.
3. Expanding the Scope of “Lobbying”
The recommendations seek to capture more “behind-the-scenes” activity, including:
- Grassroots Lobbying: Detailed reporting on digital campaigns and public appeals intended to pressure government officials.
- Government Contracts: Making communications regarding the awarding of contracts a “registrable matter” for all organizations, not just consultant lobbyists.
- Board of Directors: Clarifying that board members and partners qualify as “employees” for the purposes of the Act, ensuring their high-level advocacy is reflected in public returns.
- Extending the application of the Lobbyists’ Code of Conduct (2023): all senior officers and employees who lobby on behalf of a corporation and the most senior officer responsible for an organization or corporation would also be required to comply with the requirements of the Lobbyists’ Code of Conduct (2023).
- Compliance Measures
- Five Year Restriction on Lobby: all former designated public office holders regardless of whether they are a consultant lobbyist, or lobby for an organization or corporation would be prohibited from engaging in any lobbying activities for the duration of their five- year restriction on lobbying. This change would remove the exception for public office holders who are employed by a corporation where certain thresholds are met.
- New obligations for employers and employees: an employer will be accountable for compliance with the Act and will require employees to inform the senior responsible officer of the employee’s lobbying activities.
- Compliance Tools: giving the Commissioner new tools to enforce the Act including the use of mandatory training, administrative monetary penalties, temporary prohibitions on lobbying, referrals to appropriate authorities where other legislation has been contravened,
The Immediate Reality: The 8-Hour Threshold
While the statutory review looks toward the future, a massive change has already arrived. As of January 19, 2026, the interpretation of a “significant part of duties” has been drastically tightened.
The old “20% rule”, which effectively allowed 32 hours of lobbying per month before triggering registration, is gone. It has been replaced by a much stricter 8-hour threshold within a rolling four-week period.
Why this matters for you:
- Cumulative Time: The 8 hours are calculated cumulatively across your entire staff. If four employees each spend two hours drafting a policy brief, your organization has met the threshold.
- Broad Definition of Work: “Lobbying” isn’t just the meeting itself. It includes time spent drafting letters, preparing briefing packages, research, and even internal strategy meetings specifically for an upcoming communication with a public official.
- Severe Penalties: Missing this threshold can lead to fines up to $200,000 and the potential for a lobbying ban. Most importantly, your company’s reputation is harmed.
What’s Next: ETHI Committee and Beyond
The ETHI Committee’s study is just the beginning. Over the coming months, the committee will hear from various witnesses, including provincial regulators and the RCMP, before submitting a final report to Parliament.
Commissioner Bélanger noted during her testimony that she hopes this study leads to “integrity and trust in our federal institutions,” ensuring Canada remains a global leader in lobbying regulation.
How Lobium Law Can Help
Navigating these shifts requires more than just a tracking spreadsheet; it requires a strategic compliance framework. At Lobium Law, we help our clients:
- Conduct Threshold Audits: Determining if your current advocacy activity crosses the new 8-hour line.
- Develop Internal Protocols: Implementing robust tracking systems for employees to log their preparation and communication time in real-time.
- Interpret the “Grey Areas”: Navigating the nuances of what counts as an “established and transparent procurement process” versus a registrable contract communication.
Is your organization ready for the new transparency era? Contact Lobium Law today for a confidential compliance assessment.