Admin
February 20, 2026
On January 3, 2026, the federal government published the draft Foreign Influence Transparency and Accountability Regulations (Regulations) for public consultation in the Canada Gazette. The public consultation closed on February 2, 2026. The federal government has faced heavy criticism for the failure to implement the Foreign Influence Transparency and Accountability Act (FITAA), the associated registry and until recently, for failing to appoint a federal commissioner, with the goal of bringing transparency to activities performed on behalf of foreign powers and agents in Canada.
The Public Consultation: A Framework for Transparency
The public consultation and draft Regulations mark a critical milestone in the federal government’s efforts to curb foreign interference and increase the transparency of foreign actors in Canada’s political and governmental processes.
While the FITAA was passed in 2024, these new proposed Regulations provide the technical framework for the new registry, detailing exactly what information must be disclosed by individuals and entities acting under the direction of, or in association with, a “foreign principal.”
Commissioner Appointment
Under the Act, the federal government holds the authority to formally appoint the Foreign Influence Transparency Commissioner (Commissioner), the independent official responsible for overseeing the registry and enforcement of the FITAA.
On January 28, 2026, the federal government announced the selection of Anton Boegman as Canada’s first-ever Foreign Influence Transparency Commissioner. Mr. Boegman, the former Chief Electoral Officer of British Columbia, brings extensive experience in oversight and integrity to this new role. His appointment—subject to final approval by resolution of the House of Commons and Senate—is a critical step toward making the registry fully operational. In fact, Mr. Boegman appeared before the House of Common’s Standing Committee on Procedure and House Affairs on February 26, 2026.
As Commissioner, Mr. Boegman will be responsible for:
- Administration: Managing the public-facing registry of foreign influence activities.
- Enforcement: Issuing notices of violation and administrative monetary penalties for non-compliance.
- Investigation: Utilizing powers to summon witnesses and compel the production of documents to ensure the registry remains accurate and complete.
Key Requirements and Compliance Obligations
The registry targets three primary types of “influence activities” when performed for a foreign principal:
- Communication with Public Office Holders: Any attempt to influence a decision-maker at the federal, provincial, or municipal level.
- Dissemination of Information: Sharing information with the public via social media, print, radio, or other media for the purpose of influencing political or governmental processes.
- Disbursement of Funds or Services: Providing money, items of value, or services to influence Canadian policy or political outcomes.
The definition of a “foreign principal” is broad. It includes not just foreign governments and political parties, but also foreign state-owned enterprises and entities that may be controlled or directed by a foreign power. For businesses, law firms, and non-profits, this means that many standard international collaborations or government relations activities may now trigger a mandatory 14-day registration window. In its commentary on the draft Regulations, the federal government indicated that it will provide additional context for registration requirements for foreign-funded institutions and media outlets via outreach materials.
The definition of “person” who enters into “an arrangement” is also broad and includes a corporation, trust, joint venture, partnership, fund, unincorporated association, organization and any other legal entity, including individuals.
The Regulations set out extensive information requirements that individuals and entities will be required to provide when entering into arrangements with foreign principals. Updates on arrangements must also be provided to the Commissioner: (i) within 15 days after the end of the month in which a change occurred; and (ii) within 15 days of the end of five consecutive months in which no updates have been provided. Where no information has changed, the update would need to include a confirmation that the information is complete and correct.
Disclosure
The Regulations will permit the sharing of information between certain federal institutions, the Office of the Conflict of Interest and Ethics Commissioner, the Office of the Commissioner of Canada Elections and the Canadian Armed Forces. In total, the Commissioner would be able to share information with 268 federal institutions or bodies pursuant to its guidance in the Regulations. The Commissioner would also be permitted to share information with provincial, territorial, or municipal bodies responsible for elections, lobbying or conflict of interest matters subject to certain restrictions.
The Stakes of Non-Compliance
The federal government has signaled that this registry will be a high-priority enforcement area. The proposed Regulations establish administrative monetary penalties (AMPs) ranging from $50 to $1,000,000 based on certain considerations set out in the Regulations. Notably, there is no differentiation between an individual or organization for the purposes of enforcing AMPs. The Commissioner would also be able to enter into compliance agreements – something the federal Lobbying Commissioner cannot do and to which the federal Lobbying Commissioner has criticized as a deficiency in the federal Lobbying Act. Note that the federal Lobbying Act does not currently provide for AMPs either. Furthermore, serious cases of non-compliance—such as willfully failing to register or providing false information—can lead to criminal charges with fines of up to $5 million or imprisonment for up to five years, or both.
Implementation
The proposed Regulations will come into force when the FITAA comes into force. If the Regulations are registered after that date, they would take effect on the day they are registered.
Notably, when FITAA comes into force, reporting requirements for registrants would begin immediately.
How Lobium Law Can Help
The introduction of the Foreign Influence Transparency Registry adds a complex layer of compliance for any organization with international ties. From determining if a foreign partner qualifies as a “foreign principal” to ensuring that social media advocacy doesn’t inadvertently trigger registration, the legal nuances are significant.
As a firm specializing in Canadian political law, Lobium Law is here to help you navigate these new mandates. We provide strategic advice to ensure your activities remain transparent, compliant, and protected from the risks associated with this significant regulatory shift.
For more information on how the FITAA and its Regulations may affect your organization, or to schedule a compliance review, please contact our team at Lobium Law.