New federal lobbying rules will impact corporations

On July 16, 2025, the federal Commissioner of Lobbying announced sweeping changes that will significantly affect Canada’s lobbying regime. The changes announced in the new interpretation bulletins will dramatically impact public and private companies and organizations lobbying federal public officials.

 

Key takeaways

• The registration threshold for in-house lobbyists is reduced from 32 hours in each month to 8 or more hours in any given consecutive 4-week period.

• New rules for former designated public office holders wishing to lobby on behalf of a corporation.

 

What are the changes?

1. Significant part of duties registration threshold for organizations and corporations is reduced to 8 or more hours in any given consecutive 4-week period (the In-house Registration Bulletin)

 

Under the Lobbying Act (Canada) (the Act), the most senior paid officer of an organization or corporation must file an in-house lobbying registration with the Registry of Lobbyists when the following conditions are met:

1. One or more employees of the organization or corporation communicate with public office holders on behalf of their employer about: (i) the development of any legislative proposal by the Government of Canada or by a member of the Senate or the House of Commons; (ii) the introduction of any Bill or resolution in either House of Parliament or the passage, defeat or amendment of any Bill or resolution that is before either House of Parliament; (iii) the making or amendment of any regulation; (iv) the development or amendment of any policy or program of the Government of Canada; or (v) the awarding of any grant, contribution or other financial benefit by or on behalf of Her Majesty in right of Canada; AND
2. Engaging in such communications constitutes, either individually or collectively, a “significant part of the duties” of one employee.

 

Significant part of the duties – Since July 2009 and the issuance of its interpretation bulletin titled A significant part of duties (‘The 20% rule’), the Office of the Commissioner of Lobbying set the registration threshold for corporations and organizations at 32 hours of lobbying activities in any given month-long period of time. With the recent changes announced in the In-house Registration Bulletin, the threshold is lowered to 8 or more hours in any given consecutive 4-week period. Activities that will contribute to the new threshold include preparing for and participating in oral communications with public office holders, drafting written communications to public office holders with respect to registrable activity and grassroots communications concerning registrable activity.

 

Notably, the Commissioner or Lobbying highlights in the In-house Registration Bulletin that lobbying activity does not include communications that employees have with public office holders concerning the awarding of a contract by or on behalf of the Government of Canada.

 

Impact on In-house Lobbyists

 

According to the Commissioner of Lobbying, the In-house Registration Bulletin is addressing the substantial in-house lobbying that went unreported and contributed to a lack of transparency in the federal regime. The Commissioner was also critical of Parliament and its failure to review the Act or implement the Commissioner’s recent recommendations.

Businesses will now need to monitor their federal lobbying activity even closer. Many businesses will now need to register with the Registry of Lobbyists as the 8-hour threshold is low. Businesses will need to implement stricter training and compliance programs to ensure adherence to the new rules.

 

2. Former designated public office holders – significant part of work exception for in-house lobbying on behalf of a corporation

 

The Act makes a distinction between public office holders and designated public office holders (DPOHs), with the latter being more senior officials within the federal government. Former DPOHs are prevented from consultant lobbying activities and are also prohibited from lobbying on behalf of an organization. However, DPOHs may communicate with public office holders during the 5 years after they cease to perform their duties as a DPOH provided the activities do not constitute a significant part of their work for their employer. The new significant part of work threshold for former DPOHs who work for a corporation is set to 8 hours or more in any given consecutive 4-week period. As a result, former DPOHs should ensure that their lobbying activity does not meet or exceed the 8-hour threshold. Such activity includes time spent preparing for and participating in oral communications and drafting written communications to public office holders.

 

Next Steps

 

The proposed changes come into effect on January 19, 2026, giving lobbyists (corporations and organizations) time to update their compliance policies and programs, training and procedures for registration. The In-House Registration Bulletin will require companies in the grey zone of registration to closely monitor their employees’ activities.

Additionally, former DPOHs who intend to lobby should be aware of the three-stage transition period for the new threshold set out by the Commissioner concerning the five-year lobbying prohibition.

While the failure to comply with Canada’s federal lobbying regime can result in fines and imprisonment, public and private companies will want to avoid the public embarrassment and reputational harm of an investigation by the Commissioner of Lobbying.

Lobium Law can assist your company in preparing the necessary training and compliance programs to avoid breaches of Canada’s complex lobbying rules.