More non-profits and organizations must register as lobbyists under stricter federal rules
Why It Matters
Charities and non-profits interact with government on many levels, including requesting funding, being contracted to deliver essential services, and advocating for policy reform. While not all of these activities are classed as lobbying, the upcoming changes to reporting requirements will likely mean that many organizations will have to track and report their interactions with the federal government.
Most non-profits who interact with the federal government will likely have to register as lobby groups next year.
Starting in January, any organization that spends eight or more hours lobbying in any four-week period will have to register their lobbying activities. This will change from a threshold of 32 hours every month.
The Commissioner of Lobbying Nancy Bélanger felt that the change was necessary because there is “too much lobbying that is occurring without transparency” under the 32-hour threshold, she said in a webinar hosted by the Canadian Charity Law Association (CCLA) in October.
“The main impact is that more organizations that might not consider themselves lobbying or might not have to register will now have to,” said Jasmine Lee, a senior associate at Springboard Policy, an organization that supports the non-profit sector in policy development and capacity.
“Some of those larger or for-profit organizations probably already have systems in place for understanding who conducts different lobbying activities [and] how long they’re doing it for,” she said.
“But maybe some smaller organizations, non-profit organizations and charities don’t have those processes in place.”
Any organization of any type that lobbies the federal government for more than eight hours in any four-week period will have to register as per the new requirements. Lobbying is classified as “communicating with federal public office holders” directly or indirectly through appeals to the public.
The subject of the communication could be legislative proposals, bills, resolutions and regulations, policies and programs, grants and contributions, contracts and arranging meetings.
Consultant lobbyists must register their activities by default, while in-house lobbyists must meet the minimum hours threshold and do not need to report contracts and meeting arrangements.
Penalties for non-compliance include fines, imprisonment and/or lobbying bans.
Legislative review “overdue”
Commissioner Bélanger has stressed that a parliamentary review of the Lobbying Act is “long overdue”, with the last one taking place in 2012.
“The new interpretation should not serve as a substitute for a proper legislative review required by the Act,” her Office wrote in a news release.
During the CCLA webinar, Commissioner Bélanger also said she would prefer that all organizations register by default, but that would require a change in the law.
She stressed that lobbying is still a “legitimate activity” that supports public sector decision-makers.
She also confirmed that volunteers are not required to log and register their activities. However, board members who are paid an honorarium beyond expenses are “considered consultant lobbyists, and the organization is their client,” she said.
Time taken to respond to government calls for comment should also be logged, Commissioner Bélanger suggested.
“If you’re communicating to get grants and contributions, that’s also lobbying,” the commissioner said, adding that it also includes the time taken to write the grant, according to the Lobbying Act.
However, the time taken to travel to and from meetings with public officials is no longer being counted, she said.
With regard to research papers, the Commissioner said that organizations would only need to report the time spent creating them if the explicit purpose of conducting the research was to present it to the government for lobbying purposes.
Organizations must be prepared
The non-profit sector is often involved in a lot of policy advocacy work, said Martha Rans, a Vancouver-based lawyer specializing in working with the non-profit and charitable sectors.
However, she said, “Is it really necessary that the operations manager write that letter [to public officials], or could you have a volunteer director do it?
“Maybe this is an opportunity for boards to rethink what their role is,” Rans said.
Springboard Policy outlined the upcoming changes and reporting requirements in an online article, stating that “these new rules will introduce an added administrative burden to advocacy and a potential fear of penalty that have the potential to stifle or dissuade important advocacy efforts.”
Springboard has suggested that non-profits and charities “implement time tracking measures” to ensure they can catch all preparation activities ahead of meetings with federal officials.
“There needs to be some consideration of how umbrella groups can take on that lobbying registration requirement,” Rans added.
In an email response to Future of Good, the Office of the Commissioner of Lobbying of Canada confirmed that “as of September 30, 2025, the Office has met with over 500 stakeholders through more than 60 presentations to lobbyists, public office holders, and other interested parties.”
The CCLA is planning a second webinar with Commissioner Bélanger in December.
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