Policy Advisory: Federal Lobbying Rules Have Changed — Are You Now Required to Register?

Sara Krynitzki

PFC News

4 mins read

February 9, 2026

Effective January 19, 2026, new federal guidance lowers the threshold at which corporations and organizations, including charities, nonprofits, and foundations, must register their inhouse lobbying activities under Canada’s Lobbying Act.

For many organizations, this change won’t have an impact. For some it means that commonplace interactions with federal officials may now trigger legal registration and reporting obligations.

What’s changed

Until recently, organizations were only required to register if lobbying represented a “significant part” of an employee’s duties. This was commonly interpreted as a 20% threshold, or approximately 32 hours per month for a single full-time staff member.

Under new interpretation guidance issued by the Office of the Commissioner of Lobbying registration is now required when employees collectively spend 8 hours or more on lobbying activities within any consecutive four-week period. This applies regardless of whether the time is spent by one employee or spread across several staff members.

What counts as lobbying now

Lobbying activity includes direct and indirect efforts to influence federal decisions, including:

Meetings, emails, or phone calls with federal public office holders
Communications about federal programs, policies, legislation, or funding
Preparation time: drafting decks, briefing notes, or internal strategy
Paid or staffled grassroots campaigns urging the public to contact federal decisionmakers

All of this time is counted together across staff and assessed over a rolling four week period.

Exempt activities include unpaid volunteer advocacy or independent public action, travel time, purely administrative activities.

The organization’s seniormost paid officer must file a lobbying registration within two months of exceeding the threshold. Once registered, the organization must submit monthly reports disclosing oral, arranged meetings with Designated Public Office Holders, such as Ministers, MPs, Senators, and senior officials. These obligations continue for as long as lobbying activity remains ongoing.

Failure to register when required can lead to compliance reviews and reputational risk, even where intentions are aligned with public benefit.

Why this matters for foundations and nonprofits

Lowerlevel activity now counts, and so eight hours can go quickly. A handful of meetings, emails, or briefing notes prepared by different staff can be enough to require registration.

What’s more is that many activities long considered relationshipbuilding or program delivery, can now count toward the lobbying threshold.

Foundations engaging in policy discussions, funding advocacy, or sector coordination at the federal level may now require registration. Where campaigns are coordinated or funded, grantees’ advocacy activities may also apply.

Recommended next steps

PFC members may wish to:

Implement a tracking system for staff time spent on federal government communications, including preparation.
Review advocacy and public affairs activities, especially paid or staffled public campaigns.
Clarify roles and expectations with grantees and coalition partners.
Seek legal or compliance advice if unsure whether registration is required.

You may also consider attending one of the info sessions on the topic being held by the Lobbying Commissioner’s Office – learn more here.

Bottomline

The federal lobbying regime now captures a much wider range of charitable and nonprofit activity. Organizations that regularly intersect with federal officials should assume that registration may now be required and plan accordingly.

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