Commissioner of Lobbying issues new interpretation bulletin lowering the registration threshold for organizations and corporations

News release

July 16, 2025 – Ottawa, ON

The Commissioner of Lobbying, Nancy Bélanger, has published a new interpretation bulletin with respect to the "significant part of the duties” threshold for when organizations and corporations must be registered under the Lobbying Act.

The updated interpretation lowers the threshold from the current 32 hours per month to 8 hours in a rolling 4-week period. This change is expected to increase the number of corporations and organizations required to register their lobbying activities in the Registry of Lobbyists. This change does not affect consultant lobbyists, who must continue to register any undertaking to lobby on behalf of a client.

The previous interpretation allowed a considerable amount of lobbying by in-house lobbyists to go unregistered, thereby reducing transparency. The new interpretation is consistent with the principles of the Lobbying Act, which include ensuring that Canadians know who is lobbying federal government officials and about what.

As the five-year restriction on lobbying for former designated public office holders contains the similar expression “significant part of the individual’s work”, a corresponding interpretation bulletin and transition period have also been issued. The bulletin reduces the amount of lobbying that can be done by a former designated public officer holder employed by a corporation during their five-year restriction.

The Commissioner emphasizes that these changes are being made in the absence of a parliamentary review of the Lobbying Act, which is required to take place every 5 years. The last review was in 2012 and led to no changes to the Act. In her appearances before the Standing Committee on Access to Information, Privacy and Ethics (ETHI), Commissioner Bélanger called for a registration-by-default model with limited exceptions and the elimination of the discrepancy in the restrictions on lobbying that apply to former designated public office holders based on whether they work for an organization or corporation. Such changes would require legislative amendments, and the new interpretation should not serve as a substitute for a proper legislative review required by the Act. 

The new interpretation bulletins take full effect on January 19, 2026. The Office will undertake a wide range of activities to communicate these changes.

Quotes

I firmly believe that the previous 20% threshold was too high. It allowed for a considerable amount of lobbying to occur without registration, which is not consistent with the principles of transparency and accountability.

It is my hope that this interpretation bulletin will promote increased transparency and, in turn, help to ensure that the aims of the Act, including that the public be able to know who is engaging in lobbying activities, are met to an even greater degree.

The Lobbying Act needs to be updated and modernized. A review by parliamentarians is long overdue. The new interpretation is not intended to be taken as a substitute for updating and modernizing the Lobbying Act.

Related information

• Significant part of duties registration threshold for organizations and corporations
  
  • Backgrounder – Significant Part of Duties Registration Threshold
• Five-year restriction on lobbying for former designated public office holders
  
  • Backgrounder – Five-year restriction on lobbying for former designated public office holders
  • Transitional provisions: Application to former designated public office holders employed by corporations
• Improving the Lobbying Act: preliminary recommendations (2021)

Media contact

Office of the Commissioner of Lobbying of Canada
Email: media@lobbycanada.gc.ca
www.lobbycanada.gc.ca