Annual report 2025-26

Table of contents

• Commissioner's message

• What we do

• Enabling transparency

• Spotlight – New registration threshold

• Spotlight – Late registrations and communication reports

• Ensuring compliance

• Expanding awareness and understanding

• Workings of the Office

• Looking ahead

• Annex

Preface

This report is submitted to the Parliament of Canada pursuant to section 11 of the Lobbying Act R.S.C., 1985, c. 44 (4th Supp.).

Within three months after the end of each fiscal year, the Commissioner must prepare a report about the administration of the Lobbying Act during that fiscal year. The Commissioner is required to submit the report to the Speaker of the Senate and the Speaker of the House of Commons. Each Speaker tables the report in the Chamber over which they preside.

Commissioner's message

"Lobbying is a legitimate activity, but transparency is essential so Canadians know who is lobbying whom and on what issues.

Transparency should not be optional."

Commissioner's message

"Lobbying is a legitimate activity, but transparency is essential so Canadians know who is lobbying whom and on what issues.

Transparency should not be optional."

Since I was appointed Commissioner of Lobbying in late 2017, I have been preparing for a review of the Lobbying Act. That review is now underway.

In February 2026, ETHI was formally designated by the House of Commons to lead a review of the Act. The Committee subsequently invited me to appear on March 9, 2026. Ahead of my testimony, I shared 21 recommendations informed by my eight years of experience in administering the federal lobbying regime that would improve and modernize the Lobbying Act.

As the study continues, I remain committed to supporting the Committee in identifying legislative improvements that can keep Canada at the forefront in lobbying transparency for years to come.

Lobbying is valuable and necessary. However, it is important that it be done transparently and ethically, and that the rules be simple, clear and enforceable.

I issued a new interpretation bulletin in July 2025 which lowered the registration threshold for organizations and corporations, effective January 19, 2026. Much of 2025-26 was dedicated to the implementation of the new threshold. Even as service volumes increased, the team reinforced its reputation for dependable, high-quality advisory support and its commitment to continuous improvement.

In addition, my team and I remain committed to our ongoing work to improve the Registry of Lobbyists, to increase stakeholder understanding of the lobbying framework and to verify that registrants, lobbyists and former designated public office holders comply with the Act and Code.

Our work is rooted in all public sector values. I am very mindful of our stewardship of public resources as we administer the Lobbying Act. The ever-increasing costs, including those related to information technology, puts pressure on our human resources to continue to meet the mandate that Parliament entrusts to our organization.

I am always very proud of my team and the work we do. According to a study based on the most recent Public Service Employment Survey, our office was the top-ranked federal organization, reflecting our collective sense of shared purpose, collaboration and integrity. I am proud that our office was one of only two organizations with 100% of employees responding that their office is a great place to work.

As we begin a new fiscal year, it is my hope that the review of the Lobbying Act will lead to changes that will further transparency. We must continue to advocate for increased transparency and ethical behaviour in the lobbying of federal officials to support public trust in our democracy.

Nancy Bélanger
Commissioner of Lobbying

Return to top of page

Registry of Lobbyists

The Registry of Lobbyists is the primary tool for ensuring transparency in lobbying, allowing Canadians to explore and scrutinize the information that lobbyists are required to disclose when they lobby federal officials.

It provides access to a wealth of information and tools including statistics, search alerts and downloadable data sets. Registrations contain a wide range of information about lobbying activities, including:

• client/employer information (including parent and subsidiary companies)

• names of lobbyists and previous federal public offices held

• federal institutions lobbied

• details about the lobbying itself — including their subject matter and descriptions of the matters lobbied about

• lobbying techniques used (i.e. verbal, written, grassroots campaigns), and

• domestic and foreign government funding, if any.

Consultant lobbyists must file a separate registration for each client. For in-house lobbyists (corporations and organizations), the most senior paid officer must file a registration if the corporation or organization meets the significant part of duties threshold. A lower registration threshold of 8 hours collectively spent over a 4 consecutive week period took effect on January 19, 2026.

Corporations must list all senior officers who lobby and all employees whose lobbying activities constitute a significant part of their duties, while organizations must list every employee who lobbies.

Who was lobbied through an oral communication arranged in advance

Spotlight

New registration threshold

On January 19, 2026, a new registration threshold came into effect, increasing the number of organizations and corporations required to register their lobbying. The threshold for what constitutes a “significant part of the duties” was reduced from 32 hours to 8 hours over a four-week period.

Commissioner Bélanger’s new interpretation aligns more closely with the principles of the Lobbying Act — to ensure that Canadians know who is lobbying federal government officials and on what issues.

Dating back to 2009, the previous interpretation allowed a considerable amount of lobbying by in-house lobbyists to go unregistered, thereby hindering transparency. Additionally, it was drawn from a standard provided for in American legislation that does not include or make reference to the term “significant part of the duties”.

The change does not affect consultant lobbyists, who must continue to register any undertaking to lobby on behalf of a client.

As a similar expression (i.e. ‘’significant part of the individual’s work’’) is also referenced in the five-year restriction on lobbying for former designated public office holders (DPOHs), a corresponding interpretation was also issued. Similar to the new registration threshold, this interpretation sets out that a former DPOH employed by a corporation cannot reach or exceed eight hours of lobbying in any four consecutive weeks.

To support compliance, the Office undertook targeted outreach to raise awareness of the changes, including a combination of paid advertising, new published educational material, and info sessions. These efforts primarily focused on organizations and corporations who may not have previously been subject to the Act. More activities are described in the Expanding awareness and understanding section of this report.

Maintaining transparency requires relatively little effort, yet it is vital to sustaining public trust in our federal institutions.

Active registrations and active lobbyists

Despite the April 2025 election, the upward trend in the number of active registrations and active lobbyists continued in 2025-26. Except for the months of April and May 2025, new records for active registrations were set for each month, culminating in an all-time record in March 2026 with 7,458 active registrations, smashing the previous record of 6,223 in November 2024. The 17% increase in active registrations may be attributable in part to the lower registration threshold that took effect in January 2026. Indeed, between January 19, 2026, and May 5, 2026, there have been 211 new organizations and corporations added to the Registry.

With respect to active lobbyists, new monthly records were set each month from August 2025 to March 2026. A new all-time record was recorded in March 2026, with 8,644 active lobbyists — 14% higher than the previous record of 7,421 in January 2025.

The figures below represent the number of registrations and lobbyists registered in each month.

Reviewing registrations

Between April 1, 2025, and March 31, 2026, the Office reviewed and published 13,687 registrations, including new, reactivated, and updated registrations. This corresponds to an average of 1,141 registrations reviewed and processed each month.

While the total number of reviewed and published registrations in 2025-26 was roughly 500 lower than in the previous year, the volume of new and reactivated registrations increased by approximately 30%. The 23% decrease in updated registrations reflects a return to more typical levels. In 2024-25, the number of updates were unusually high due to a change to the Registry of Lobbyists that required registrants to update their active registration by linking subject matters to their details. This change was made to make the information available in registrations and communication reports more comprehensive.

Communication reports

Verification of communication reports

To ensure accurate reporting by lobbyists, the Office extracts a sample (5%) of new communication reports filed in the Registry of Lobbyists every month. The designated public office holders named in these reports are required under the Lobbying Act to confirm whether the information submitted in the reports is complete and accurate. They must do so in the prescribed time of 30 days. The Commissioner may report any failure to do so in a report.

In 2025-26, the Office requested the verification of 1,833 communication reports to 207 of designated public office holders named in these reports. Of these 1,545 were confirmed complete and accurate while another 191 contained some inaccuracies, which were then corrected. Some reports contained multiple inaccuracies.

Advisory services

In 2025-26, the Office saw an increase in both the number of individual stakeholders (13%) reaching out and in the total number of inquiries (9%) it received.

This increase is undoubtedly attributable to a new registration threshold coming into effect in January 2026, requiring a larger number of organizations and corporations to register. The April 2025 election also resulted in a higher number of former designated public office holders wanting to better understand their obligations under the 5-year restriction on lobbying.

Service standards for advisory services

The Office continued to deliver strong results in 2025–26, showing consistent performance across all areas, with near-perfect or perfect results throughout.

Email responsiveness remained a key strength, with 99.6% of simple inquiries answered within two business days and 100% of complex requests completed within 10 business days.

Overall, the results reflect sustained excellence, reinforcing the Office’s commitment to high-quality, timely service despite increasing demand.

Return to top of page

Compliance

The Office ensures that registrants, lobbyists, and former designated public office holders meet their obligations by conducting a variety of activities to enforce the Lobbying Act and the Lobbyists’ Code of Conduct.

In addition to 37 compliance files carried over from the previous year, which included 2 investigations, the Office initiated 20 preliminary assessments during the 2025-26 fiscal year.

In 2025-26, the RCMP returned 3 files referred by the Commissioner without laying charges. As of March 31, 2026, the Commissioner had ceased those investigations.

At the close of the fiscal year on March 31, 2026, there were 19 files at the preliminary assessment stage and 5 suspended files, 4 of which were with the RCMP while 1 continues to be suspended pursuant to subsection 10.4(8) of the Lobbying Act because the Commissioner became aware of an ongoing parallel investigation on the same subject matter.

Update on charges laid in 2024 under the Lobbying Act

Gerald Paulin

As mentioned in the previous two annual reports, the RCMP formally charged Gerald Paulin in March 2024 under the Lobbying Act following a referral by the Commissioner of Lobbying in September 2020.

Mr. Paulin is alleged not only to have failed to file a return after undertaking to communicate and to arrange a meeting with a public office holder, but also to have received a payment contingent on the outcome of a registrable matter.

Proceedings were instituted against Mr. Paulin in the Ontario Court of Justice in Thunder Bay in March 2024. The next step in these proceedings is a trial confirmation hearing set to take place on December 11, 2026.

Compliance assessments and letters

In addition to its investigation efforts, the Office undertakes a variety of activities to verify compliance with the Lobbying Act and the Lobbyists’ Code of Conduct.

Throughout 2025-26, the Office sent 27 compliance letters to lobbyists to ensure compliance with various rules or requirements. These letters addressed the potential need to register, missing subject matters in registrations and the rules related to gifts and hospitality under the Code.

The Office also conducts compliance assessments to address late filings of registrations and late filings of communication reports. Regular monitoring is conducted for a period of 1 year to ensure continued compliance. In 2025-26, 7 lobbyists were monitored.

Gifts and hospitality exemptions request

The Lobbyists’ Code of Conduct prevents lobbyists from providing gifts or hospitality — directly or indirectly — to an official they lobby or expect to lobby, other than a low value gift that is a token of appreciation, or promotional item and a low value instance of hospitality for consumption during an in person gathering.

The Commissioner may grant an exemption to the gift and hospitality rules by considering any relevant factors.

In 2025-26, the Office received 12 requests for exemptions related to limits on gifts and/or hospitality. While 7 were granted — 4 with conditions — another 4 were denied and 1 was withdrawn.

Requests are submitted through a standardized online form and are typically processed within 10 business days of the Office having received all relevant information.

Exemption requests for the five-year restriction on lobbying

In 2025-26, the Office received 23 applications for exemptions to the five-year restriction on lobbying from former designated public office holders, the highest number received to-date. One additional application was carried over from the previous year.

Of these 24 exemption requests:

• 6 were granted

• 12 were denied

• 4 were withdrawn/ineligible

• 2 were carried over to 2026-27

All granted exemptions are published in the Registry of Lobbyists, along with relevant information and any conditions that may apply.

Service standards for requests for exemptions to the 5-year restriction on lobbying

Return to top of page

Outreach and education

The Office actively engages with lobbyists, public office holders, members of media, and the general public to raise awareness of the Lobbying Act and the Lobbyists’ Code of Conduct. These outreach efforts foster understanding and support compliance with both the Act and the Code.

In 2025-26, the Office met with 1,981 stakeholders through 196 presentations to lobbyists, public office holders, international organizations, students, and other interested parties.

Proactive info sessions

The coming into effect of a lower registration threshold provided the perfect opportunity for the Office to proactively offer info sessions. In late November 2025, the Office hosted its first Do you need to register your lobbying: Understanding the new registration threshold session, which focused on providing an overview of the lobbying framework and the threshold for registration. By March 31, 2026, the Office had hosted 14 of the pre-scheduled sessions, 8 in English and 6 in French, which were attended by approximately 500 participants.

Given the success of these sessions, the Office will continue to proactively offer info sessions in addition to on-demand sessions requested by individuals or groups and will explore additional topics for new regular sessions.

Advisory letters

The Office issued advisory letters to 5 individuals identified in media reports following announcements of their employment with government relations firms, organizations, or corporations engaged in federal lobbying. These letters serve to inform potential lobbyists about registration and reporting obligations under the Lobbying Act, promoting compliance and transparency.

Additionally, the Office also reached out to 119 designated public office holders outlining the 5-year restriction on lobbying that applies to them after they cease to occupy their position. As a general election was held in April 2025, the majority of these letters were sent to those not seeking re-election or not re-elected to inform them of their obligations under the Lobbying Act.

Ways to stay informed

Launched in early 2025, the Office’s LinkedIn page and email distribution list play an important role in expanding our reach and improving proactive communications.

Both platforms allow us to effectively reach stakeholders across Canada, in both official languages. In just over a year, our LinkedIn page grew to nearly 728 followers while our email distribution list has grown to 194 subscribers. The Office regularly publishes content on LinkedIn, including a monthly reminder to submit communication reports. Five messages were also sent to our mailing list subscribers notifying them of new developments, publications and information sessions throughout the year.

Complementing these tools, the Registry of Lobbyists’ search alerts allow users to create alerts based on keywords such as names, subject matter, institutions, and other criteria. Whenever information matching the selected criteria is added to the Registry, a notification is sent. In 2025-26, 489 search alerts were created by 272 unique users, triggering more than 13,956 results. This marked a 28% increase in searches and 12% in users.

New and updated resources

Throughout 2025-26, the Office continued to create or update a variety of resources. In July 2025, the Commissioner issued a new interpretation of the significant part of duties registration threshold for organizations and corporations and a new interpretation bulletin with respect to the five-year restriction on lobbying for former designated public office holders.

In support of the effective date of the new registration threshold and interpretation bulletin, a dedicated landing page, Transparency matters: Know your obligations, was developed to help direct those who had little to no knowledge of the requirements of the federal lobbying framework.

Additionally, in anticipation that more organizations and corporations would need to register, the Office updated its guide on How to register and report your lobbying activities.

Media engagement

The Office of the Commissioner of Lobbying remains committed to providing the media with accurate, appropriate and timely, information regarding Canada’s lobbying regime.

Media inquiries

In 2025–26, the Office responded to 98 media inquiries, a 58% increase over the previous year and the third-highest volume on record, just shy of the 100 inquiries received in 2019-20 and the 102 in 2020-21. Unlike earlier peak years, which were driven by high-profile issues, this year’s activity reflects a broader and more sustained interest in the Office’s mandate.

Notably, 39% (38) of all inquiries focused on the Registry of Lobbyists. These inquiries spanned a range of topics, including assistance with navigating and searching the Registry, requests for data extracts, and clarification regarding the type and scope of information publicly available.

Questions relating to the rules of Canada’s lobbying regime, namely the Lobbying Act and Lobbyists’ Code of Conduct, accounted for 25% (24) of the total number of inquiries. Compliance activities, including investigations, rounded up third place with 14% (14) of the questions received while questions about the statutory review of the Lobbying Act or its related regulations a notable 11% (11).

Overall, the distribution of inquiries highlights continued media interest in both the transparency tools and the regulatory framework supporting Canada’s lobbying regime.

Media interviews

Reinforcing the Office’s commitment to openness and accountability, the Office participated in 12 media interviews which included print, radio, television, multi-media and podcast. Commissioner Bélanger gave 10 media interviews and members of the Office participated in another 2, for a total of 12 media interviews.

Common goals of transparency and accountability

Canada’s long-standing experience in regulating lobbying activities positions the Office well to share its experience and contribute to the discourse around transparency and ethical lobbying of government officials.

Common standards for lobbying transparency and accountability support the development of systems that can strengthen democracies. The ongoing collaboration with provincial and international counterparts provides opportunities to share expertise among participants to help foster effective, accountable, and inclusive institutions at all levels.

Lobbyists Registrars and Commissioners Network

Each year, Commissioner Bélanger and employees of the Office participate in two meetings with the Lobbyists Registrars and Commissioners Network (LRCN) to share best practices and provide updates related to their respective regimes.

This year, the in-person meeting took place in Saint Andrews, New Brunswick from September 29 to October 1, 2025. Members shared information and techniques on reaching lobbyists who may not currently be aware of their respective obligations. Additional topics of discussion included cooling-off periods for former officials, recent legal findings, and a more in-depth exploration of registration thresholds.

Members also agreed that the Office would host the LRCN’s annual virtual meeting going forward. As in previous years, the 2026 annual virtual meeting was held in February.

In addition to the meetings, members of the LRCN issued a joint news release supporting the modernization of the Act proposed by federal Commissioner Bélanger following her appearance before parliamentary committee in relation to the statutory review of the Lobbying Act.

Council on Governmental Ethics Laws (COGEL) 

The Council on Governmental Ethics Laws (COGEL) is a largely U.S.-Canada-based professional organization for government regulators and others working in ethics, elections, freedom of information, lobbying, and campaign finance.

Once again, Commissioner Bélanger provided an update on developments in the Canadian federal lobbying landscape at the virtual roundtable on lobbying held each May.

Organization for Economic Cooperation and Development (OECD) 

The Organisation for Economic Co-operation and Development (OECD) is an international organization that helps governments work together to improve economic and social well being.

In March 2026, the Commissioner and the Office’s Director of Registration, Policy and Public Affairs joined leaders from around the world for the OECD Global Anti-Corruption & Integrity Forum, to discuss matters related to improving and transparency.

They also attended the annual in-person meeting of the OECD Network of Lobbying Regulators which included a presentation by the Commissioner on “Designing effective lobbying registration thresholds: what works, what doesn’t, and why.”

Parliamentary activities

The Commissioner of Lobbying reports to Parliament through the Standing Committee on Access to Information, Privacy and Ethics (ETHI). In 2025-26, Commissioner Bélanger testified before the Committee on two occasions.

Briefing session

First, on October 10, 2025, Commissioner Bélanger was invited to a briefing session with the new ETHI membership. During her testimony, Commissioner Bélanger stated she was pleased to see that the committee intended to study the Lobbying Act, as outlined in the motion passed on September 17 and looked forward to supporting the Committee in this work to identify important legislative and regulatory amendments. The Commissioner also advocated for a new funding process to preserve the independence of Agents of Parliament.

During the meeting, the Committee Chair invited the Commissioner to submit a list of proposed witnesses along with statistics for registration and communication reports for 2015 to 2025, which she promptly submitted to the Committee Clerk in the days following.

Statutory review of the Lobbying Act

On March 9, 2026, the ETHI Committee began its long awaited and long overdue statutory review of the Lobbying Act. Commissioner Bélanger was invited as the first witness to discuss her 21 recommendations for modernizing and improving the Act. At the time, the Commissioner expressed that it was her sincere hope that this study will lead to improvements to the Lobbying Act. During the meeting, the Chair indicated that he expected it may be the will of the Committee to have the Commissioner come back at the end of the study to review what the Committee has heard during the study.

At the time of publishing this annual report, the Committee had held five meetings and heard from 17 witnesses, including provincial lobbying regulators, the OECD and the RCMP.

Return to top of page

A great place to work

In 2025, the Office of the Commissioner of Lobbying was ranked #1 among 85 federal departments and agencies in the Ottawa Citizen’s inaugural Best Public Service Workplaces ranking.

The ranking drew primarily on an analysis of feedback from the 2024 federal Public Service Employee Survey (PSES) and assessed organizations across 10 key performance indicators, including management, health and safety, work life balance, accessibility, and overall employee engagement.

The Ottawa Citizen highlighted the Office’s clear mandate, small and highly engaged workforce, and strong leadership under the Commissioner of Lobbying behind its top rankings. With a staff complement of approximately 33 employees at the time of the survey, the Office achieved a leading overall score of 77.94, the highest among all organizations assessed.

This recognition reflects the shared commitment of employees and leadership to fostering a respectful, supportive, and accountable workplace. It also underscores the Office’s strong organizational culture and its dedication to excellence in advancing its mandate to promote transparency and ethical conduct in federal lobbying for the benefit of Canadians.

Limited resources

The Office’s total budget in 2025-26 was approximately $6.4 million. Roughly $4.9 million went to salaries and benefits, leaving an operating budget of around $1.5 million. About $700 thousand of that operating budget was spent on obtaining services from other federal organizations, including services related to human resources, finances, procurement and information technology.

Unsurprisingly, the Office was not subject to the comprehensive expenditure review given its very small budget. However, the Office is always very mindful of its stewardship of resources. Ever rising costs, including expenses for the information technology, licenses and infrastructure needed to run our Office, are increasingly putting pressure on our budget and limit our flexibility in the allocation of funds.

Additionally, the Office is subject to the same corporate reporting requirements as large departments. However, with only 35 employees, these reports often do not contemplate or account for the size and resource capability of micro-organizations such as ours.

The Commissioner continues to highlight the challenges posed by the current funding model for Agents of Parliament. Currently, the Office is required to seek funding through a ministerial portfolio which undermines its independence. A new funding model that recognizes and reinforces the independence of Agents of Parliament should be considered. Any such new model should remain subject to parliamentary oversight.

Return to top of page

In 2026–27 and beyond, the Office will continue to support good governance and sustain public trust in federal institutions by strengthening Canada’s lobbying regime. Our work will remain focused on ensuring that lobbying activities are carried out transparently, ethically and in compliance with the Lobbying Act and the Lobbyists’ Code of Conduct.

A key priority in the coming year will be supporting Parliament, through the ETHI committee, in its study of the Lobbying Act. We will contribute our expertise and experience to assist parliamentarians in their review of the legislative framework, with a view to ensuring it remains effective, relevant and responsive to evolving expectations around transparency and accountability. Also, we will share possible updates to the Lobbyist Registration Regulations with the Treasury Board Secretariat.

This past year, we have put significant effort into reaching out to current and potential lobbyists and reaching new stakeholders. Building on this, we will continue to support compliance by expanding awareness and understanding of the Act and the Code. This includes plans to update various information resources, including advisory opinions, to simplify and increase clarity for stakeholders.

At the same time, we will maintain a strong compliance and enforcement function. This includes verifying that registrants, lobbyists and former designated public office holders meet their obligations and conducting investigations when necessary to ensure compliance.

We will also continue to look at ways to improve the Registry of Lobbyists, both for those who consult the Registry and for those required to register their lobbying activities.

Internally, we remain committed to remaining a high-performing organization that delivers value to Canadians. We will continue to foster a workplace culture grounded in collaboration, innovation and respect, while supporting employees in developing the skills, knowledge, and engagement needed to achieve excellence.

Return to top of page

Return to top of page