LobbyComply Blog

Beginning on April 1 and lasting until September 30, 2026, unregistered lobbyists will not face fines for certain violations of British Columbia’s Lobbyists Transparency Act. One of the main goals of the  “temporary fine freeze” is to encourage currently unregistered lobbyists and organizations to register with the province’s Office of the Registrar of Lobbyists. In order to avail oneself of this freeze, a person or organization must not have previously received a fine from the registrar’s office, not have been registered since May 4, 2020, and must be forthcoming with the registrar’s staff about all required information to be submitted into the registry. This freeze does not apply to violations related to the prohibition on lobbying by former public office holders or for previous lobbying performed in connection with a contract for providing paid advice to the government of British Columbia or another provincial entity. The fine freeze is not available to registered lobbyists, to unregistered lobbyists that the registrar believes may have committed flagrant violations of the law, or to unregistered lobbyists attempting to use the temporary fine freeze to delay or obscure transparency.

On March 9, the Commissioner of Lobbying of Canada, Nancy Bélanger, presented recommendations to lawmakers concerning the country’s lobbying laws and regulations. Bélanger appeared before the Standing Committee on Access to Information, Privacy and Ethics (ETHI) of the Canadian House of Commons. Among Bélanger’s recommendations are clarification of who qualifies as in-house lobbyists; disclosure of all employees who lobby for their employer; disclosure of all funding provided to support lobbying activities; and disclosure of all entities that control and have a direct interest in the outcome of the lobbying. On February 12, the Canadian House of Commons had ordered ETHI to review the nation’s lobbying law. The law itself requires a comprehensive review of the provisions and operations of the law to be taken every five years. Within a year after the committee’s review is undertaken, the ETHI must submit a report on the review to parliament that includes a statement of any changes to the Lobbying Act or its operation that the committee recommends.

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By-elections will be held on April 13 in the electoral districts of Scarborough Southwest (Ontario), Terrebonne (Quebec) and University–Rosedale (Ontario) to fill vacancies in the House of Commons. On March 8, Canadian Prime Minister Mark Carney called for the special elections for the three districts, which are all currently vacant. Former Minister of Finance and Deputy Prime minister of Canada, Chrystia Freeland, resigned her seat representing the University–Rosedale riding in January in order to become the Warden of Rhodes House and CEO of the Rhodes Trust, which is best known for granting the Rhodes Scholarship. In February, MP Bill Blair resigned his seat representing Scarborough Southwest  to become the Canadian High Commissioner to the United Kingdom. A by-election for Terrebonne is being held after the riding’s result in the 2025 general election was annulled by the Supreme Court of Canada in February due to a printing error on the return envelopes used for mail-in ballots. The Elections Canada offices are now open in the three electoral districts.

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Sometime before July 8, 2026, a by-election will be announced for the seat in the House of Commons representing University–Rosedale in the province of Ontario. On January 9, the Chief Electoral Officer of Canada, Stéphane Perrault, received official notice from the Speaker of the House of Commons that the seat for University–Rosedale (Ontario) became vacant on January 9, following the resignation of Chrystia Freeland. Freeland left her seat in order to become the Warden of Rhodes House and CEO of the Rhodes Trust, which is best known for granting the Rhodes Scholarship. Under the law, the by-election date must be announced by July 8 and will signal the start of the by-election period. According to Elections Canada, the earliest date the by-election can be held is March 2, 2026.

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On October 27,  Attorney General Doug Downey announced comprehensive proposals to change Ontario’s dates of elections, increase its political contribution limits, eliminate pre-writ spending limits for third parties, and alter other provincial campaign finance laws.

The reforms, announced in a news release by the government of Ontario, would eliminate “American-style fixed election dates” in favor of provincial elections taking place on a date determined by the lieutenant governor on the advice of the premier, but within the five-year maximum limit mandated by the province’s constitution.

Beginning in 2026, individuals’ contribution limits to a political party would be raised from $3,400 to $5,000. Future increases would be indexed to the rate of inflation.

In addition to eliminating third party and political party pre-writ spending limits, the government proposes establishing new financial penalties for those not in compliance with the Election Finances Act.

The amendments to the law would also provide new investigative powers to the Chief Electoral Officer to request information from third parties to ensure they are in compliance with political advertising rules. The proposed changes to the law also include requiring third parties to provide proof of registration status to broadcasters and publishers before placing political advertisements during an election period. 

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On August 12, by-elections will be held for District 9 (Charlottetown-Hillsborough Park) and District 15 (Brackley-Hunter RiverPark) for the Legislative Assembly of Prince Edward Island.

In District 9, the by-election was called because of the resignation of MLA Natalie Jameson, who resigned on February 11. Jameson will be the Conservative Party of Canada’s candidate for Charlottetown in the next federal election.

In District 15, the by-election was called because of the resignation of Premier Dennis King, who resigned on February 21. King has indicated he no longer wished to remain in politics.

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Beginning January 19, 2026, the Canadian federal lobbyist registration threshold for organizations and corporations will be lowered. On July 16, the Office of the Commissioner of Lobbying of Canada issued new interpretation bulletins concerning the “significant part of the duties” threshold for when organizations and corporations must be registered under the Lobbying Act.

One bulletin lowers the lobbyist registration threshold from the current 32 hours per month to 8 hours in a rolling four-week period.

A second updated interpretation addresses the Lobbying Act’s revolving door provision and interprets a significant part of a designated public office holder’s work as 8 hours or more in any given consecutive four-week period. This would include any time spent preparing for and participating in oral communications with public office holders as well as drafting written communications to public office holders.

An additional bulletin addressing the transitional period for former designated public office holders employed by corporations was also issued.

The commissioner believes these interpretations are consistent with the Lobbying Act.

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Beginning on July 14, a new federal procurement policy regarding foreign vendors took effect.

The new policy requires all new non-defense procurements over $10,000 involving an open competition by or on behalf of any federal department or agency of Canada by a foreign supplier be limited to whether the solicitation is subject to a trade agreement between Canada and the supplier’s jurisdiction. If a supplier is from a jurisdiction that does not have a trade agreement with Canada and applies to a procurement process, it will no longer be eligible to compete, with limited exceptions. Canadian suppliers will continue to be eligible to compete for all federal procurement opportunities.

The Treasury Board of Canada Secretariat issued a Contracting Policy Notice on July 10 regarding the policy, entitled the Interim Policy on Reciprocal Procurement, for all departments and agencies that have delegated authority for procurement from the Minister responsible for Public Services and Procurement Canada.

Contracts and solicitations posted prior to July 14 are not subject to this new rule

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On August 11, a by-election will be held in the electoral division of Arthabaska, in the Centre-du-Québec region, for a seat in the province’s National Assembly of Quebec. MNA Éric Lefebvre had resigned on March 18 to run with the Conservative Party of Canada for the federal riding of Richmond-Arthabaska (Quebec) for a seat in the Canadian House of Commons.

Under a decree issued by the Government of Québec on July 8, the Chief Electoral Officer, Mr. Jean-François Blanchet, will oversee the organization of the election. Advance polling for voting will begin on August 3.

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On June 30, Canada’s Prime Minister Mark Carney announced a federal by-election will be held on August 18 for the electoral district of Battle River-Crowfoot in Alberta.

Earlier this month, the Chief Electoral Officer of Canada, Stéphane Perrault, had received official notice from the Speaker of the House of Commons that the seat was vacant. MP Damien Kurek had resigned in order to allow Pierre Poilievre to run for his place in the House of Commons.

Perrault’s announcement of the vacancy, made on June 18, signaled the start of the election period.

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Commissioner of Lobbying Nancy Bélanger has submitted to the Parliament of Canada her annual report for 2024-25. The report highlights the Office of the Commissioner of Lobbying’s ongoing efforts to support transparency in lobbying at the federal level in Canada.

The report details information about lobbying registration and compliance activities. Additionally, the commissioner repeats her intention to issue a new interpretation in 2025 with respect to the registration threshold by employees of organizations and corporations. A new interpretation will also be issued regarding the five-year restriction on lobbying for individuals ceasing to be designated public office holders.

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Beginning on January 1, 2026, third parties running partisan election advertisements will have to register with Quebec’s Chief Electoral Officer. On May 30, Quebec’s Bill 98, the Act to Amend the Election Act Primarily to Preserve the Integrity of the Electoral Process, received royal assent.

Third party advertisers with expenses totaling more than $1,000 will have to register with the Chief Electoral Officer by sending a notice of intent. Following the election, they will have to submit a statement of their advertising expenses. The public will be able to view a list of registered third parties and their statements on the Elections Québec website.

The bill also changes political party activity reporting, imposes an obligation to destroy personal information relating to voters in certain circumstances, and makes it an offence for anyone disseminating certain information that they know to be false with the intent to influence the results of an election, disrupt its conduct, or compromise public confidence in the electoral process.

New changes in the legislation will be in effect by October 5, 2026, the date of Quebec’s next scheduled provincial elections.

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On May 27, the Office of the Registrar of Lobbyists for British Columbia released updates for several of its guidance documents to reflect the changes to the Lobbyists Transparency Act’s (LTA) filing requirements brought in by the Miscellaneous Statutes Amendment Act, 2024, which came into force on the same day.

One updated guidance, Government Funding, is intended to help lobbyists understand what is meant by the term government funding and the associated reporting obligations.

A guidance previously called Coalitions is now entitled Working Together for the Purpose of Lobbying. It outlines the reporting requirements under the LTA. It outlines designated filers’ obligations to report the name and business address of any other client or organization with whom they work for the purpose of lobbying and who has a direct interest in the outcome of the lobbying activities. When a consultant lobbyist or an organization ceases lobbying, a designated filer has 30 days after the month in which lobbying stops to end their registration return in the registry.

Other released guidance documents include Sample Questionnaire for Consultant Lobbyists’ Clients, Sample Questionnaire for Organizations that are Lobbying, Non-Profit Organizations, Getting Started – Reference Guide, Registration Returns – New and Reactivations, Monthly Returns – Registration Return Updates and Lobbying Activity Reports, Quick Reference Guide for Representatives, and Funding Returns.

On May 27, 2025, Elections Canada published the updated limits on expenses for regulated activities of third parties involved in federal elections in Canada. The Canada Elections Act imposes a limit on expenses a third party can incur for regulated political activities.

For an election called on or after April 1, 2025, and before April 1, 2026 , a third party is prohibited from incurring overall election advertising expenses of a total amount of more than $617,400 during a general election. The previous limit was $602,700. For the same period of April 1, 2025, to March 31, 2026, a third party is prohibited from incurring election advertising expenses in a given electoral district of a total amount of more than $5,292 during a general election. The previous limit was $5,166.

Adjustments are made annually based on a formula of a base amount multiplied by the inflation adjustment factor in effect for the period.

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