As of January 19, 2026, the threshold for registering as a federal lobbyist has been lowered, affecting organizations that regularly communicate with federal officials, including not-for-profit corporations and charities. The new threshold applies to in-house staff who lobby on behalf of their employer.
The Legislative Framework: When Federal Registration Is Required
The federal Lobbying Act requires an organization to register as lobbyist when certain advocacy activities form a “significant part of the duties” of one or more employees.
Specifically, an organization must file an in‑house lobbying registration when:
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- One or more employees communicate with federal public office holders on behalf of their employer about prescribed subject matters; and
- The communication constitutes a “significant part of the duties” of one employee, whether assessed individually or collectively.
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As of January 19, 2026, there has been a change to the interpretation of the Lobbying Act and what constitutes a “significant part of [an employee’s] duties.”
Who is a Federal Public Office Holder?
Communications with a broad range of federal public officials could trigger lobbying registration requirements. These include communications made on behalf of an organization with:
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- Federal employees, officers, and executives;
- Members of the Armed Forces and RCMP;
- All Parliamentarians – including Members of Parliament, Senators, and Ministers;
- Staff of Parliamentarians;
- Senior executives – Deputy Ministers, CEOs, Associate and Assistant Deputies, etc.; and
- Additional positions set by regulation.
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What Types of Advocacy Require Registration?
Oral and written communications with federal public office holders with respect to the following matters may require registration as a federal lobbyist:
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- Developing legislative proposals;
- Introducing, amending, passing, or defeating bills or resolutions;
- Developing or amending federal regulations, policies or programs; and
- Awarding of federal grants, contributions, or other financial benefits.
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Note that these communications may include research, preparation, meetings, correspondence and social media.
What Types of Communications DO NOT Require Registration?
For in-house employees, communications with federal public office holders with respect to the following matters may not require registration as a federal lobbyist:
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- Awarding of federal contracts;
- Arranging meetings between a federal official and other person;
- Making submissions to parliamentary committees that form part of the public record;
- Enforcing or interpreting legislation as it applies to your respective organization;
- Certain public consultation submissions; and
- Requests for information.
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What Constitutes a “significant part of the duties”? The New “8‑Hour / 4‑Week” Rule
Since 2009, organizations have been operating under a “20% rule” with respect to their “significant duties.” Time spent on federal lobbying would constitute a “significant part” of an employee’s duties if they spent about 20% of their work hours on these activities, equivalent to one (1) full work day per week, or 32 hours per month.
Under the new rule, registration is required when employees collectively spend eight (8) or more hours in any four (4) week period communicating with federal public office holders about specified subject matters listed in the Lobbying Act. Time spent preparing for meetings, drafting correspondence or submissions, and undertaking related grassroots communications on those same subject matters is included in the calculation.
Once the threshold is met, the organization’s most senior paid officer must file an in-house registration return within two (2) months from the date the threshold is met. Organizations must then comply with ongoing reporting requirements.
Key Takeaways for Organizations
Organizations with employees engaged in federal advocacy should:
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- Implement internal practices to track time spent on lobbying activities (including preparation time, such as research and drafting);
- Monitor collective lobbying activity across all employees over rolling four‑week periods; and
- Assess ongoing reporting obligations once registration is triggered.
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Thing to Keep in Mind
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- These rules involve federal advocacy, and do not address advocacy at the provincial or municipal levels, which may be subject to their own respective legislation and registration requirements.
- The federal lobbying registration rules refer to employees that are being paid to advocate to the federal government, not to volunteers undertaking advocacy that is not for the benefit of their employer or client.
- External federal lobbyists, such as consultants who lobby on behalf of an organization, will have their own individual compliance requirements.
- Registered charities are allowed to advocate to the federal government as a “Public Policy Dialogue and Development Activity,” (“PPDDA”) as long as such advocacy furthers the charity’s purposes. The rules governing the political activities of charities have been amended by the Canada Revenue Agency to remove the limits on the resources a charity can devote to PPDDAs. Note, however, that PPDDAs cannot directly or indirectly support or oppose a political party or candidate for public office.
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PooranLaw will continue to monitor the legal implications and impact related to this new rule. In the meantime, if you require legal assistance, we encourage you to reach out to any member of our team.
Note: This article provides general information only and does not constitute, and should not be relied upon as, legal advice or opinion. PooranLaw Professional Corporation holds the copyright to this article and its contents may not be copied or reproduced in any form, in whole or in part, without the express permission of PooranLaw Professional Corporation.
