Small Business Resources | CFIB

New Federal Lobbying Registry Rules Might Consider You a Lobbyist

Written by Business Resource Advisor | Mar 27, 2026 5:51:21 PM

As of January 19, 2026, interpretations under the Lobbying Act lower the threshold to register as a “federal lobbyist” from 32 hours to 8 hours of “lobbying activity” in any four-week period across all employees combined. This means many more businesses will now be required to register and report their lobbying activities. 

Lobbying activity can include preparing a letter to your federal Member of Parliament (MP), applying for a federal grant or contribution, or meeting with federal government officials on behalf of your business. Determining what counts toward the 8-hour threshold can be tricky, so we have provided more details and examples below. 

Non-compliance can lead to monitoring and investigation. Failing to comply can lead to court-imposed fines up to $200,000, up to two years in prison, and a ban on lobbying for up to two years following successful prosecution.  

Is Your Business Lobbying the Federal Government? 

According to the Act and its interpretations, registration to the federal lobby registry is required when: 

  • One or more persons employed by the business, and 
  • Collectively spending 8 hours or more in any four consecutive weeks  on communication with a “federal public office holders” about “lobbying activities” such as:
    • Making, developing or amending federal legislative proposals, bills or resolutions, regulations, policies or programs,
    • The awarding of a federal grant, contribution, or other financial benefits, and/or
    • Meetings with a federal public office holder to influence policy or financial decisions relating to the business. 

If you’re unsure, call the Office of the Commissioner of Lobbying at 613-957-2760. 

Note: Consultants are paid third parties who lobby on behalf of a client. They communicate with public office holders on behalf of their clients. They must register once an agreement is made to take on any lobby activity which can also include advocating for federal government contracts or procurement opportunities, or arranging meetings with public office holders for their clients. 

Who is a Federal Public Office holder? 

A federal public office holder is anyone who works for the Government of Canada, either elected, employed or appointed. This includes senators, members of Parliament, ministerial staff, deputy ministers, assistant deputy ministers and other senior officials. It also includes members of the Canadian Armed Forces, the RCMP and federal government employees. 

What Activities Count Toward the 8-hour Registration Threshold? 

If you or your employees spend a combined 8 hours or more in any four consecutive weeks preparing to or communicating with “federal public office holders” about influencing legislation, regulations, policies, programs, or the awarding of grants, contributions or other financial benefits, then you have met the “significant part of the duties threshold” and must register. The time is aggregated across all employees

What counts as lobbying? What does NOT count as lobbying?
Activities contributing to asking federal officials for a change in proposals, bills or resolutions, regulations, policies or programs. This would include preparing briefing notes, talking points, writing emails, or letters. 

Developing policy positions before contacting government 

Strategy meetings related to influencing federal decisions 

Meeting by phone, video or in person 

Preparing and applying for a federal grant, contribution, or fully non-repayable loan 

Submissions & Consultations to government officials unless the Office of the Commissioner of Lobbying confirms the process qualifies as truly transparent Creating campaigns, websites, or social media content encouraging the public to contact the federal government. (Grassroots communication) 
Communications made to a public office holder that are restricted to Requests for Information (e.g., Letters to MP for clarification on existing programs and processes and calling call centers to determine the status of an application) 

Communications with a public office holder concerning the enforcement, interpretation or the application of any Act of Parliament or regulation, without proposing or requesting any changes. 

Submissions to parliamentary committees 

Press releases not encouraging public pressure on government
Common Situations Where Businesses May Not Realize They Must Register 

Example 1) Seeking Intervention of Elected or Senior Federal Officials 

Two co-owners each spend 1 hour communicating with a federal official about the development of a new program or the implementation of a new policy that would improve available grants to small business owners. The co-owners spent 3 hours each preparing for this meeting.

Why it counts: 
They are trying to influence a federal regulatory decision. Research, drafting, and preparation all count toward the eight-hour threshold. 

Example 2) Applying for the Canada Summer Jobs Wage Subsidy 

A business takes 8 hours to complete their Canada Summer Jobs Wage Subsidy application. They submit this online and speak to no government representatives throughout this process. 

Why it counts: 
Federal grant and contribution applications count toward lobbying activities even without direct communication. 

Who must register? 

The responsibility to register falls on the most senior paid employee of the corporation (e.g., CEO or President). They must register the business and the list of the names of the employees lobbying in-house within 2 months from the day they first meet the requirement to register.  

If your business has board directors that are not employees, their registration requirements depend on whether they are paid for their work. To be certain about this situation, please reach out to the Office of the Commissioner of Lobbying. 

Where and how to register? 
  1. Create an account on the Registry of Lobbyists portal
  2. Submit a registration:
    1. Consultant lobbyists: within 10 days of agreeing to lobby
    2. In-house lobbyists: within 2 months of reaching the registration threshold
  3. Keep your registration up to date and file communication reports monthly when required. 

Check out the OCL’s guide to registering and give them a call if you have any questions or concerns at 613-957-2760. 

Once registered, what activities need to be reported? 

Once you are registered, you only need to report oral and pre-arranged conversations you have with a designated public office holder when the discussion is about something covered by the Lobbying Act. These reports are due by the fifteenth of the next month. If the federal public office holder is the one who reaches out to you to talk about legislation, regulations, policies, or programs, you do not need to file a communication report. You just need to make sure that topic is included in your registration. However, if the discussion involves a grant, contribution, or any other financial benefit, then a communication report is required for organizations and corporations. 

Still confused? Where to Get Help 

If you are unsure whether your business needs to register or how your time should be counted, the Office of the Commissioner of Lobbying can help. They also offer guidance, information sessions, and allow you to subscribe for updates. 

Phone: 613-957-2760 
Email: info@lobbycanada.gc.ca 
Website: lobbycanada.gc.ca  
WebTool: Are you required to register in the federal registry of lobbyists?  

The contents of this page have been reviewed and verified by the Office of the Commissioner of Lobbying.