On July 16, the Office of the Commissioner of Lobbying Canada released a new bulletin, interpreting (or, re-interpreting) the in-house lobbying registration threshold under section 7(1)(b) of the Lobbying Act (Canada). This quiet, yet substantial, change will have a significant impact on organizations and corporations who would not traditionally consider themselves “lobbyists”.
In accordance with section 7(1)(b) of the Lobbying Act, corporations and organizations are required to register themselves with the Office of the Commissioner of Lobbying of Canada (OCLC) if their lobbying duties conducted “constitute a significant part of the duties of one employee if [the lobbying duties] were performed by only one employee.”
The key determination of which organizations and corporations are captured under this provision turns on the interpretation of a “significant part of the duties.” Since 2009, a “significant part of the duties” was interpreted to mean 20% of an employee’s working hours. This interpretation, known as the “20% rule,” allowed organizations and corporations to engage in up to 32 hours of lobbying activities over 4 weeks, without needing to register with the OCLC.
The Commissioner further clarifies that the eight hours are inclusive of all time spent on lobbying activities, including matters such as researching, drafting and editing written communication. It is not limited to face to face meetings with public office holders.
However, as of January 19, 2026, the “20% rule” will no longer be in effect. The original 32-hour allowance will be quartered, restricting corporations and organizations to 8 hours of lobbying activities, over 4 weeks, before requiring registration with the OCLC.
The effect of this new interpretation will be to capture a considerably larger number of organizations and corporations under lobbyist registration. As such, all organizations and corporations engaging in even minimal lobbying activities must be aware of this change, as the implications for failing to adequately register with the OCLC can be severe. Offences for failing to comply with the registration requirements range from fines of between $50,000 and $200,000 to terms of imprisonment between six months and two years. This change will potentially affect hundreds or thousands of non-profits and charities in Canada.
It will be interesting to see if this change actually goes forward, but one of the good things about this change is that it will make it much easier for many groups to decide that they need to register. Unfortunately, many groups had miscalculated and misapplied the 32-hour rule, and it meant that groups doing substantial lobbying with staff were not registering. For example, they may have just calculated it based on the actual meetings and not the preparatory work. It will be harder for those groups to argue that they can avoid registering.
Perhaps more importantly, many groups are not aware of their obligations to register at all, and this will be a good reminder for those groups that they need to keep track of their time and potentially register.
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If your non-profit or charity has questions about registration, you may be able to retain our law firm and we can discuss them.
Here is a copy of the advice and direction:
Significant part of duties registration threshold for organizations and corporations
Effective date
This interpretation bulletin takes effect on January 19, 2026.
Read the backgrounder.
The purpose of this bulletin is to describe how the Commissioner of Lobbying interprets and applies the significant part of duties registration threshold set out in paragraph 7(1)(b) of the Lobbying Act (Act).
The elements of subsection 7(1) of the Act
The Act requires the officer responsible for filing returns of an organization or a corporation (the most senior paid officer) to file an in-house registration in the Registry of Lobbyists when:
- one or more employees of the organization or corporation communicate with public office holders on behalf of their employer about any of the matters listed in paragraph 7(1)(a); and
- engaging in such communications constitutes, either individually or collectively, a “significant part of the duties” of one employee within the meaning of paragraph 7(1)(b).
Matters referred to in paragraph 7(1)(a)
Communications that employees have with public office holders on behalf of their employers about any of the following matters count towards the significant part of duties registration threshold:
- the development of any legislative proposal by the Government of Canada or by a member of either the Senate or House of Commons;
- the introduction, passage, defeat or amendment of any Bill or resolution in the Senate or the House of Commons;
- the making or amendment of any federal regulation;
- the development or amendment of any federal government policy or program; and
- the awarding of any grant, contribution or other financial benefit by or on behalf of the Government of Canada.
Please note that paragraph 7(1)(a) does not apply to any communications that employees have with public office holders on behalf of their employer about the awarding of a contract by or on behalf of the Government of Canada. As a result, such communications do not count towards the significant part of duties registration threshold.
The significant part of duties registration threshold set out in paragraph 7(1)(b)
The Commissioner of Lobbying interprets the term “significant” as used in the phrase “significant part of the duties” to mean a “notable” or “noteworthy” part of an employee’s duties.
In practice, the Commissioner of Lobbying considers the significant part of duties registration threshold to be met when the total volume of communications that one or more employees of an organization or corporation have with public office holders about any of the matters listed in paragraph 7(1)(a) amounts to 8 or more hours in any given consecutive 4-week period.
In determining whether this registration threshold is met, the Commissioner of Lobbying considers the number of hours employees spend preparing for and participating in oral communications with public office holders as well as drafting written communications to public office holders about any of the subject matters listed in paragraph 7(1)(a). The time employees spend making appeals to the public (i.e., grassroots communications) about any of those same subject matters also counts towards the registration threshold.
When determining whether this threshold has been met, the Commissioner of Lobbying considers the total number of hours of oral and written communications that employees have with public office holders about any of the subject matters listed in paragraph 7(1)(a) in any given consecutive 4-week period.
For example, the significant part of duties registration threshold would be met and the most senior paid officer would be required to file an in-house registration in the Registry of Lobbyists if, between January 16 and February 12:
- one employee spends 3 hours drafting a letter sent to a public office holder (3 hours)
- one employee spends 2 hours drafting and another employee spends 1 hour editing and finalizing an information package that is provided to the public office holder (3 hours)
- four employees each spend 30 minutes in a face-to-face meeting with a public office holder (2 hours).
The most senior paid officer has two months from the date the significant part of duties registration threshold is met to file an in-house organization or corporation registration return in the Registry of Lobbyists.
Ask the Office of the Commissioner of Lobbying
Contact our Office if you have any questions about whether your organization or corporation meets the significant part of duties registration threshold.
Nancy Bélanger
Commissioner of LobbyingJuly 16, 2025
Effective January 19, 2026