Are You Now a Lobbyist? Understanding Canada’s Expanded Registration Requirements

By: Stewart Maier

In July 2025, the Office of the Commissioner of Lobbying of Canada (“OCL”) released a significant interpretation bulletin that materially alters the registration threshold requirements under the federal Lobbying Act (the “Act”).

With implementation scheduled for January 19, 2026, this change represents the most substantial expansion of federal lobbying registration requirements in recent years. The new threshold for mandatory registration under the Act for organizations will drop from the prior 32-hour monthly benchmark, to a cumulative 8 hours of lobbying activity within any rolling four-week period. This adjustment pulls far more organizations and corporations into the Act’s registration regime, with the effect that many parties not previously considered “lobbyists” will now be required to register for the first time.

This post examines the scope of these changes, identifies which activities now trigger registration requirements, and outlines the compliance implications for organizations.

Registration Under the Act

Under the Act, registration is mandated when the combined lobbying activities of employees of an organization constitute a “significant part of duties” of one employee, or when such activities are performed in aggregate by multiple employees and collectively constitute a significant part of one employee's duties. The OCL's previous interpretation provided that "significant part of duties" meant approximately 20% of one employee’s time in a calendar month, calculated as 32 hours based on a standard work month. 

Under s. 7 of the Act, the OCL maintains a publicly available registry of all organizations participating in lobbying within the Canadian federal government.

Pursuant to the Act, an organization is considered to be participating in lobbying if it has at least one employee whose duties include communications (oral or written) with a public office holder in respect of:

• the development of any legislative proposal by or within the Federal Government;

• the introduction, passage, defeat or amendment of Bills within the Houses of Parliament;

• the making or amendment of regulations;

• the development or amendment of federal programs and policies; or

• the awarding of grants, contributions or financial benefits by the federal government.

For purposes of calculating whether the threshold has been met, the OCL considers the following time to constitute lobbying activities under the Act:

• the full duration of communications with public office holders;

• time spent preparing, drafting, revising, or sending written communications; and

• time organizing campaigns to the public with respect to the above subject matter (for example, public newsletter communications, urging the public to contact public officials).

All such time is aggregated to determine whether the threshold has been met, regardless of whether the activities are performed by one employee or distributed among multiple employees of the organization. Preparation time, drafting letters or briefs and public campaigns aimed at influencing public officials all count towards the threshold.

Hours are aggregated across all of an organization's employees rather than calculated individually. For example, if Employee A spends 4 hours and Employee B spends 4 hours on lobbying activities within the same rolling four-week period, the organization has met the 8-hour threshold and must register within two months, even though neither individual employee reached 8 hours.

Organizations are required to file a single registration with the OCL (through the most senior paid officer) once their team's collective time meets the registration threshold. If an organization retains external consultants, law firms, or government relations firms to lobby on its behalf, those external lobbyists must file their own individual registrations.

It’s important to note that people who lobby on a voluntary basis are not required to register and private citizens and volunteers (people who are not paid to make communications) are not considered lobbyists under the Act.

Registration and Reporting Requirements

Registration with the OCL is filed by organization’s most-senior paid officer within two months of hitting the “significant part of duties” threshold. The registration contains the organization’s identifying details, summary of lobbying activities, the names of employees who conduct lobby activities, the subject matter of lobbying communications, and any former public office holder information for any listed employees.

Once registered with the OCL, organizations are also required to file a monthly return to the OCL which discloses lobbying communications that occurred in the prior month.

Per the OCL’s news release, the intention behind the new reporting threshold is to increase transparency, as “the previous interpretation allowed a considerable amount of lobbying by in-house lobbyists to go unregistered, thereby reducing transparency.” The OCL expects these new changes to result in a significant increase in the number of registered lobbyists.

Impact on Organizations and Next Steps

Under the new interpretation, organizations previously exempt under the 32-hour monthly benchmark will now trigger registration with the OCL if their collective lobbying activities reach 8 hours in any four-week period, significantly expanding the scope of entities subject to federal lobbying registration requirements.

The practical effect of the OCL’s new interpretation is that more ordinary government-relations activity will now tip organizations into the federal registry. The number of active registrations and lobbyists under the Act is actively growing each year. During 2024–2025, approximately 8,000 individual lobbyists were registered under the Act (consultant and in-house) across approximately 1,500 organizations at any given time. The new registration thresholds will likely result in thousands more registrants under the Act. Many mid-sized entities, associations and non-profits that interact with federal public office holders, even intermittently, will likely cross the 8-hour threshold through a mix of preparation time, meetings, written communications and advocacy activities that constitute lobbying.

For newly qualifying organizations, these changes will impose immediate and significant compliance obligations. Organizations should look to conduct an audit of their government relations activities to determine whether they will meet the new thresholds, implement appropriate time-tracking mechanisms, and designate responsible individuals for compliance with registration and reporting obligations under the Act. The penalties for failure to comply with registration and reporting obligations under the Act can result in significant statutory penalties.

The OCL's shift to an 8-hour threshold represents the most significant expansion of Canada's federal lobbying registration regime in recent years. Previously exempt organizations should begin preparing immediately for the January 19, 2026, implementation date.