Federal Lobbying Registration Rules Update

June 30, 2026

Advocacy Alert - Sent June 30, 2026

Federal Lobbying Registration Rules

The Federal Lobbying Regulations saw a number of changes come into effect on January 19, 2026, and over that period PACT has provided updates and events to ensure its members have updated information to remain in compliance. We are writing to share an important update on federal lobbying registration rules and how they may apply to theatre organizations that prepare and submit federal grant applications.

PAA recently sought clarification from the Office of the Commissioner of Lobbying on whether this work may count toward the federal lobbying registration threshold. This is particularly relevant for: organizations applying to programs through the Department of Canadian Heritage, the Canada Council for the Arts, or other federal departments, agencies, or Crown entities.

Based on the response received, communications related to the awarding of a federal grant, contribution, or other financial benefit may be considered a lobbying activity under the Lobbying Act. This can include applications submitted through formal program streams or online portals.

The Office of the Commissioner of Lobbying has also confirmed that time spent preparing for these communications is included in the calculation of the registration threshold. In practical terms, this means that time spent drafting application materials, developing budgets, preparing supporting documentation, coordinating internal inputs, and finalizing submissions may count toward the threshold.

Under the current interpretation, an organization may be required to register if its employees collectively spend eight or more hours on federal lobbying activities within a consecutive four-week period, since January 19, 2026. This threshold is cumulative across employees. For example, if two staff members each spend four hours preparing a federal grant application, the organization may meet the threshold. The time spent preparing reports on federal grants do not constitute lobbying activities.

If the threshold is met, the registration obligation rests with the organization’s responsible officer, generally the most senior paid employee, such as the Executive Director, CEO, General Manager, or equivalent position. The registration is filed on behalf of the organization; individual employees do not register separately.

Members who believe they may meet the threshold should review the registration requirements and consider whether they need to file an in-house lobbying registration. PACT also encourages members to begin tracking staff time spent preparing and submitting federal grant applications.

Information on how to register is available through the Office of the Commissioner of Lobbying website: How to register and report your lobbying activities; | Office of the Commissioner of Lobbying of Canada

The Lobbyists Registration System sign-in and account creation page is available here: Sign in - Lobbyists Registration System - Office of the Commissioner of Lobbying of Canada

According to the Office of the Commissioner of Lobbying, for organizations and corporations that employ individuals who lobby, the most senior paid officer is required to create an account. An in-house registration is required within two months of reaching the significant part of duties threshold.

FOR YOUR CONSIDERATION

Members should also be aware that the Lobbying Act is currently under statutory review. As part of that process, the Commissioner of Lobbying has recommended that the Act be amended to exclude certain communications about grants, contributions, and other financial benefits where the funding is below a defined monetary threshold, or where it is awarded through an established and transparent process or recurring operational funding model.

This recommendation is highly relevant to the theatre sector, where many organizations apply for federal support through recurring, transparent, and program-based funding streams. However, until the Act is amended or further guidance is issued, members should treat this as a live compliance issue.

This update is intended to provide general information to PACT members and should not be taken as legal advice. Organizations should assess their own circumstances and seek appropriate advice where needed.

PAA will continue to monitor this issue and provide further updates as more information becomes available.

PACT Members who have questions can reach out to Brad Lepp, Executive Director, at BradL@PACT.ca. 

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