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As governments across Canada assess the geopolitical and economic landscape, and reshape policy in critical areas, now is the time for stakeholders to be heard. Whether your organization is engaging federal or provincial officials on funding, advocating on regulatory reform, or infrastructure priorities, effective government advocacy has never mattered more. Just as important, however, is ensuring that your advocacy is conducted with full awareness of your compliance obligations under lobbying regimes at the federal, provincial, and municipal levels of government.
At Gowling WLG, our Government Affairs team, supported by our dedicated and experienced Lobbying Compliance Unit, provides strategic guidance and practical support to ensure your organization remains compliant while engaging with government. With deep expertise in lobbying laws across federal, provincial, and municipal jurisdictions, we are well-positioned to assist you across all aspects of your advocacy initiatives—from registration and reporting obligations to navigating complex legislative frameworks and managing regulatory inquiries or investigations.
Compliance can't be an afterthought
Compliance must be a key pillar of your advocacy planning and cannot be a post-campaign consideration.
As Canada's lobbying compliance frameworks evolve, it is critical for organizations to understand that regulations are not static, and penalties for non-compliance can be significant. Faling to comply with legal requirements can result in significant reputational harms, considerable financial penalties, and even criminal penalties such as imprisonment.
Recent developments from Canada's lobbying and ethics regulators highlight the fluid nature of Canada's legislative framework for lobbying. In particular, changes to the interpretation of registration thresholds will soon affect how organizations assess their duties.
New guidance on the federal "Significant Part of Duties" threshold – Effective January 19, 2026
On October 10, 2025, the federal Office of the Commissioner of Lobbying ("OCL") released updated guidance for the in-house lobbyist registration threshold, which is assessed using the "significant part of duties" threshold. This test determines whether an organization or corporation must register its lobbying activities federally when lobbying federal public office holders.
Historically, the OCL has used a cumulative "20% of duties" threshold, meaning that registration is required if the collective lobbying activities of all employees (including preparation time and strategic discussions) add up to 20% of a single full-time employee's time over a monthly period.
Starting January 19, 2026, the OCL will apply a new method for calculating this threshold. Registration will now be required when lobbying communications, including both written and oral exchanges, as well as related preparation time, total eight or more hours within any consecutive four-week period. The threshold applies collectively to all employees of the organization or corporation. Importantly, activities such as drafting letters, preparing information packages, and participating in meetings with public office holders all count toward the threshold, as do appeals to the public to lobby public office holders (grassroots communications). In the case of grassroots communications, included in the calculation of "significant part of the duties" are activities such as directing a campaign, making decisions about the message of the campaign, and making decisions about the techniques to be used in the campaign, as opposed to administrative work such as photocopying or website maintenance.
These changes mean that even organizations with occasional lobbying efforts will likely be required to register federally, depending on how internal resources are allocated.
Gifts, hospitality & sponsorship: Key compliance considerations
Organizations often hope to engage with public office holders through receptions, sponsorships, or holiday season outreach. As organizations seek meaningful ways to engage with public office holders, it is essential to understand the legal boundaries surrounding gifts, hospitality, and sponsorship across all levels of government.
Across federal, provincial, and municipal jurisdictions, there are strict rules and ethical codes governing what can be offered to public office holders, including:
- Limits on gifts and tokens of appreciation
- Restrictions on hospitality, including meals, event invitations, and sponsored activities
- Varying requirements around sponsorship of conferences, events, or community initiatives where public office holders are in attendance or participating
These rules are not uniform across jurisdictions, and what is permissible in one context may be prohibited in another. With the end of the calendar year approaching, when engagement of this kind often increases, it is more important than ever to ensure that your interactions are compliant with the applicable regulations and codes of conduct to avoid potential penalties.
With new guidance set to come into force in early 2026 and significant policy changes underway across Canada, now is the time to assess your organization's lobbying practices and compliance framework.
How we help
At Gowling WLG, our Lobbying Compliance Unit combines legal, political, and regulatory expertise, backed by decades of experience working at the intersection of advocacy, law and public policy. This experience is grounded in a nuanced understanding of Canada's complex and evolving lobbying rules, enabling us to assist with every aspect of your compliance planning, including:
- Internal audits to assess lobbying undertakings and existing compliance posture
- Strategic advice and ongoing maintenance of registration and reporting practices
- Development of lobbying policies and internal compliance protocols
- Training for staff involved in government advocacy on lobbying legislation and codes of conduct
- Reporting requirements pertaining to Designated Public Office Holders
- Representation during regulatory reviews or investigations
- Direct advocacy before public office holders
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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
