The New "Significant": Lower Federal Threshold Will Require More Businesses And Organizations To Register In-House Lobbyists

Beginning January 19, 2026, it will take a lot less for a business or organization to trigger the federal lobbying registration requirement in Canada. The Commissioner of Lobbying of Canada has released new guidance that significantly lowers the threshold for when businesses and organizations must register their in-house lobbying activities.¹

If your staff collectively spends 8 hours on lobbying activities in any given consecutive 4-week period, your corporation or organization will have to register its federal lobbying activities, and meet ongoing reporting requirements.

Below, we break down the new "significant part of duties" threshold and how it will affect businesses and organizations that communicate with federal public office holders.

Registration is required when lobbying is a "significant part" of duties

Under the Lobbying Act (the "Act"), corporations and organizations (profit or non-profit corporations, community groups, industry associations, etc.) are required to register their in-house lobbying activities when:

1. one or more employees of the organization or corporation communicate with public office holders on behalf of their employer about:
   • 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;² and
2. engaging in such communications constitutes, either individually or collectively, a "significant part of the duties" of one employee.³

The old significant: the 20% rule

Since 2009, corporations and organizations have been operating under the "20% rule" to understand what constitutes a "significant part of duties": if any employee spent about 20% of their work hours—roughly one full work day per week, or 32 hours per month—on lobbying, their time would count as a "significant part" of their duties.

As of January 19, 2026, this rule will no longer be in effect.

The new significant: the "8-4" rule

On July 16, 2025, the Commissioner issued an interpretation bulletin which offers a new interpretation of the "significant part of duties" threshold, citing a greater need for transparency of the federal lobbying regime following the Commissioner's 2021 report on recommended changes to the Act,⁴ which we wrote about here.

Registration will now be required if employees, collectively, spend 8 or more hours lobbying (within the meaning of the Act, as set out above) in any 4-week period.

For example, the "significant part of duties" registration threshold will be met when, between January 16 and February 12, or May 1 and May 31:

1. one employee spends 3 hours drafting a letter sent to a public office holder (3 hours);
2. one employee spends 2 hours editing that letter and another employee spends 1 hour drafting an information package that is sent to the public office holder (3 hours); and
3. two employees each spend 1 hour in a face-to-face meeting with a public office holder (2 hours).

The bottom line

The Commissioner's latest guidance will undoubtedly bring a swath of new businesses and organizations under the purview of the federal lobbying regime. It is important for entities to understand, and comply with, their legal obligations under the Act to avoid criminal and quasi-criminal investigation, regulatory penalties, administrative headaches, and reputational risks.

Now is the time to think strategically about your employees' interactions with federal public office holders. For example, tracking time in a more standardized way will allow you to more efficiently deploy hours spent on preparing for and participating in oral communications with public office holders, drafting materials, and grassroots communications to the public, by creating internal logs to monitor all lobbying‑related activities. Refreshing education of staff on the types of activities that qualify as lobbying, and when and how to know the registration threshold has been met, is also timely

Footnotes

1 Office of the Commissioner of Lobbying of Canada, "Significant part of duties registration threshold for organizations and corporations" (July 16, 2025).

2 The in-house lobbying registration rules do not apply to any communications that employees have with public office holders about the awarding of a contract by or on behalf of the Government of Canada.

3 Lobbying Act, RSC 1985, c 44 (4th Supp) at ss. 7(1)(a) and (b).

4 Office of the Commissioner of Lobbying of Canada, "Backgrounder - Significant part of duties registration threshold" (July 16, 2025).

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