The House of Commons Standing Committee on Access to Information, Privacy and Ethics (ETHI) studied the *Lobbying Act* at meeting 31 on March 9, 2026. The sole witness was Nancy Bélanger, the Commissioner of Lobbying.
Commissioner Bélanger presented 21 recommendations to modernize the *Lobbying Act*, focusing on enhancing transparency, expanding enforcement, and increasing efficiency. She stated that the current threshold for registration—a "significant part of duties"—should be zero, noting she had already reduced her interpretation from 32 to eight hours per month, which has led to 70 new organizations registering. She recommended removing the threshold entirely to require registration by default for any lobbying communication, as done in British Columbia, and argued that the form of communication (oral, written, or informal) should not matter, only its substance.
On enforcement, Bélanger said she lacks the power to impose proportionate sanctions, such as mandatory training, administrative monetary penalties, or temporary lobbying bans, and must refer all potential offences to the RCMP, which is inefficient for minor infractions like late filings. She recommended gaining order-making powers and a mechanism for the Federal Court to enforce her production orders, as well as immunity for herself and her staff from civil or criminal prosecution for actions taken in the course of their duties, noting this protection exists for all other agents of Parliament but was omitted for her office.
Regarding post-employment restrictions, Bélanger highlighted a loophole where former designated public office holders (DPOHs) can lobby for up to eight hours if they work for a corporation, but are completely prohibited if they work for a non-profit organization; she recommended eliminating this discrepancy. She also noted that communications about obtaining government contracts are not currently covered by the *Lobbying Act* for organizations and corporations, and recommended they be included, except for communications within transparent public processes like RFPs.
Bélanger addressed the status of staff in the office of the Leader of the Opposition, confirming they are not appointed under section 128 of the *Public Service Employment Act* and therefore are not DPOHs, meaning lobbyists are not required to file monthly communication reports for meetings with them, though many mistakenly do. She recommended clarifying the definition of DPOHs by removing the reference to section 128 and instead listing the positions directly in the act, which would also cover individuals like advisers working in a minister's office under any mechanism.
On grassroots lobbying, Bélanger said current rules only require a checkmark that this method will be used, with no obligation to disclose when a campaign starts or who is targeted; she recommended requiring lobbyists to record the specific public office holders and subjects of such campaigns in the registry. She also recommended that board members of organizations be deemed employees for registration purposes to avoid fragmented reporting, and that the source of funding for lobbying activities be disclosed, as is done in several provinces.
Bélanger supported expanding the definition of DPOHs to include director general-level positions, as recommended by this committee in 2012, to increase transparency for operational-level meetings. She also recommended giving her office regulation-making power to update the registry's subject matter list (e.g., adding "climate") without needing to go through the Treasury Board Secretariat, noting the current regulations have not been updated since 2008. She disagreed with the suggestion that her recommendations might be unfeasible due to her 35-person staff, arguing that the reporting obligation lies with lobbyists, not her office, and that her team can verify compliance through random checks and investigations.
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