Backgrounder - Significant part of duties registration threshold

July 16, 2025 – Ottawa, ON

Commissioner Bélanger has issued a bulletin interpreting the phrase “significant part of the duties” as used in paragraph 7(1)(b) of the Lobbying Act (Act). This bulletin replaces a previous bulletin issued in 2009 and aims to enhance transparency in the lobbying of federal officials.

This interpretation is grounded in accepted principles of statutory interpretation and consistent with the principles set out in the preamble to the Act.

In this bulletin, the term “significant” is interpreted to mean a “notable” or “noteworthy” part of an employee’s duties.

The new bulletin sets out a clear standard for when this in-house lobbying registration threshold for organizations and corporations is understood to be met. The goal is to promote increased transparency and, in turn, help to ensure that the aims of the Act, including that the public be able to know who is engaging in lobbying activities, are met to an even greater degree.

The Commissioner of Lobbying is authorized to issue advisory opinions and interpretation bulletins about the interpretation, application or enforcement of the Act pursuant to subsection 10(1) of the Act.

Previous interpretation (July 2009)

In July 2009, the Office of the Commissioner of Lobbying issued an interpretation bulletin entitled, “A significant part of duties (‘The 20% rule’’)”.

This July 2009 bulletin described the approach of the Office of the Commissioner of Lobbying to interpreting and applying the significant part of duties registration threshold for in-house lobbying by organizations and corporations set out in the Act.

The 20 percent threshold set out in that document was drawn from a standard provided for in American legislation that does not include or make reference to the term “significant part of the duties”.

The “20% rule” established a relatively high registration threshold, according to which organizations and corporations were only required to file in-house registrations once their employees, individually or collectively, engaged in 32 hours of lobbing activities in any given month-long period of time. This threshold allowed for a substantial amount of in-house lobbying to go unreported and contributed to less transparency.

Statutory review of the Lobbying Act

Subsection 14.1(1) of the Act requires a parliamentary committee to undertake a comprehensive review of the provisions and operation of the Lobbying Act every five years. The last review took place in 2012 —thirteen years ago— and did not result in any amendments to the Act. No parliamentary reviews took place in either 2017 or 2022.

In 2021, the Commissioner submitted 11 preliminary recommendations for amendments to the Act to the House of Commons Standing Committee on Access to Information, Privacy and Ethics (ETHI), including a recommendation to replace the existing in-house registration threshold with a regime requiring registration by default, subject to limited exemptions based on objective criteria.

Since then, the Commissioner has indicated to ETHI that, in the absence of a review of the Act, she would issue an interpretation bulletin with respect to the significant part of duties threshold applicable to organizations and corporations. She has informed stakeholders of this intention through her annual report, during various presentations and through the media. Importantly, this new interpretation bulletin is not intended as a substitute for the statutory review mandated by the Lobbying Act.

This change reflects a commitment to greater transparency in federal lobbying. Organizations and corporations are encouraged to seek guidance from the Commissioner’s office to ensure compliance ahead of the bulletin’s effective date of January 19, 2026.