Annual report 2024-25

*Slight difference over previous reported yearly totals may occur due to late communication reports or deletions following verifications.

Type of late registrations

Late registrations table

Late communication reports

In 2024-25, 2,120 communication reports were filed late, a modest decrease of 20 late reports compared to the previous year. While 93.4% of communication reports were filed on time, any late report hinders transparency. 

The vast majority of late reports were submitted between 1 and 15 days late, at nearly 57%, while nearly 36% were submitted between 16 to 180 days late. Disappointingly, more than 7% were submitted more than 180 days late.

Even a small number of late reports can hinder timely public access to lobbying information. The Office continues to emphasize the importance of timely reporting and works with registrants to improve compliance through education and monitoring.

Timeliness of communication reports

*Data captured on 2025-03-31, for reports filed between 2024-04-01 and 2025-03-31, which would include oral and arranged communications filed late from previous years.

Late communication reports table

Verification of communication reports

To ensure accurate reporting by lobbyists, the Office extracts a sample (5%) of new communication reports filed in the Registry of Lobbyists every month and asks the designated public office holders named in them to confirm whether the information submitted in the reports is complete and accurate.

To allow the implementation of changes to communication reports requiring the addition of the subject matter details, the Office briefly paused its verification of communication reports. During October and November 2024, no verifications were conducted, resulting in a slightly lower than normal number of verified reports. 

In 2024-25, designated public office holders named in 1,064 communication reports reviewed the information and confirmed that 929 reports, just over 87%, were complete and accurate. This marked a 2% increase over 2023-24.

The 110 communication reports that were inaccurate contained 117 inaccuracies as some contained more than one error. The Office reaches out to registrants and requests that they correct inaccuracies. 

Common inaccuracies in communication reports

Registration and advisory services

To ensure compliance as well as accurate and consistent data in the Registry of Lobbyists, the Registration and Advisory Services team reviews all new, updated, and reactivated registrations to verify that they meet all the disclosure requirements outlined in the Lobbying Act.

In addition to these reviews, the team delivers information sessions to help lobbyists understand their obligations under the Lobbying Act and the Lobbyists’ Code of Conduct. The team also answers inquiries from stakeholders on a wide range of topics and reaches out to lobbyists to offer advice and support.

Reviewing registrations

Between April 1, 2024, and March 31, 2025, the team reviewed and posted 14,215 registrations, including new, reactivated, and updated registrations. This represents an average of 1,185 registrations per month and marks a 31% increase compared to the previous year.

Of the 14,215 registrations reviewed, 2,143—approximately 15%—were returned to the registrant at least once for corrections following a review by one of our advisors. Of these, 362 were sent back more than once.

In 2024-25, the number of new registrations totaled 2,912, a 3% decrease from 2023-24. However, the number of updated registrations rose to 10,745, an increase of 46% from 7,357 the previous year while reactivated registrations also increased by 18%, from 472 to 558.

Inquiries by source

Inquiries by topic

Registration and Advisory Services service standards

A continuously increasing volume of calls and emails has not deterred the Registration and Advisory Services team from providing exceptional service throughout 2024-25. 

The team met or exceeded all their service standards, achieving an outstanding 100% result in four out of five service standards.

Service standards for Registration and Advisory Services

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Ensuring compliance

Compliance

The Compliance Directorate ensures that registrants, lobbyists, and former designated public office holders meet their obligations by conducting a variety of activities to enforce the Lobbying Act and the Lobbyists’ Code of Conduct.

In addition to 34 compliance files carried over from the previous year, which included 1 investigation, the Office initiated 25 preliminary assessments during the 2024-25 fiscal year. The Commissioner closed 21 files at the preliminary assessment stage, while 2 progressed into investigations.

During the year, the Commissioner referred 1 investigation to the Royal Canadian Mounted Police (RCMP) after determining there were reasonable grounds to believe an offence had occurred under the Lobbying Act. When the Commissioner refers a file to the RCMP, she must suspend her investigation. 

Compliance statistics

In 2024-25, the RCMP returned 3 files referred by the Commissioner without laying charges. As of March 31, 2025, the Commissioner had ceased those investigations.

At the close of the fiscal year on March 31, 2025, there were 35 files at the preliminary assessment stage, 2 ongoing investigations and 4 suspended files, 3 of which are with the RCMP while 1 continues to be suspended pursuant to subsection 10.4(8) of the Lobbying Act because the Commissioner became aware of an ongoing parallel investigation on the same subject matter. 

Compliance assessments and letters

In addition to its investigation efforts, the Office undertakes a variety of activities to verify compliance with the Lobbying Act and the Lobbyists’ Code of Conduct. 

Throughout 2024-25, the Office sent 23 compliance letters to lobbyists, 12 of which were to ensure compliance with the hospitality rules of the Lobbyists’ Code of Conduct. 

The Office also conducts compliance assessments to address late filings of registrations and late filings of communication reports. Regular monitoring is conducted for a period of 1 year to ensure continued compliance. In 2024-25, 13 lobbyists were monitored.

Update on charges laid under the Lobbying Act

Gerald Paulin

As set out in last year’s annual report, the RCMP formally charged Gerald Paulin under the Lobbying Act following a referral by the Commissioner of Lobbying in September 2020. 

Mr. Paulin is alleged not only to have failed to file a return after undertaking to communicate and to arrange a meeting with a public office holder, but also to have received a payment contingent on the outcome of a registrable matter. 

Proceedings were instituted against Mr. Paulin in the Ontario Court of Justice in Thunder Bay in March 2024. The Court subsequently heard a peremptory defence on May 12, 2025, and set the next court appearance for June 16, 2025. 

Exemption requests for the five-year restriction on lobbying

In 2024-25, the Office received 14 applications for exemptions to the five-year restriction on lobbying from former designated public office holders. Another 2 applications were carried over from the previous year.

Of these 16 requests:

• 5 were granted
• 6 were denied
• 4 were withdrawn
• 1 were carried over to 2025-26

While slightly lower than the number of requests received last year, the amount remains significantly higher than the number of requests received in other previous years. 

Service standards for requests for exemptions to the 5-year restriction on lobbying

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Expanding awareness and understanding

Outreach and education

The Office actively engages with lobbyists, public office holders, members of media, and the general public to raise awareness of the Lobbying Act and the Lobbyists’ Code of Conduct. These outreach efforts foster understanding and support compliance with both the Act and the Code.

In 2024-25, we met with 1,099 stakeholders through 119 presentations to lobbyists, public office holders, international organizations, other interested parties, etc. Several of these presentations were made to students to help them better understand how transparent and ethical lobbying is essential to a healthy democracy. 

Additionally, the Office issued advisory letters to 14 individuals identified in media reports following announcements of their employment with government relations firms, organizations, or corporations engaged in federal lobbying. These letters serve to inform potential lobbyists about registration and reporting obligations under the Lobbying Act, promoting compliance and transparency.

The Office also reached out to 18 designated public office holders outlining the 5-year restriction on lobbying that applies to them after the cease to occupy their position. Shortly after the election was announced, an additional 64 letters were sent to those not seeking re-election to inform them of their obligations under the Lobbying Act.  

Presentations to stakeholders

Throughout 2024-25, a variety of resources were developed or updated. This included a primer related to how the rules on gifts and hospitality apply in practice, a new timeline on the history of the lobbying regime in Canada, and two updated interpretation bulletins. 

Media engagement

The Office of the Commissioner of Lobbying is committed to providing the media with timely, accurate and appropriate information regarding Canada’s lobbying regime. 

In 2024–25, the Office responded to a total of 62 media inquiries, reflecting sustained interest in the Commissioner’s mandate and activities.

Media inquiries covered a range of topics, with the most frequent questions relating to the Lobbying Act and Lobbyists’ Code of Conduct, which accounted for 32% (20) of the total number of inquiries. 

Compliance activities, including investigations, was another common topic with 21% (13) of the received inquiries. 

The Registry of Lobbyists was the third most common topic with 19% (12) of the questions. We assisted journalists in locating specific information in the Registry, in clarifying information about registrations or communication reports or by simply confirming the accuracy of their findings from their registry search.

The Commissioner also participated in seven media interviews, providing insights into the Office’s work and reinforcing its commitment to openness and accountability.

Common goals of transparency and accountability

Canada’s long-standing experience in regulating lobbying activities positions the Office well to share its experience and contribute to the discourse around transparency and ethical lobbying of government officials.

Common standards for lobbying transparency and accountability support the development of systems that can strengthen democracies. The ongoing collaboration with provincial and international counterparts provides opportunities to share expertise among participants to help foster effective, accountable, and inclusive institutions at all levels.

Lobbyists Registrars and Commissioners Network

Each year, Commissioner Bélanger and employees of the Office participate in two meetings with the Lobbyists Registrars and Commissioners Network (LRCN) to share best practices and provide updates related to their respective regimes. 

In September 2024, the Office was pleased to host the LRCN in Ottawa for its annual in-person meeting. The Commissioners and Registrars discussed the range of thresholds for in-house lobbying registration in their respective federal, provincial, and municipal regimes and considered the merits of registration by default.

Members of the LRCN were joined virtually by representatives of the Organisation for Economic Co-operation and Development (OECD) who provided an overview of the OECD’s 2024 Recommendations on Transparency and Integrity in Lobbying and Influence.

The LRCN’s annual virtual meeting was hosted by the Office of the Integrity Commissioner of Ontario in February 2025.

Council on Governmental Ethics Laws (COGEL)

The Council on Governmental Ethics Laws (COGEL) is a largely U.S.-Canada-based professional organization for government regulators and others working in ethics, elections, freedom of information, lobbying, and campaign finance.

In December 2024, Commissioner Bélanger attended the annual COGEL Conference in Los Angeles, California. The conference allows members to share a wealth of knowledge and expertise. To this end, Commissioner Bélanger provided an update on developments in the Canadian federal lobbying landscape and moderated a panel on stakeholder education on a budget.

Organization for Economic Cooperation and Development (OECD)

Each year, the Organization for Economic Cooperation and Development (OECD) brings together leaders from around the world who share a common goal of improving transparency and integrity. 

In March 2025, the Commissioner and the Office’s Director of Registration, Policy and Public Affairs attended the Global Anti-Corruption and Integrity Forum to exchange best practices, participate in a working group on integrity indicators and to attend the in-person OECD Meeting of Lobbying Commissioners, Registrars and Oversight Entities.

Parliamentary activities

The Commissioner of Lobbying reports to Parliament through the Standing Committee on Access to Information, Privacy and Ethics (ETHI). In 2024-25, Commissioner Bélanger testified before the Committee on two occasions.

On April 16, 2024, Commissioner Bélanger appeared before the Committee to discuss Main Estimates 2024-2025. The Commissioner and committee members’ discussions continued to highlight some of the shortcomings in the Lobbying Act, notably with the “significant part of duties” threshold and the lack of a spectrum of sanctions.

Commissioner Bélanger also appeared before ETHI on November 5, 2024, as the Committee considered her nomination to the position of Commissioner of Lobbying for a second seven-year term. The Committee supported her re-appointment and presented the certificate of nomination to the House of Commons on November 7, 2024. The Senate approved the reappointment in a resolution dated October 29, 2024. Commissioner Bélanger was reappointed, effective December 30, 2024.

Following her re-appointment, the Commissioner reached out to Senators, offering to meet with them to discuss her mandate and priorities. This outreach resulted in 6 meetings with individual Senators, with additional meetings anticipated in 2025-26.

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Workings of the Office

In the backdrop of fulfilling its mandate, the Office must also meet organizational obligations and ensure smooth day-to-day operations.

Following the government’s return-to-work directive in the fall of 2024, employees and executives increased their in-office presence to three days and four days a week, respectively. All employees share at least one common in-office day to facilitate collaborative work and all-staff meetings.

Fall staff meeting

In November 2024, the Office held an all-day, all-staff meeting at the Native Women’s Association of Canada. This was an opportunity for the entire team to share information, have broader discussions on issues that span the entire organization and interact with team members in a different setting. 

This meeting focused on organizational performance indicators, workplace culture and updates from various teams. Employees also had the opportunity to participate in an indigenous workshop.

Values and ethics

As ethics is at the core of the Office’s mandate, employees participate in both formal and informal discussions on values and ethics on a continuous basis. In 2024-2025, activities included an organization-wide discussion related to the Office’s Values and Ethics Code that involved a study of scenarios. In addition, two employees of the Office also participated in a values and ethics event held by the Clerk and Deputy Clerks of the Privy Council entitled “What Unites Us, Defines Us”.

Accessibility

In December 2024, the Office published its first progress report on the implementation of its Accessibility Plan 2023-25, in accordance with the Accessible Canada Act. The progress report highlights the variety of initiatives that were taken in 2024-2025 to improve and promote accessibility.

In August 2024, the Office engaged the Accessibility, Accommodation and Adaptive Computer Technology (AAACT) team to assess the accessibility of a subset of frequently accessed pages from the website and the Lobbyists Registration System (LRS). The Office put an action plan in place in response to the resulting recommendations. By March 31, 2025, all actions related to the website were completed, including applying some of the recommendations to web pages that were not covered by the review. Several of the actions related to the LRS were also completed and plans are in place for the remainder of the recommendations. Our efforts in improving the accessibility of our website and the LRS will continue.

Strain on resources

The Office allocates most of its limited human and financial resources to fulfilling its mandate related to the regulation of lobbying. However, despite being a micro-organization and an institution supporting an independent agent of Parliament, we must undertake a wide range of corporate functions typically supported by full teams in much larger departments. 

Not only must the Office prepare the same accountability reports required by large departments, but as a function of being a micro-organization, it must also prepare and manage memoranda of understanding with other federal entities for the provision of essential services such as human resources, finances, contracting, security, and IT support.

The reality is that the Office simply does not have the levels of financial resources or the depth of human resources comparable to those of other federal organizations to effectively respond to reporting requirements that do not contemplate or account for the size and resource capability of micro-organizations like us. 

The Office accomplished its work in 2024-2025 with a budget of approximately $6.2 million. Roughly $4.6 million of this budget is for salaries and benefits, leaving our operation and maintenance budget to approximately $1.6 million. About $700K of this budget is for obtaining services from other government institutions, including services related to human resources, finance, procurement, and information technology. 

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Looking ahead

The focus for the beginning of 2025-26 fiscal year is shaped by the April 2025 election. With a new Parliament in place, one key priority is ensuring that both outgoing and incoming MPs are well-informed of the requirements under the Lobbying Act and are aware of the obligations and ethical standards expected of those who lobby them.

An upcoming highlight will be the release of an interpretation bulletin that will redefine the Commissioner’s interpretation of “significant part of duties”, the threshold that triggers the requirement for organizations and corporations to be registered in the Registry of Lobbyists. As a similar expression (i.e. ‘’significant part of the individual’s work’’) is also referenced in the five-year restriction on lobbying for former designated public office holders, a corresponding interpretation will also be issued. 

Originally planned for early 2025, their publication was delayed due to the prorogation of Parliament in early January. They are now expected to be released in early summer 2025, followed by a 6-month period before they come into effect. We will update our educational material accordingly and will expand our outreach and awareness activities to support the understanding of this change.

Throughout 2025-26, with the hard work and dedication of employees, we expect to continue to look for ways to enhance how we support our mandate of ensuring transparency, compliance and awareness of Canada’s lobbying regime. 

It has now been more than 15 years since the Lobbying Act and its regulations were updated. The Commissioner is actively developing new and updated recommendations to provide parliamentarians with a renewed vision for modernizing the Lobbying Act.

Building on the preliminary recommendations released in 2021, the Commissioner also plans to seek regulatory updates to make lobbying registration more effective in accordance with its legislated purpose.

We must continue to advocate for increased transparency and ethical behaviour in the lobbying of federal officials to support public trust in our democracy.