Information & Ethics Committee on April 16th, 2026

[Elsa Pilichowski]

If it's okay, sir, I would prefer that Pauline respond to that question.

[Pauline Bertrand]

Very quickly, for example, in order for Canada to reach 100% on implementation, one of the key elements that are currently absent from the register and could be included is information related to financial information, so the budget and expenses related to lobbying activities. There was a question raised earlier by one of the members about the funding that is provided for the purpose of lobbying and influence. This could be information that is relevant to include in the register. That is included in some registers across the OECD, like, for example, in Germany.

Other elements that Canada could consider, and that is in our legal instruments, is the question related to grassroots communication to provide more transparency on these types of activities that are currently in the register. Lobbyists have to indicate only that, yes or no, they do grassroots, but give no further details.

Throughout the discussion, the question on monetary fines was mentioned. That is also an area of improvement that could bring Canada more in line with our recommendation on lobbying and influence.

[Gurbux Saini, Liberal, Fleetwood—Port Kells, BC]

In your 2020 report, you recommended additional compliance measures that could be available to the Commissioner of Lobbying in Quebec. Do other countries, such as the United Kingdom, France, Australia or New Zealand, have similar tools? If so, what types of measures do they use?

[Pauline Bertrand]

In terms of compliance, as I mentioned, I do not have the exact numbers for which countries have the possibility of imposing a monetary fine. However, in terms of the best practices that we could highlight, I mentioned Ireland in terms of monetary fines. Also, countries like Lithuania and Slovenia have relevant practices in terms of not going directly to criminal prosecution or penalties but imposing measures such as training, a temporary debarment from the register or a temporary prohibition from conducting lobbying activities, which are there to ensure compliance and provide more proportionate sanctions. In countries like France, however, where there are only possibilities for criminal sanctions, there have been recommendations that are similar to those made by the lobbying commissioner to provide for a more graduated system of compliance and enforcement.

[Gurbux Saini, Liberal, Fleetwood—Port Kells, BC]

British Columbia is considered to have some of the best legislation in the world. Can you compare that to Canadian legislation, both at the federal level and in Quebec?

[Pauline Bertrand]

I have one point before I mention the regulation in British Columbia. Our indicators and measurements do not cover regulations at the provincial level or at the state level. Our analysis, when it comes to our data measurement, is limited to a national, federal level. We have not analyzed in detail the regime in British Columbia.

That being said, as the commissioner from British Columbia mentioned earlier today, we also have discussions with regulators at the provincial level. We did publish a report on Quebec. British Columbia is part of our network of lobbying regulators. The key strengths of the system that were mentioned throughout the discussions today are the fact that communications reports do not cover just pre-arranged meetings, but all oral and written communications. This is in line with the practices across the OECD.

A system of monetary penalties is also aligned with these best practices and with our recommendations. These would be the key elements that I would say differentiate British Columbia from the federal level. The thresholds issues, which were a significant part of it, were removed. These are some of the key points that differentiate British Columbia from the federal level, but, again, we have not gone into detail of the system in B.C. in our indicators.

[The Chair, Conservative, John Brassard]

Thank you, Pauline.

Thank you, Mr. Saini.

Mr. Thériault, from the Bloc Québécois, you have five minutes.

[Luc Thériault, Bloc, Montcalm, QC]

Thank you.

I'd like to spend the next five minutes having a more open discussion about a report entitled “Anti‑Corruption and Integrity Outlook 2026: Canada”. In the report, you note that Canada does not have a unified central anti-corruption strategy. That's a statement of fact. There are multiple bodies that manage cases, multiple pieces of legislation and so forth.

Have you identified any benefits to a unified central strategy?

Was it simply an observation to lay out the underpinnings of Canada's provisions on the issue?

[Nejla Saula]

I'll take that question, if I may.

Thank you very much. That's a very interesting question and an issue that we discuss on a regular basis.

The answer lies in the second element you suggested. In other words, we are fully aware that there might not be a consolidated national strategy; however, strategic goals that are scattered across various legislative and policy instruments have been adopted at the federal level under the Criminal Code, the Financial Administration Act and so forth.

Under the OECD's approach, which is incorporated in our recommendation on public integrity and upon which our analysis and report are based, we recommend that even though there isn't a single document, there should be a central strategic approach to anti-corruption.

That's probably what is missing in Canada's system, and this has been included in that analysis and indicator, which I think might be the only one where Canada doesn't rank high. Even though Canada is ahead in all the other areas, this is still a weakness. A stronger strategic approach is needed, one that goes beyond the legislation and provides a policy direction on anti-corruption and enhanced integrity at the federal level.

[Luc Thériault, Bloc, Montcalm, QC]

Do you have any examples of countries with such strategies?

Have any positive impacts been observed on that front?

[Nejla Saula]

Absolutely.

Most OECD countries and some non-OECD member countries have strategies. First, interestingly enough, since we started tracking developments in this area in member and non-member countries two or three years ago, we have seen a growing number of countries adopt their first national strategy. Second, the most effective strategies have the highest quality. High-quality national strategies or strategic national objectives include the capacity to implement a monitoring and evaluation system.

A coordinated national strategy allows for that. It makes it possible to track implementation, evaluate the impact and inform subsequent national strategies. We drew on that point to make our finding, in the document, that national strategies have a positive impact on a country's anti-corruption and integrity system, especially when the strategies have monitoring and evaluation systems that allow governments and public authorities to determine the impacts of the strategies and to draw conclusions. There is less scope for that in a more fragmented system.

[Elsa Pilichowski]

I'd like to add to that, if I may. Having a national strategy that is reviewed regularly also allows all administrations to identify new threats to integrity, which emerge very quickly in the digital world, such as foreign interference. As such, a strategy makes it possible to review these new threats in a coordinated manner with all integrity stakeholders.

[Luc Thériault, Bloc, Montcalm, QC]

When you talk about a national strategy, you're simply saying that notwithstanding the various authorities in Canada that are responsible for combatting corruption through various pieces of legislation, there is some consistency and cohesion. However, we must consider that Canada's performance has room for improvement. Other countries are doing better than Canada on that front.

Is that what you mean?

[The Chair, Conservative, John Brassard]

Your time is up, Mr. Thériault, so I'll ask the witness to give a brief response.

[Nejla Saula]

First, I'd be delighted to continue this conversation in a different setting, because I think it's very important. The fact that there are several stakeholders is definitely not a problem, far from it. There are many institutions that make up the integrity ecosystem.

At the same time, it's important to have a policy direction for efforts to fight corruption and promote integrity, as Ms. Pilichowski noted, to position institutions to be dynamic and to adapt to risks.

That is not possible without such a strategy.

[The Chair, Conservative, John Brassard]

Thank you.

Mr. Barrett, you have five minutes. Go ahead.

[Michael Barrett, Conservative, Leeds—Grenville—Thousand Islands—Rideau Lakes, ON]

Canada scores highly in the OECD's 2026 lobbying indicators, meeting 80% of criteria on regulation and 89% on practice.

However, in their 2023 report, “Implementing the OECD Anti-Bribery Convention in Canada: Phase 4 report”, the OECD said that, under the Liberal government, “Canada's prosecutorial independence framework came into sharp focus during the SNC-Lavalin...case” and that allegations of political interference “triggered a public statement from the Working Group on 11 March 2019.”

Does this suggest that Canada's system may look strong on paper but still fails when real pressure is applied by well-connected insiders?

[Elsa Pilichowski]

Our indicators look at the regulatory systems in existing institutions and at a set of potential penalties. They don't look at the day‑to‑day reality within a country—well, the indicators in my department don't. Regardless of the institutions and existing regulations, the fact is that there are scandals or issues in real life. We that see in all countries, including Canada and countries that are very successful when it comes to regulation.

It's therefore hard to conceive—at least that's our perspective—of a system where issues don't arise in real life. The important thing is to have penalties for such issues, to learn from the issue, to look at emerging risks, and to ensure systems are up to date.

[Michael Barrett, Conservative, Leeds—Grenville—Thousand Islands—Rideau Lakes, ON]

The OECD's anti-bribery convention says that foreign bribery cases must not be influenced by national economic interest or by the identity of a company involved. In that Liberal scandal with SNC-Lavalin, we saw that the government repeatedly relied on fabricated jobs and economic arguments.

Does Canada's current lobbying regime do enough to expose those pressure campaigns built around those arguments, when the beneficiary is a major corporation with significant political access?

In your previous response, you said it's about lessons learned and really what consequences are brought to bear. Does the current regime go far enough, knowing what we know now following that very significant scandal?

[Pauline Bertrand]

I will take that one, and perhaps echo what Elsa said.

When it comes to lobbying regulations, there will always be actors who want to conduct influence in a malign, manipulative or secretive way. They can find ways to circumvent regulations. The goal of a lobbying regulation—a lobbying register—is not to cover every single angle, but really to, as much as possible, cover some of the key risks, provide transparency where it is relevant and ultimately enable citizens and various stakeholders to understand who is lobbying on what, how and with what means.

As you said, when there are these cases, it's always an opportunity to improve. Following this particular case, there have been reforms. I think that the purpose of your study is to be able to ask, where can we go even further, in terms of transparency and what communications we ask lobbyists to disclose in terms of who is the ultimate beneficiary of lobbying? These are the questions that you could look into on how to enable citizens to understand where the lobbying comes from.

Again, there will always be cases and those who want to influence in a malign way. Sometimes, they're ahead of the reforms. The idea is, through these cases, learning and experience, to be able to identify where reforms are needed.

In Canada, you have a very long experience regulating lobbying—one of the longest experiences within the OECD. I think, from the previous commissioner, the current commissioners and now these international examples, there is room to really identify where these specific points are where Canada already does well but could do better in terms of transparency.

[The Chair, Conservative, John Brassard]

Thank you.

Thank you, Mr. Barrett.

Ms. Lapointe, you have the floor for five minutes.

[Linda Lapointe, Liberal, Rivière-des-Mille-Îles, QC]

It is John-Paul's turn.

[The Chair, Conservative, John Brassard]

Please go, Mr. Danko, for five minutes. Go ahead.

[John-Paul Danko, Liberal, Hamilton West—Ancaster—Dundas, ON]

Thank you, Chair.

I really appreciate taking part in committee today and the discussion, especially hearing what I think are some pretty positive opinions about Canada's lobbying registry, Canada's ethics regulations, and Canada's being a global leader and having very strong ethics and lobbying regulations already in place. Of course, we're always interested in what can be improved.

Part of the question, for me, is the ongoing evolution of how governments and elected officials are influenced, or attempts are made to influence them, to reach one decision or another. Two of those kind of come together. We've talked a little about it, in terms of social media and foreign influence. I want to bring those together and ask a question about that.

What we're seeing is a whole ecosystem of social media, so-called influencers, whose purpose is not conveying news or their opinion. It's to influence public policy and elected officials. Oftentimes, what we've seen is that they are funded by corporate interests, or even occasionally, foreign interests.

We've seen that in the United States, where there have been social media influencers attempting to influence government policy who were funded by foreign adversaries.

My question for the witnesses is, can they comment on where they see the evolution of lobbying going? How can we make sure that those undue influences are appropriately managed, so that Canadians have the transparency they deserve?

[Pauline Bertrand]

You're making a very important point. That is one of the central messages and key reasons we update our own standards. The previous version of our legal instruments defined lobbying as a direct oral or written communication. What we found—and you mentioned it—was that a lot of lobbyists or interest groups will say that, today, they can conduct a very successful lobbying and influence campaign without the need to write to or meet with a single public official.

We have moved from lobbying to influence. A lot of this influence is done through grassroots lobbying or communications campaigns, where the goal is to spread information materials and influence the opinions of the general public so that this can in turn put pressure on public officials to take a specific stance. This is why the new version of our legal instrument defines lobbying as more than just written and oral communications. It includes all these attempts to influence the public. This is the first point.

The second point is how this can be addressed in lobbying registers and what the link is to the foreign influence landscape. Some of these practices, whether they're, as you mentioned, done on behalf of a corporation or a foreign country, are quite similar. We have lobbying firms that represent both corporations and foreign governments.

As you mentioned, there are also groups that we could call front groups. They are controlled by an industry interest or by a foreign interest. This is where the link between the lobbying register and the foreign influence register comes into play. There is a case for aligning these frameworks a bit.

What I want to say is that it's really crucial, in terms of how lobbying registers evolve, that they no longer just provide transparency on oral and written communication but go beyond that.

I think Canada already defines and includes grassroots communications in the Lobbying Act. I think that the next step is to ensure that this notion of grassroots communications is clearly understood and that there's clear interpretation on what that means. There can be a lot of activities that can fall under indirect or grassroots lobbying. How can that be disclosed in the register, and how do we ask lobbyists to disclose this type of information?

There are few examples within the OECD, with the exception of the EU transparency register. All the other registers, unfortunately, are still focused on oral and written communications. There is a lot to learn from foreign influence registers that have for a long time included these communications campaigns and these political activities that are more about influencing minds and less about directly influencing public officials.