Information & Ethics Committee on June 1st, 2026

[Jodene Baker]

Yes.

Because so many charities and non-profits are small and do not have the capacity to hire full-time government relations staff, we rely on strength in numbers. Imagine Canada, for example, often plays a backbone role in coalition work, in which we'll do a lot of the coordinating and organizing, such as a lobby day.

We see uncertainty and nervousness right now in the non-profit sector around which of those coalition activities require registration or are required to be counted in the tracking towards the threshold for lobbying. With the reduction in the number of hours from 32 to eight, there's more attentiveness and more attention being paid to it because there's a recognition that the number might be met more quickly than it has been in the past. Our recommendation is about a need clarity around how coalition activities are tracked in lobbying and what is included and not included in it.

[Fares Al Soud, Liberal, Mississauga Centre, ON]

Thank you, Ms. Baker.

Mr. Larkin, I'll turn to you now. Before this committee, we've had the opportunity to hear from federal and provincial lobbying commissioners, legal experts and academics. It's also important that we get to hear from someone who has practical, on-the-ground experience and an understanding of how the act works in practice.

I have a big question for you: What's working well, what isn't and needs reform, and what suggestions would you like to put forward to this committee?

[Kyle Larkin]

That's a great question. Thank you for it.

What's working well is the lobby registry. I have registered in every single province in Canada, so I can compare the federal registry to the systems that I've used at the provincial level. I can tell you that some at the provincial level, such as the one in Saskatchewan, are absolutely fantastic. Others need some work; they need a new web developer.

The federal one is very accessible by lobbyists; it's accessible by the public, and it's accessible by public office holders. It's a very easy tool to find out who is lobbying whom and who's lobbying for what. The transparency through the system now is at the right level in terms of showcasing the subject matters you're lobbying for, who you've lobbied, when you've lobbied them and what you've lobbied them on. It also includes government funding and other aspects, so that is working really well.

The main element that I think is concerning is the interpretation of different things in the Lobbying Act. I touched on that in my opening remarks, because things are interpreted by different people in different ways. The Lobbying Act, in the section with the “significant part of the duties”, for example, has been interpreted by commissioner after commissioner as being 32 hours. The newer-ish commissioner has now interpreted that as eight hours despite no evidence showing that there's been shadow lobbying, negative lobbying or anything that led from 32 hours to eight hours. I question the interpretation there.

The second piece I question is the interpretation of the hospitality level. That has been interpreted as $40 since the Lobbyists' Code of Conduct was renewed in 2023, and it hasn't been updated since then. If we want to continue holding parliamentary receptions hosted by not-for-profit associations that support your parliamentary roles, your committee roles and your roles in the House of Commons, we need to ensure that level meets inflation and is increased. I know many of you in the room attend and enjoy these receptions, as they are a great opportunity for you to connect with Canadians in Ottawa instead of having to go across the country in an attempt to connect with these Canadians. Forty dollars was great in 2023, but it needs to be updated in 2026.

[The Chair, Conservative, John Brassard]

Thank you, Mr. Larkin.

Thank you, Mr. Al Soud.

Mr. Fortin, you have the floor for six minutes.

[Rhéal Fortin, Bloc, Rivière-du-Nord, QC]

Thank you, Mr. Chair.

Thank you, Mr. Larkin and Ms. Baker.

Ms. Baker, I'll address you first.

The commissioner recommends disclosing all non-governmental sources of funding, including foreign sources of funding. I'd like you to tell us about that.

Does this seem appropriate to you? Is that a good idea?

[Jodene Baker]

Thank you for the question.

This isn't an issue that we've considered in our submission, so I don't have the experience to speculate on that today, especially speaking on behalf of an organization. It's something I'd certainly be willing to look into with some of our members and others across the sector. I can provide an answer to you at a later date.

[Rhéal Fortin, Bloc, Rivière-du-Nord, QC]

I just want to make sure I clearly understand your answer.

Your organization receives no funding other than from the government. Your only client is the government. Is that accurate?

[Jodene Baker]

No. Imagine Canada does receive donations from foundations—for example, grants from donations. I'm not sure that I could speak in terms of changes to the Lobbying Act as it relates to the entire sector.

[Rhéal Fortin, Bloc, Rivière-du-Nord, QC]

Okay.

You don't know if it would be a good idea to require disclosing those funding sources. Is that what you're telling me?

[Jodene Baker]

Charities already disclose their funding sources with their reporting through the Income Tax Act, so I think I may not be understanding the question that you're asking.

Could you please rephrase that for me?

[Rhéal Fortin, Bloc, Rivière-du-Nord, QC]

I'm simply saying that recommendation 8 of the commissioner's report calls for the disclosure of all non-government sources of funding. This concerns funding that lobbying organizations or private lobbyists, regardless, receive from sources other than the government, which includes foreign funding sources, among others.

This has been raising some concern for a few years. I imagine you're aware of the issue of foreign interference, including in the electoral process, which would make us a bit more concerned about those issues. Perhaps the commissioner's recommendation could protect us against some of this interference.

I don't want to put you on the spot. If you don't have an opinion on that, that's fine, I'll move on to something else.

[Jodene Baker]

At this point, I would like to think some more on that topic.

[Rhéal Fortin, Bloc, Rivière-du-Nord, QC]

Thank you.

Mr. Larkin, I have the same question for you regarding the commissioner's recommendation 8. In your opinion, is it a good idea to require the disclosure of non-government sources of funding?

[Kyle Larkin]

I'm sorry, Mr. Fortin. I can't comment either. I've never worked with a not-for-profit association that's received funding from international organizations or from other means.

[Rhéal Fortin, Bloc, Rivière-du-Nord, QC]

In your case, you're at the Canadian Meat Council. I assume you don't have any clients other than government agencies, is that right?

[Kyle Larkin]

In the association I work for currently, the main dues are from the members. We receive some government funding to do different types of programming.

The associations I've worked for before were similar, in which the lion's share was membership dues, with a very small portion of government grants to enact different programs that the government was looking to accomplish.

[Rhéal Fortin, Bloc, Rivière-du-Nord, QC]

Do you think that registration by default is a good idea?

In your opinion, should we stick to the previous threshold of 32 hours or the current threshold of 8 hours? How do you view that?

[Kyle Larkin]

Registration by default is extremely concerning. I would flow into that needing to put in communications reports by default, as well as changing from the oral and arranged, which is currently the case, to the need for any instance of communications with any designated public office holder to be registered.

That's what we've seen in British Columbia. They have had to change some of their rules because things have gotten so onerous. If someone put out a Facebook post that said, “Premier David Eby, you need to do this”, you would need to put in a communications report for that Facebook post. If I sent you a meeting request to say, “Mr. Fortin, can you meet me on X date?” and you missed the email—you didn't even respond to the email—there would need to be a communications report behind that.

Both of those things play into each other, but registration by default is extremely concerning, especially when you look at not-for-profit associations that represent individuals or small and medium-sized enterprises across Canada. If those individuals are advocating on behalf of their individual business, registering by default would mean that most Canadians who liaise with their member of Parliament for one issue or another would need to register.

[Rhéal Fortin, Bloc, Rivière-du-Nord, QC]

In your opinion, could the commissioner do more to help non-profit organizations, among others, meet their obligations under the Lobbying Act?

[Kyle Larkin]

To be completely fair to the Office of the Commissioner of Lobbying, they already do that. I would give them thanks for doing that. They're always open to answering questions. I've worked with many different associations that haven't understood one part or another of the Lobbying Act or the Lobbyists' Code of Conduct, and any time we reach out to the office, they always come back to us with a good answer.

[Rhéal Fortin, Bloc, Rivière-du-Nord, QC]

The commissioner is requesting a broader range of sanctions as part of recommendation 17 of the report.

The commissioner recommends, among other things, mandatory training measures, monetary penalties and temporary prohibitions on lobbying in cases of violations of the Lobbying Act. What's your opinion on that? Is it useful for the commissioner to have more powers regarding sanctions?

[The Chair, Conservative, John Brassard]

I need a very quick response.

[Kyle Larkin]

I would say that the tools the lobbying commissioner has right now are sufficient in terms of being able to loop in the RCMP and to levy fines and greater penalties than that.

[The Chair, Conservative, John Brassard]

Thank you, Mr. Fortin.

We're starting the second round.

Mr. Cooper, you have five minutes. Go ahead, please.

[Michael Cooper, Conservative, St. Albert—Sturgeon River, AB]

I'm going to direct my questions to Mr. Larkin.

I take your point, but I'm going to push back a little on your submissions with respect to the commissioner's recommendation around communications, whether they be oral, written or pre-arranged.

At the end of your testimony, you suggested that this could result in having to issue or file a report upon there being any communication with a public office holder, such as running into a public office holder at an airport lounge or on the street. When I look at the act in terms of what constitutes lobbying, it relates to a communication with respect to “the development of any legislative proposal”, “the introduction of any bill or resolution in either House”, “the making or amendment of any regulation”, “the development or amendment of any policy or program”, “the awarding of any grant, contribution or other financial benefit” or “the awarding of any contract”. That seems very different, in substance, from simply running into a member of Parliament or a senator and saying hello at an airport lounge.