Thank you, Mr. Chair.
Good morning, everyone.
I sincerely thank the committee for this kind invitation.
The Canadian Federation of Independent Business, or CFIB, represents more than 103,000 small and medium-sized business owners across all sectors of the economy and in all regions of Canada. More than 52% of our members have nine employees or fewer. This means that these are truly smaller businesses.
Small business owners work an average of 54 hours a week and wear many hats, managing staff, sales and finances while serving their communities as your local shops, your local service providers and your local employers. They are remunerated by their business either as an employee or as a shareholder.
In July 2025, the Commissioner of Lobbying issued an interpretation bulletin, which lowered the registration threshold for organizations and corporations from 32 hours per month to eight hours in any rolling four-week period. The new threshold and proposals to move toward registration by default that would encompass all planned and unplanned written or oral registrable activity is concerning.
Why? These changes risk unintentionally capturing ordinary small business owners as lobbyists. From time to time, a small business owner contacts their federal MP or minister to raise concerns and make recommendations relating to policies that affect their business, or they apply for financial supports in relation to their business. They now need to register if they and/or their employees have collectively spent more than eight hours researching, drafting and sending these communications.
We are already hearing from business owners who are surprised to learn that writing to their MPs or applying for support programs could require them to register. They do not see themselves as lobbyists. They are simply trying to run their business. They believe they are raising concerns as constituents about government policy that affects their business.
One practical measure that would help reduce red tape on small businesses would be to exclude time spent applying for grants, contributions and other financial benefits from the registration threshold, particularly when there is a public, rules-based, transparent process. Applying to such programs is not an attempt to influence decisions. It is participation in a process created by government.
While we support the idea of transparency, we also caution about how it is sought. Thus, CFIB recommends not pursuing registration by default and legislating the threshold—specifically, the former 32-hour threshold. Changes to this threshold should be reviewed and debated by the House of Commons and the Senate and not left to the purview of the commissioner.
Further, a requirement should be that only planned communications organized for the purpose of influencing policy and procurement decisions are reported—not unintended or haphazard meetings at a community barbecue, for example, that weren't planned but where certain topics may be raised. We also support the suggestion of excluding the time spent preparing and submitting requests for grants and contributions when they're part of a government process.
We would also suggest or recommend that clarity be provided to stakeholders so they could properly assess the potential impacts of some of the other recommendations made by the Commissioner of Lobbying. For example, how would “grassroots lobbying” be defined and what would it include: surveys, petitions, letters or communiqués?
We are regularly told that MPs want to hear directly from small business owners in their ridings. These changes and the associated administrative burden risk discouraging that engagement. Consequently, those with the time and the resources to navigate administrative requirements will be heard. Others may opt to be silent. Transparency should shed the light on organized lobbying, not create barriers between small business owners and their elected representatives.
Thank you. I welcome your questions.