Thank you.
Good afternoon, chair and members of the committee. Thank you for the opportunity to appear before you today.
My name is Jodene Baker, and I'm the vice-president of research, advocacy and external relations at Imagine Canada.
Imagine Canada is a national charitable organization dedicated to strengthening Canada's charitable and non-profit sector through research, advocacy and sector-wide initiatives. Canada's charitable and non-profit sector includes more than 170,000 organizations working in communities across the country. The sector contributes 8.4% of Canada's GDP, employs nearly three million people and is supported by approximately 13 million volunteers.
Organizations across our sector work every day on issues such as housing, poverty, disability inclusion, mental health and newcomer settlement, to name a few, giving them direct insight into community needs and the impact of public policy.
The non-profit sector supports transparency and accountability in public decision-making, and we support the objectives of the Lobbying Act.
The issue before this committee is not whether transparency matters; it is whether the act continues to strike the right balance between transparency and participation in public policy discussions. Recent changes to the interpretation of the in-house lobbying threshold have created significant concern across the non-profit sector. For many non-profit organizations, engagement with government is not carried out by dedicated government relations staff. It is often one responsibility among many for executive directors, program staff, researchers and other employees. These organizations participate in consultations, respond to requests for information and provide evidence and expertise to government.
As organizations have worked to understand the implications of the new interpretation, we have heard concerns about administrative burden, uncertainty regarding what activities count towards the threshold and the risk of unintended non-compliance. For many organizations, the issue is not just the threshold itself; it is also the loss of predictability that comes when a long-standing interpretation changes.
Ultimately, the larger question before this committee is not simply where the threshold should be set. The more fundamental question is why Parliament included a threshold in the first place.
Consider a small non-profit delivering services in its community. An executive director might spend a few hours responding to a government consultation and participating in a discussion about program design, and another staffer may share what they're hearing from the communities they serve. The question is whether these are the kinds of activities that Parliament intended to capture when it established the “significant part of the duties” threshold.
Parliament could have required registration for every interaction with government but instead chose to distinguish between sustained lobbying activity and occasional engagement. That distinction helps focus transparency requirements on significant lobbying activities while recognizing that engagement with government is often a normal part of how charities and non-profits fulfill their missions.
Transparency matters, but participation matters as well. As Parliament considers changes to the act, it's important that registration requirements do not inadvertently discourage charities and non-profits from participating in public policy discussions.
Transparency also depends on organizations' being able to understand and comply with the rules. Clear and predictable requirements make compliance easier and more effective. For that reason, our primary recommendation is that Parliament clarify the meaning of “significant part of the duties” so that it captures significant lobbying activity while avoiding unintended consequences for organizations whose policy engagement is limited or incidental.
More broadly, Parliament should ensure that the act is applied proportionately and reflects the realities of non-profit organizations, in which staff who engage government are often also responsible for program delivery, fundraising, volunteer management and community engagement. The Lobbying Act should promote transparency while ensuring that charities and non-profits can continue to contribute their expertise and community perspectives to public policy discussions.
Thank you. I look forward to your questions.