Information & Ethics Committee on June 1st, 2026

[Kyle Larkin]

That's a great question, Mr. Cooper. Thank you for the question.

I'd say two things to that. First of all, in the section you read of the Lobbying Act, that is definitely correct. I would say that really influences what a registrable activity is and what requires not-for-profit associations to register. Having worked in the consulting world and worked with many different associations, the question we always got was, should I register? Our answer, 99% of the time, was yes, you should register.

The other issue, though, is when and if a communications report is required. I, as a professional lobbyist, am at a reception, and I run into five members of Parliament. I want to talk to them and ask, “How's this act going? How's this bill going? Have you heard about this regulation? Have you heard about this issue?” Quick, 30-second conversations like that at a reception over a beer or a cocktail would now require a communications report.

The same would go for social media posts. If an association puts out a post that says, “Prime Minister Carney, you need to do X, Y or Z”, it now requires a communications report. It really opens Pandora's box for communications reports, which I think is extremely concerning. As I said, British Columbia has already opened that Pandora's box. It's not an area I would recommend the federal law go into.

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

Your recommendation is to leave it as is.

[Kyle Larkin]

I believe that—

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

I take your point, up to a point. It seems to me that, for many circumstances in which communications are happening, it goes to the heart of what constitutes lobbying under the act when, for technical reasons, there is no legal requirement to file a report or to register. That is what has concerned the lobbying commissioner. What is your response to those activities beyond a very brief interaction with a member that are not all that substantive in moving any kind of needle?

[Kyle Larkin]

It's a great question. There needs to be a line created. That line, for years now, has been created on oral and arranged communication, for the right reasons.

If I set up a meeting with you, Mr. Cooper, and I lobby you on X, Y or Z, there's a formal agenda. We've both agreed to participate in the activity of my lobbying you or advocating on behalf of a different industry or different professionals. I put in a communications report, and the commissioner could call your office and ask, “Hey, did Mr. Cooper meet with Mr. Larkin on June 1, 2026, to discuss X, Y or Z?” Your staff or you would have notes that we did meet, and you can confirm that. The commissioner does spot checks like that with public office holders.

If we eliminate the need for oral and arranged communication, all of a sudden, not only is there a plethora of extra communications reports coming into the office, but designated public office holders now would also need to recall every interaction they've had with a lobbyist at Tim Hortons, a reception, the airport, etc., in which that individual brought up a bill, a regulation, some kind of program or something else. That's where I find there's an issue in which things grow.

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

I take it from your answer that your position is, with respect to the reporting requirements, to maintain the status quo. Do not make a change is your recommendation.

[Kyle Larkin]

Exactly. Oral and arranged communication works the best because that's when real, formal lobbying and the actual act of lobbying happens.

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

Thank you.

[The Chair, Conservative, John Brassard]

Thank you, Mr. Cooper.

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

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

Thank you very much, Mr. Chair.

I was surprised to see that you were one of the witnesses we were receiving today, given that you usually appear before the Standing Committee on International Trade. Since you're involved in lobbying, I believe you're well positioned to speak about the review of the Lobbying Act. Still, I was surprised to see your name, but I'm glad that you're here and able to talk about it.

Have you been doing this for a long time?

[Kyle Larkin]

I've been a lobbyist for 10-plus years, and it's an industry I'm extremely passionate about. I used to work on Parliament Hill for a few members of Parliament, receiving lobbying on the other side. I wanted to get into this profession, and I've enjoyed it ever since.

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

We won't be talking about pork and beef today. Okay.

I know you briefly mentioned your perspective earlier, but do you think the 10-day filing deadline proposed by the Lobbying Commissioner is appropriate? Just before your appearance today, we received Ms. Sabourin, who is still in the room, as well as Mr. Shore, and both of them instead advocated for a 30-day filing deadline. Do you believe that a 30-day period is the most appropriate benchmark to give registered individuals enough time to conduct thorough and thoughtful assessments, and that it would help avoid the risk of inadvertent non-compliance?

[Kyle Larkin]

Yes, I think so.

I've seen with former clients that life sometimes gets in the way of things. You lose a loved one; you go on vacation, or something happens in your life. You had a lobbying meeting on the Friday and then you're out of the office for the next three weeks because something unfortunate happened.

It's important to provide as much flexibility to lobbyists as possible while also ensuring that the act, the code and the way lobbyists are treated are still transparent, because transparency and accountability are paramount for the profession. It already has a negative connotation in the public sphere. We need to ensure that Canadians know that we're as accountable and as transparent as possible.

Allowing as much flexibility as possible is good.

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

Thank you. I understand what you mean; it can be very difficult to meet the 10-day deadline given the uncertainties of life.

As a member of the Canadian Meat Council, can you tell us to what extent industry associations help provide the government with the expertise needed to develop good public policies?

[Kyle Larkin]

That's a great question.

I've had the pleasure of working with provincial and national not-for-profit associations for about 10 years now, in many different industries, from farming to meat, intellectual property, construction, chemistry and all over the board. The role they all play here in Ottawa with parliamentarians, and even in provincial legislatures, is really to be a bastion of information.

You folks know that you do not have the time to meet with 100,000 farmers, 20,000 auto workers, 50,000 people who work in our forestry sector or whatever it may be. That's why not-for-profit associations exist. It's so that you can meet with one individual or a few individuals who represent that industry. They can provide you with a general idea of the issues the industry is facing, what works well and what doesn't work well in terms of bills, acts, regulations or programs, etc.

Their role is fundamental to Canadian parliamentary democracy in terms of shaping various policies and legislation. They represent Canadians and Canadian businesses that otherwise wouldn't be represented here in Ottawa.

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

Thank you. That's very interesting. Before entering politics, I worked as a treasurer at the Association des détaillants en alimentation du Québec. It took me back to my beginnings.

Based on your experience, does the current framework allow for effective dialogue between public decision-makers and actors in the strategic economic sector?

[Kyle Larkin]

Yes, I think that the Lobbying Act right now fills the purpose that Parliament, the House of Commons and the Senate intended it to, but as I said earlier, there's always an issue in terms of interpretation of the Lobbying Act, which is the role of the commissioner.

From my previous experience, I find that the parliamentary oversight on the interpretations isn't fully understood, so interpretations can happen that really impact the profession day to day without any recourse from this committee, from the House of Commons or from our elected body here in Canada.

That's always been a concern. One area in which the Lobbying Act could be improved is the five-year lobby ban. Looking internationally, what do other countries have as a lobbying ban? You're a designated public office holder, and you want to get into lobbying. How much time do you have as a cool-off period?

In Canada, it's five years. The average internationally is much lower than that. If you take an average of all our OECD or G7 partners, you're looking at four years. We're one year above. That's why I said in my testimony that we have one of the most onerous lobbying acts in the world. What I've seen in my career is that it really prevents a lot of young individuals from getting into lobbying or even from getting into a minister's office or into some designated public office position.

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

Thank you very much.

[The Chair, Conservative, John Brassard]

Thank you, Mr. Larkin.

Thank you, Ms. Lapointe.

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

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

Thank you.

Mr. Larkin, we've learned that Yukon has added the concept of “directing mind” to the definition of “lobbyist.” This definition therefore includes individuals, self-employed workers and directing minds.

I'm wondering about something. In your opinion, is this a useful concept? Is this something we should replicate in the Lobbying Act here or would it not change anything?

[Kyle Larkin]

I haven't heard that proposal before. Even though I've lobbied in every single province in Canada, I haven't lobbied in the territories.

I've never been registered in the Yukon, but we see that there's a similar system, from my understanding, in Alberta, in which you have an account manager and then all the lobbyists who fall under that.

At the federal level, we see that already for in-house organizations. The senior-most officer—myself, for example, at the association I work at right now—is the registered individual, and under that name are all of those at the association who lobby on behalf of the organization.

At the federal level, the way that in-house registrations are encapsulated and built is the right direction to go. I think it would be quite onerous for each individual in an association to have to create their own lobby registry when we're all advocating on behalf of one association and for one set of issues.

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

I have another question, which I don't think I've asked you, but my memory might be playing tricks on me. In your opinion, should members of a board of directors be considered lobbyists or not? Should their obligations be treated differently?

[Kyle Larkin]

Most not-for-profit associations don't pay their board of directors, because they don't have money to pay their board of directors. Most of the individuals on the boards I've worked with in the past are volunteers. They're volunteering their time because they're passionate about their industry. They're passionate about growing their industry and ensuring that their industry is successful. I do not think that those individuals should need to register. They lobby on a very infrequent basis.

If we have a lobby day in Ottawa, for example, to bring the board of directors in, and they meet with 20 members of Parliament in one day, that's maybe the limit of the advocacy or the lobbying work that they do in one year. I don't think that those individuals should have to register. They are volunteers. It opens a Pandora's box. If we start to look at volunteers as professional lobbyists, how does that apply to the coffee shop in your constituency or the small business in other constituencies, etc.? We start to go down a slippery slope, in my opinion.

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

You say that volunteers are people who are passionate. They represent the organization that they manage simply because they're passionate about the organization's mission. However, it is a form of compensation. Actually, that's not the right word, but they derive a kind of advantage from it.

Isn't it important to make public any involvement with the government, whether that person is a volunteer or an employee? If there's a difference, I'll let you explain it to me.

In my mind, initially, take the Canadian Meat Council, for example; if someone from the council intervenes with the Minister of Finance, whether it's the board director, an independent lobbyist, or a volunteer, that's still lobbying. Should it not be treated the same way, in your opinion?

[Kyle Larkin]

There needs to remain—and there currently is—a distinction between professional lobbyists who are paid and volunteers on boards of directors, who could be day-to-day farmers, nurses, engineers or teachers; you name the profession. I still believe very fundamentally that there needs to be a distinction between those two types of individuals.

For those who are professional lobbyists, as I have been over the past 10-plus years, every single day is about lobbying. Every single day is looking at what's happening in the House of Commons and what's happening at these committees. Okay, we need to meet with these members of Parliament on this issue. We need to meet with these ministers or ministers' offices on this issue. Every day as a lobbyist, you're thinking about lobbying. You're thinking about how you can influence the Government of Canada to go one way or another on a policy or a program that impacts 100,000 or 50,000 Canadians. That's the day-to-day life of a lobbyist.

In the day-to-day life of individuals who volunteer on boards of directors, they may meet four times a year. One of those meetings is here in Ottawa, and they meet with a few members of Parliament. Otherwise, they're tilling their fields; they're nursing patients, or they're teaching children. They're doing their actual job. Just because they're volunteers on a board of directors, that doesn't mean they should be required to register.