Information & Ethics Committee on June 1st, 2026

[Kyle Larkin, President and Chief Executive Officer, Canadian Meat Council, As an Individual]

Thank you, Chair.

Thank you to the members of the committee for inviting me today.

My name is Kyle Larkin. I am appearing before you in my capacity as a not-for-profit executive who has spent more than a decade engaged in federal and provincial lobbying activities. The views I express today are based on my own experience as a government relations professional and do not reflect the positions of any organizations with which I am currently affiliated.

I appreciate the opportunity to discuss the Lobbying Act, which governs my professional activities on a day-to-day basis.

I would like to begin by addressing several recommendations recently presented to this committee by the Commissioner of Lobbying that raised significant concerns for not-for-profit associations.

First, the commissioner recommended amending the act “to deem members of boards of directors to be ‘employees’”. While this may appear to be a modest change, it would significantly expand the scope of both the act and the commissioner's mandate, by capturing Canadians who volunteer their time to serve on not-for-profit boards. Individuals who are not professional lobbyists, including farmers, nurses, engineers and other community leaders, could be required to register simply for advocating on behalf of their neighbours, colleagues and industries.

Second, the commissioner recommended requiring the “Disclosure of all entities” with a direct interest in the outcome of lobbying activities. Associations, by their very nature, are a collective of individuals or organizations united around a common purpose. This proposal would require many not-for-profit associations to publicly disclose and continually update their membership lists. For associations with individual memberships, this could mean publishing the names of tens of thousands of individuals in a public registry, although those members never agreed to such a disclosure.

Third, it was recommended that the act be amended to require the “Disclosure of all funding provided to support lobbying activities”. Given that advocacy is often a core purpose of not-for-profit associations, this proposal could effectively require the disclosure of nearly all membership dues and funding sources. With many not-for-profit associations comprising small teams and operating on limited resources, this could create a substantial administrative burden while providing limited additional transparency.

Finally, the commissioner recommended requiring all communications with designated public office holders to be reportable “regardless of whether such communications are oral or written” or pre-arranged. This would mean that even unsolicited emails that are never opened or responded to could become reportable communications.

It would also require both lobbyists and public office holders to account for virtually every interaction they have with one another. Such interactions could include passing one another on the street, exchanging pleasantries at a reception or encountering each other at the airport. The result would be hundreds of thousands of additional communication reports and a significant administrative burden for both lobbyists and public office holders.

These recommendations, along with others advanced by the commissioner, would not only have a disproportionate impact on not-for-profit associations but also increase regulatory complexity for lobbyists and public office holders alike. Moreover, ongoing ambiguity within the act, combined with limited parliamentary oversight, has resulted in evolving interpretations that continue to create uncertainty within the profession.

One example is the 2023 revision of the Lobbyists' Code of Conduct, particularly with respect to hospitality. Despite testimony before this committee indicating that the $40 hospitality threshold for food and beverages would be adjusted for inflation, that threshold has remained unchanged since 2023. Without a meaningful adjustment, parliamentary receptions hosted by not-for-profit associations—an important forum through which Canadians can engage with their elected officials and senators—may become increasingly difficult to organize and sustain.

In closing, lobbying is already among the most highly regulated professions here in Canada. Lobbyists are committed to operating transparently, ethically and accountably. At the same time, we must ensure that our legislative and regulatory frameworks remain practical, internationally competitive and respectful of the important role that not-for-profit organizations play in representing Canadians. While there's certainly room to improve the Lobbying Act, any reforms must preserve Canadians' fundamental ability to participate in and advocate within our democratic institutions.

Thank you again for the invitation. I'd be happy to take any questions.

[The Chair, Conservative, John Brassard]

Thank you, Mr. Larkin. You get an ethics participation ribbon for being under five minutes. I appreciate that.

Ms. Baker, you have up to five minutes to address the committee. Go ahead.

[Jodene Baker, Vice-President, Research, Advocacy and External Relations, Imagine Canada]

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.

[The Chair, Conservative, John Brassard]

Thank you, Ms. Baker.

We're going to start with our six-minute rounds, and Mr. Barrett will go first.

Go ahead, sir.

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

Mr. Larkin, you raised concerns about the broader registration rules. Can you give the committee concrete examples of how that disclosure itself would discourage legitimate participation in policy-making?

Also, I know you spoke to administrative burdens. Could you expand on that point a little for our benefit?

[Kyle Larkin]

The third recommendation I highlighted from the commissioner was around adding to your registration all of those who benefit from your lobbying activities. For not-for-profit associations that may have 1,000 members, 20,000 members or 100,000 members, who could be nurses, farmers, etc., all of them would benefit from the outcome of the lobbying that those associations participate in. Therefore, my interpretation, at least, is that the membership list would need to be included in the registration.

The other piece is on volunteers versus paid employees. Since the Lobbying Act was created, there's always been a distinction between paid employees and volunteers. The recommendation that the commissioner put forward would loop volunteers into that registration. For boards of directors I have worked on in the past, with individuals—be they farmers or whoever—who volunteer their time to be on these not-for-profit association boards, now they would have to create their own registrations with the lobbying commissioner, despite receiving zero dollars from the not-for-profit association.

Those are some of the challenges I highlighted.

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

Do you think that would reduce participation by those volunteers?

[Kyle Larkin]

There could be a case of that, but I think it's a bigger question of small and medium-sized enterprises or even just Canadians who get involved in not-for-profit associations and advocate on behalf of their industry, their neighbours and their colleagues—and then have to register for something when they didn't need to do that before.

To be frank, that shouldn't be a requirement, because they receive zero dollars from their activities. They're really advocating on their own behalf as volunteers. If you follow that path down the line, you get to a world in which your small business in X constituency advocates to its local member of Parliament for an immigration issue, a CRA issue or whatever it might be and then needs to register and report.

Jodene spoke a bit about the eight hours versus the 32 hours and the definition of what is a significant part of your duties. You also start to go down that path that really impacts small businesses or even just individuals who are advocating to their local member of Parliament.

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

When someone helps to shape policy or they influence a change that materially benefits their employer, their organization or their client, what do you think is the level of disclosure that Canadians are entitled to?

[Kyle Larkin]

That's a great question.

The level of disclosure is currently available through the lobby registry in terms of disclosing money received from government, all the subject matters you're lobbying for and all the meetings you've had that are prearranged and oral.

The current federal lobby registry is framed through a transparent method. As a lobbyist for 10-plus years, I believe in transparency. I believe Canadians should know about everything I'm doing as a lobbyist and the individuals I meet with, but there needs to be a line between transparency and overburdening not-for-profit associations that may have just one, two or three employees.

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

This should be reserved for people who are being remunerated and not capture volunteer activities.

[Kyle Larkin]

That's correct.

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

Thank you very much for your reply.

Ms. Baker, you raised the threshold that Parliament had originally included. That was so that ordinary Canadians, small businesses, charities and local organizations wouldn't be buried in paperwork for that occasional contact with government. What kind of reform or change should take place so that we preserve this protection?

[Jodene Baker]

In our submission, the recommendation we have made is to go back to the 32 hours. The fundamental question is around a reference to a threshold at all in legislation. The commissioner has recommended registration by default, which would remove that. Our recommendation is to retain that and have it more clearly articulated within legislation around what that threshold should be.

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

Is the number, 32 hours, important? What do you think? In 30 seconds or less, which is what I think the chair would tell you, how would you design it?

[Jodene Baker]

I don't think I would come to that number today. I've heard other witnesses mention the need for consultation. It is about balancing the transparency piece with the participation aspect.

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

It is about avoiding any kind of sophisticated effort to exploit loopholes.

[Jodene Baker]

Yes.

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

Thank you.

[The Chair, Conservative, John Brassard]

Thank you, Mr. Barrett.

We'll go to Mr. Al Soud for six minutes.

Go ahead.

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

Thank you, Chair.

Thank you both for taking the time to be with us today.

Ms. Baker, for several years I had the privilege of working and volunteering for the Canadian Red Cross, primarily in fundraising, philanthropy and stakeholder relations, as well as in disaster management and emergency response. The CRC is, if I recall correctly, a member of Imagine Canada, so I will start by taking a moment to thank you for the work you do.

My time at the CRC intersected with some of the most significant challenges the organization has seen in its history, tied to various natural and conflict-related catastrophes, so I say the following with every conviction in the world: The non-profit sector plays a fundamental role across our country, doing some of the most important work of all, often with far less resources than they might need.

As we conduct this review of the Lobbying Act, I'd like to offer you the opportunity to speak to the importance of that work, as well as the importance of striking the balance between transparency mechanisms while ensuring that unintended consequences do not end up disproportionately impacting them.

[Jodene Baker]

Thank you for your question and for your previous work in the sector.

The non-profit sector really is the connective tissue between what Canadians are experiencing in their everyday lives and the government, so having that line of communication between charities and non-profits and the government is essential to a healthy and functioning democracy. We support transparency, so we believe that if there are charities and non-profits engaging in sustained lobbying activities, that should be registered and reported on.

However, if you get to the tipping point at which there is the burden of reporting, you risk both the burden of work—which means those staff at charities and non-profits have less time to put towards the actual delivery of programs and services—and a reluctance to even engage with government, which means that government is now missing important information to inform its program and policy design.

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

That's a fantastic answer.

Your brief touches on this to some extent, so I'd like to ask you this question: How do you believe the Lobbying Act could introduce more proportionate reporting approaches for smaller organizations?

[Jodene Baker]

The first point is maintaining a distinction between sustained lobbying and occasional engagement. On maintaining a threshold, our recommendation would be to go back to the 32 hours. Also, this would go over to the commissioner's office around clarity on what activities do and do not count. We've been seeing some confusion over the last several months around activities such as preparation for meetings.

We've heard a lot of references to work related to grants and contributions, so more plain language guidance and perhaps an online tool specifically for charities and non-profits would help them navigate the regulation and compliance environment more efficiently.

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

The sector will often see collective advocacy efforts. In your brief, you note in recommendation three the need to “Clarify the treatment of coalition and sector-wide advocacy”.

Could you speak to this a little more?