Good afternoon, Chair and members of the committee. Thank you for the opportunity to appear today.
My name is Muhammad Ali. I'm the vice-president of the volunteer board of directors of the Government Relations Institute of Canada. GRIC is a national not-for-profit association representing government relations and public affairs professionals across all sectors of the Canadian economy. Our membership includes both consultant and in-house lobbyists.
Let me begin with one foundational point: Canada already operates one of the most transparent and rigorous lobbying regimes in the world. That is not to say the act cannot be improved, but any amendments should be grounded in clear evidence of a problem and must strike a careful balance between seemingly enhancing transparency and preserving Canadians' open access to government. Our recommendations are guided by that principle. GRIC has put forward six recommendations, but I'll focus on two today.
First, the Lobbying Act does not define the phrase “significant part of duties”, which determines when a corporation or organization must register for in-house lobbying. In the absence of a statutory definition, the threshold to meet a significant part of duties has been set through interpretation by the Office of the Commissioner of Lobbying, OCL. For over a decade, this threshold was interpreted as 32 hours over four weeks across employees. In July 2025, it was reinterpreted as just eight hours—a 75% decrease—without clear public evidence of widespread non-compliance nor robust consultation to justify such a change.
It is important for this committee to understand what this threshold includes. It captures not only time spent meeting with government officials and elected officials, but also the preparation time, internal strategic decisions and any written communications, as well. In other words, this is not just a measure of time spent lobbying in meetings; it is a measure of the total time connected to those interactions.
Consider a local, family-owned small business in your riding, like a restaurant or a farmer, or consider a food bank facing an urgent issue. Over a few days, staff meet internally, prepare materials to brief you, as their local MP, email your office, meet with you and then meet again internally to debrief on the meeting. Perhaps there is a follow-up meeting with you, as their MP, to present further information to help them. Their collective time spent could easily reach eight hours just before that one meeting. Now, they are required to register under the law. These are not professional lobbyists. They are Canadians engaging with their elected representatives to seek help.
Going even further by potentially expanding the regime to that of registration by default by getting rid of “significant part of duties” altogether from the act, as has been proposed by the OCL, would significantly broaden the scope of the act. This risks imposing even further unnecessary administrative burden and red tape on small organizations and could overwhelm the registry with low-value filings, which would ultimately reduce meaningful transparency.
Given how central this concept is to the act, GRIC believes that “significant part of duties” should be defined in the legislation and not left to OCL interpretations that could be changed without any industry consultation. We recommend restoring it to 32 hours over four weeks, ensuring the system remains focused on capturing sustained lobbying activity.
Second, GRIC recommends maintaining the current requirement that only oral communications that are arranged in advance and initiated by lobbyists be reportable, and that reporting continues to focus on senior civil servants along with other designated public office holders, including, as the OCL has suggested, staff of the office of the Leader of the Opposition. The OCL's proposal to expand reporting to all communications, whether they are written or unarranged, would significantly flood the registry with insignificant communications and add limited transparency value.
Such changes could also create unintended consequences. Public office holders could be associated with interactions they did not agree to, including unsolicited written communications, such as emails and letters.
Transparency is most effective when it captures deliberate, substantive engagement, not incidental or informal exchanges. Fundamentally, designated public office holders, such as yourselves, should continue to have the authority to decide who they meet with and when. Government decisions are not shaped simply by chance encounters at the airport, your local community event or a letter. Similarly, expanding reporting requirements to include all public servants present at meetings would dilute the registry's usefulness. The current focus on senior decision-makers reflects how government decisions are actually made.
Our other recommendations include defining “undertaking” in the act, reducing post-employment bans, improving clarity in the code of conduct and including paid board directors in organizations' registrations.
In conclusion, Canada's lobbying framework is the strongest in the OECD. We welcome changes that are evidence-based, proportionate and focused on improving transparency where it matters most without limiting Canadians' democratic ability to engage with their elected officials.
Thank you. I look forward to questions.