Mr. Chair, members of the committee, thanks for the opportunity to appear before you today.
My name is Dylan Hanley. I'm the senior vice-president for public affairs at CIJA, the advocacy agent of Jewish Federations of Canada, representing hundreds of thousands of Jewish Canadians.
Thank you for the opportunity to address you as you undertake the statutory review of the Lobbying Act.
That's all the French that I will attempt. My apologies for it. I'm working to make sure my kids are properly bilingual.
At its core, our concern is not about any single provision of the act. It's about whether Parliament's intent, clearly expressed through legislation and committee recommendations, is being upheld or effectively overridden through administrative interpretation by the Commissioner of Lobbying.
We have concerns in two areas: sponsored travel of parliamentarians and parliamentary internship programs.
First is sponsored travel. Parliament allowed sponsored travel because it recognized its value. Public office holders benefit from direct first-hand exposure to complex global issues they're asked to weigh in on. CIJA's missions to Israel are structured, non-partisan and educational. Participants engage with Israeli, Palestinian and Canadian officials, as well as experts, journalists and civil society.
However, the current interpretation, advanced by the Office of the Commissioner of Lobbying, has created a clear contradiction. Parliament clearly permits sponsored travel under section 15 of the conflict of interest code, but the regulatory approach effectively prevents participation by including sponsored travel under gifts with a $200 limit. In practice, this has largely nullified the exemption Parliament deliberately created, undermining the will of parliamentarians.
We are already seeing the impact. According to the Ethics Commissioner's most recent annual report, only 15 MPs participated in sponsored international travel in 2025, the lowest number in 15 years.
Second is parliamentary internships, where the contradiction is even clearer. In 2002, CIJA established a multipartisan parliamentary internship program to give young Canadians first-hand experience working on Parliament Hill. The objective was simple: to expose participants to public service and inspire future careers in political life. In October 2018, the Ethics Commissioner issued an advisory opinion stating that interns placed by third parties constitute a benefit under the code, despite the code making no explicit reference to interns.
The following month, the Commissioner of Lobbying issued a ruling concurring with the Ethics Commissioner that providing paid interns to MPs free of charge is a gift or benefit. It's also considered a gift in the context of rule 10 of the Lobbyists' Code of Conduct. In compliance with the rules, CIJA immediately suspended the program.
Parliament has since spoken directly on this issue. In 2022, the Standing Committee on Procedure and House Affairs, whose report was concurred on by the House, stated clearly that parliamentary internships are invaluable opportunities and recommended that interns be excluded from the definition of benefit. Yet, despite that clear expression of parliamentary will, the outcome remains unchanged in practice. While the Ethics Commissioner has moved toward allowing internships, the Commissioner of Lobbying's interpretation continues to prevent organizations subject to the Lobbying Act from offering them.
Taken together, these cases point to a broader issue. The activities themselves are legitimate, educational and non-partisan. Parliament has either explicitly permitted them or, in the case of internships, clearly indicated its intent to do so, and yet regulatory interpretations made them impractical. This is not simply stricter oversight; it's divergence from Parliament's intent.
We're strongly supportive of both safeguards and full transparency for sponsored travel, public disclosure, and detailed reporting of participants and costs. For internships, there should be a clear exemption for sponsored interns alongside public disclosure of the sponsoring organization, the intern and the duration of placement. Transparency can address concerns without eliminating the programs themselves.
In closing, Parliament made its intent clear, both through legislation and through committee recommendations adopted by the House. We're concerned that current interpretations have, in effect, overridden Parliament's intent. We respectfully urge this committee to restore alignment between Parliament's will and regulatory practice.
Thank you.