Information & Ethics Committee on Oct. 6th, 2025

[Nancy Bélanger]

Good question.

I believe in zero, and it should be zero. Unfortunately, according to the wording used in the act, the work is collectively “a significant part of the duties.” Those words must have meaning. I have to make a legislative interpretation. Unfortunately, if I set the thresholds at three hours, the court will probably say that it isn't “significant”, which means “noteworthy”.

I looked at the practices of other jurisdictions that use the same language as us. I did a quick analysis of what might be noteworthy. In my opinion, it's eight hours over a one‑month period. The equivalent of about one work day over a one‑month period is noteworthy.

It should be zero. I completely agree with you. However, this change must be made in the act. Unfortunately, I can't interpret the act to imply that the word “significant” means zero. I think that I would have a hard time winning that argument in court.

[Luc Thériault, Bloc, Montcalm, QC]

If we were to amend the Lobbying Act, for example, that would give you an opportunity to make improvements.

Lobbying is easy to recognize. As soon as a person opens their mouth…

I didn't understand why the threshold was lowered from 32 hours to eight hours a year. Even a threshold of 32 hours seems excessive.

[Nancy Bélanger]

When the act came into force in 1995 or 1996, the members of this committee acknowledged the vague and ambiguous nature of the words “significant part of the duties” of a lobbyist. They decided to give the registrar—now we would say the Commissioner—the authority to interpret what this meant. It was a start.

We decided to draw inspiration from the United States, where the “significant part” of the duties amounted to 20%. Over a one‑month period, this 20% equates to 32 hours.

However, since I've been coming to this committee, I've wanted the act to change. In my opinion, it was really time to lower this threshold. I lowered it to eight hours. I think that it's reasonable to consider this number a “significant part of the duties” of a lobbyist. Those are the words used in the act. That's why I lowered the threshold.

I gave interviews to the media. One person wrote to congratulate me on my excellent initiative, but said that lobbying activities should be limited to one hour. I completely agree with that person. However, I must comply with the wording of the act.

[Luc Thériault, Bloc, Montcalm, QC]

Your recommendation to lower the lobbying limit from 32 hours to eight hours shouldn't be considered the threshold for compliance. The number of hours could also be reduced to zero.

[Nancy Bélanger]

In British Columbia, that's the default practice. It's the norm. The province has provided for a few exceptions, such as when an employee of a company with fewer than six employees spends less than 50 hours a year on lobbying activities. I'm told that these types of organizations are few and far between.

You can talk to people in British Columbia to learn about their practices.

[Luc Thériault, Bloc, Montcalm, QC]

I wanted to discuss another matter.

The departmental plan states that the Office of the Commissioner will continue to reduce barriers to accessibility on its website and in the registry of lobbyists.

What improvements have been made?

[Nancy Bélanger]

We asked the Office of Public Service Accessibility to assess the registry of lobbyists and our website. Some pages didn't meet accessibility standards. We needed to make some technical improvements, particularly in terms of colours and font size. This work is now complete, and we should receive an A+ rating.

[Luc Thériault, Bloc, Montcalm, QC]

Oh, really?

[Nancy Bélanger]

We should.

[Luc Thériault, Bloc, Montcalm, QC]

So, in terms of accessibility—

[Nancy Bélanger]

So far, so good.

We had the assessment carried out to ensure that we met the standards. We recently conducted a survey, but I haven't seen the results. I think that it will be completed in the coming weeks.

[Luc Thériault, Bloc, Montcalm, QC]

I'll ask you a question that you don't have to answer.

When I read that the Lobbying Act hadn't been reviewed since 2012, I wondered how that was possible.

Do you have an explanation for me?

[Nancy Bélanger]

How is that possible? It isn't for lack of trying on my part.

I think that the committee members know this. Since my appointment in 2017—

[Luc Thériault, Bloc, Montcalm, QC]

Is there an explanation?

[Nancy Bélanger]

I don't know whether there's an explanation. However, I can tell you that other priorities have emerged, such as the pandemic.

This committee had other studies on its agenda. The review of the Lobbying Act was constantly postponed.

I'm pleased that a motion has been moved in this area. It's a step in the right direction.

[The Chair, Conservative, John Brassard]

Your time is up, Mr. Thériault.

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

[Gabriel Hardy, Conservative, Montmorency—Charlevoix, QC]

Thank you, Mr. Chair.

I want to thank the witnesses for joining us today.

For the people tuning in, lobbying is an activity that involves approaching public officials, such as elected representatives or public servants, to influence their decisions, policies or legislation for the benefit of a group. That's the definition provided for “lobbying activities”.

I say this every time I meet with someone here. People are losing confidence in our institutions, as you said earlier, Ms. Bélanger.

Do you feel supported enough? I have another question coming up.

You said earlier that we used to be an international leader in lobbying, but that we're losing our status.

For how many years has Canada been losing its status as a leader?

[Nancy Bélanger]

This decline has likely been going on since 2016 or 2017, when the review should have been done. The legislation in British Columbia was passed in 2020.

[Gabriel Hardy, Conservative, Montmorency—Charlevoix, QC]

We knew this back in 2012. Since 2016 or 2017, we've felt that this issue hasn't been considered important or a priority in Canada.

[Nancy Bélanger]

The reality is that many pieces of legislation in the pipeline around the world contain good features that would be worth considering here.

[Gabriel Hardy, Conservative, Montmorency—Charlevoix, QC]

We're lagging. We haven't dealt with this issue. To a certain extent, I agree with my colleague. I had planned to ask the following question. Why isn't it a priority for our government to ensure that our lobbyists comply with the legislation?

I'll move on to another question. We were talking about 32 hours, which amounted to 20%. We're now down to eight hours. Is this because there are more and more lobbyists? Have you seen an increasing number of lobbyists?

[Nancy Bélanger]

I've noticed an increasing number of lobbyists. However, I also saw that, in 2024, for example, 22 days of unregistered lobbying took place.

[Gabriel Hardy, Conservative, Montmorency—Charlevoix, QC]

Why have we ended up in a world with more and more lobbyists? Is it because people realize that, deep down, paying for a nice lunch here and there and exerting a little influence actually works?

[Nancy Bélanger]

I hope not. I've introduced rules regarding nice lunches here and there. I hope that there aren't too many of these nice lunches.

I think that lobbying is useful and valuable for each and everyone one of you who must make decisions that benefit Canadians. You need to know their concerns. You need to have data. People roll their eyes when they hear the word “lobbying”. However, it's a good thing, as long as the process is transparent and ethical.

I did what I could in terms of ethics, but we really have a transparency issue here. I read newspaper articles and conduct investigations. Trying to substantiate 32 hours of lobbying is nearly impossible. Furthermore, it isn't good to see all these unregistered meetings taking place. We need transparency.

[Gabriel Hardy, Conservative, Montmorency—Charlevoix, QC]

It's a bit like the wild west. The structure is no longer strong enough, and, as you said earlier, the penalties aren't severe enough to make lobbyist groups realize that they're crossing the line and that they need to stop.

I would also like to hear about the number of offences that you have referred to the RCMP compared to the number that work their way through the process and come back to you.