By Terrance S. Carter and Adriel N. Clayton

Changes to Federal In-House Lobbying Registrations in Effect

A new, revised threshold for federal lobbying registrations is now in effect and may impact charities and not-for-profits that carry out lobbying activities by requiring more organizations to register under the federal Lobbying Act. The revised threshold was initially announced by the Commissioner of Lobbying through an Interpretation Bulletin released on July 16, 2025 (the “New Bulletin”), which came into effect on January 19, 2026, replacing the previous interpretation bulletin from 2009.

Under the 2009 bulletin, the Commissioner of Lobbying interpreted the phrase “significant part of the duties” under paragraph 7(1)(b) of the Lobbying Act, which sets out filing and registration requirements, such that organizations were generally required to register where the total amount of time spent by all paid employees carrying out lobbying work equalled 20% or more of the working hours of one employee. According to the backgrounder, this threshold “allowed for a substantial amount of in-house lobbying to go unreported and contributed to less transparency”.

The New Bulletin revises how the term “significant part of the duties” is interpreted and applied. Under the revised interpretation, the registration threshold will be met where employees collectively spend eight or more hours within any consecutive four-week period communicating with federal public office holders about the subject matters listed in paragraph 7(1)(a) of the Lobbying Act. Time spent preparing for meetings, drafting correspondence or submissions, and undertaking related grassroots communications on those same subject matters is included in the calculation, and the hours of multiple employees are aggregated. Communications relating solely to the awarding of federal government contracts do not count toward the threshold. Once the threshold is met, the organization’s most senior paid officer must file an in-house registration return within two months from the date the threshold is met.

New Digital Technologies Accessibility Regulations under the Accessible Canada Act

Regulations designed to improve digital accessibility have been published, with most provisions coming into force on December 5, 2027. The federal Regulations Amending the Accessible Canada Regulations (the “Regulations”) under the Accessible Canada Act were published in the Canada Gazette on December 17, 2025, and introduce new compliance obligations aimed at removing and preventing barriers in digital technologies used by persons with disabilities. Certain obligations, particularly those affecting mobile applications and digital documents, will come into force on December 5, 2028.

The Regulations apply to federally regulated public-sector entities and to federally regulated private-sector organizations that averaged 100 or more employees over the preceding three-year period, with more extensive requirements for organizations with 500 or more employees. As a result, most charities and not-for-profits will not likely be captured. However, the Regulations may be relevant primarily for larger organizations in federally regulated sectors. Smaller federally regulated private-sector entities are generally exempt. Applicability and compliance timelines depend on an organization’s size, sector, and activities, and some obligations do not apply to certain sectors, such as transportation, broadcasting, and telecommunications.

At the core of the new framework is the introduction of a dedicated “Information and Communication Technologies” section, which requires covered organizations to ensure that new or updated web pages, mobile applications, and certain digital documents conform to a prescribed national accessibility standard for information and communication technologies. In addition to technical conformance requirements, organizations must publish and maintain accessibility statements, conduct or obtain conformity assessments for certain digital assets, and provide accessibility training to employees involved in the development, maintenance, or procurement of digital technologies. Records of training, assessments, and accessibility statements must be retained for prescribed periods, and non-compliance may result in administrative penalties.

Further information on digital accessibility, including the amended regulations, is available in the Guidance Overview of Regulatory Amendments: Digital Technologies Phase 1.

Public Safety Canada Launches 2026 Supply Chains Act Reporting Portal and Updated Guidance

Public Safety Canada has opened the reporting portal for the 2026 compliance cycle under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “Supply Chains Act”), with reports due by May 31, 2026. This follows the Supply Chains Act’s enactment on January 1, 2024 and continues the federal government’s efforts to increase transparency around forced labour and child labour risks in global supply chains. As discussed most recently in the November 2025 Charity & NFP Law Update, the high threshold for qualifying as an “entity” under the Act means that only a limited number of charities and not-for-profits will be subject to these reporting obligations.

Alongside the opening of the portal, Public Safety Canada has also released an updated guidance and a revised online questionnaire. While the substantive reporting requirements remain unchanged, the updated materials provide additional clarity on completing the questionnaire, attestation and signature requirements, and the treatment of “very minor” supply chain dealings. As with previous reporting years, affected organizations must disclose information relating to their structure, supply chains, policies, risk-management and due diligence processes, training, remediation efforts, and assessments of effectiveness, all of which are made publicly available through Public Safety Canada’s online catalogue.

​Read the January 2026 Charity & NFP Law Update