Foreign Influence Transparency and Accountability Regulations: SOR/2026-152

Canada Gazette, Part II, Volume 160, Number 13

Registration
SOR/2026-152 June 22, 2026

FOREIGN INFLUENCE TRANSPARENCY AND ACCOUNTABILITY ACT

P.C. 2026-642 June 22, 2026

Her Excellency the Governor General in Council, on the recommendation of the Minister of Public Safety and Emergency Preparedness, makes the annexed Foreign Influence Transparency and Accountability Regulations under sections 22 and 27 of the Foreign Influence Transparency and Accountability Act ^{footnote a}.

Foreign Influence Transparency and Accountability Regulations

Interpretation

Definitions

1 The following definitions apply in these Regulations.

Act

means the Foreign Influence Transparency and Accountability Act. (Loi)

influence activities

means the activities referred to in the definition arrangement in section 2 of the Act. (activités d’influence)

registry

means the registry established by the Commissioner under section 8 of the Act. (registre)

Public office holder

2 For the purpose of the definition public office holder in section 2 of the Act, individuals who are included in any of the following classes and who are not already public office holders by virtue of paragraphs (a) and (b) of that definition are public office holders:

• (a) officers or employees of a division or branch of the federal public administration referred to in column I of Schedule I.1 to the Financial Administration Act, of a departmental corporation referred to in Schedule II to that Act or of a Crown corporation as defined in subsection 83(1) of that Act;
• (b) officers or employees of His Majesty in right of a province or of the government of a territory, including officers or employees of any provincial or territorial board, commission, office or tribunal and any individual, other than a judge of a provincial or territorial court, who is appointed to an office or body by or with the approval of the lieutenant governor in council or a minister of a province or territory;
• (c) officers or employees of a corporation that is wholly owned directly by His Majesty in right of a province or the government of a territory;
• (d) officers or employees of a municipal board or commission; and
• (e) trustees, officers or employees of a school board.

Provision of Information

Excluded arrangements

3 For the purpose of paragraph 6(2)(b) of the Act, section 5 of the Act does not apply to an arrangement to which any of the following is a party:

• (a) the Senate, the House of Commons or the Library of Parliament;
• (b) an office or committee of Parliament, the Senate or the House of Commons or an officer of Parliament, the Senate or the House of Commons who is acting in that capacity;
• (c) a division or branch of the federal public administration referred to in column I of Schedule I.1 to the Financial Administration Act;
• (d) a departmental corporation referred to in Schedule II to the Financial Administration Act;
• (e) a Crown corporation as defined in subsection 83(1) of the Financial Administration Act;
• (f) His Majesty in right of a province or the government of a territory;
• (g) the legislature of a province or territory;
• (h) the legislative library or research service of a province or territory, an office or committee of the legislature of a province or territory or an officer of such a legislature who is acting in that capacity;
• (i) a division or branch of the public administration of a province or territory, including a provincial or territorial board, commission or agency;
• (j) a corporation that is wholly owned directly by His Majesty in right of a province or the government of a territory;
• (k) a municipality or any division or branch of the public administration of a municipality, including a municipal board, commission or agency; or
• (l) a municipal council, an office or committee of a municipal council or an officer of a municipal council who is acting in that capacity.

Entry into arrangement

4 (1) For the purpose of subsection 5(1) of the Act, the information with which a person who enters into an arrangement with a foreign principal must provide the Commissioner is

• (a) if the person is an individual,
  • (i) their full name and any alternate names,
  • (ii) their date and place of birth,
  • (iii) their primary civic address and their mailing address, telephone number and email address, and
  • (iv) the full name and date and place of birth of any other individual who has carried out or is expected to carry out influence activities under the arrangement on their behalf and a description of those influence activities;
• (b) if the person is not an individual,
  • (i) their legal name and any other names under which they operate,
  • (ii) their primary civic address,
  • (iii) the full name, date and place of birth, mailing address, telephone number and email address of a person who is authorized to make representations on their behalf for the purposes of the Act,
  • (iv) any number that identifies them, such as an incorporation number, business number or charity registration number, and the jurisdiction that issued that number,
  • (v) in the case of a subsidiary, the name and primary civic address of its parent entity and the information referred to in subparagraph (iv) in respect of the parent entity,
  • (vi) their website address, if any, which may include a social media web page if that is their main Internet presence,
  • (vii) a description of the nature of their regular activities, including the products or services they provide or the activities they carry out, and
  • (viii) the full name and date and place of birth of every individual who has carried out or is expected to carry out influence activities under the arrangement and a description of those influence activities;
• (c) in respect of the foreign principal,
  • (i) their name,
  • (ii) their primary civic address, if any,
  • (iii) their website address, if any, which may include a social media web page if that is their main Internet presence, and
  • (iv) the full name, position title, telephone number and email address of their primary representative with whom the person has communicated or expects to communicate in relation to the arrangement; and
• (d) a description of the arrangement, including
  • (i) its start and end dates,
  • (ii) any compensation or other benefit that has been or is to be provided to the person by the foreign principal in relation to the arrangement,
  • (iii) the political or governmental process to which the arrangement relates,
  • (iv) the types of influence activities that the person has undertaken to carry out under the arrangement,
  • (v) in the case of influence activities described in paragraphs (b) and (c) of the definition arrangement in section 2 of the Act, the target of those influence activities, for example, public office holders, groups of Canadians or persons in Canada or private or not-for-profit organizations in Canada,
  • (vi) the details set out in subsections (2) to (4), as applicable, in respect of the influence activities that the person has undertaken to carry out under the arrangement, and
  • (vii) the foreign principal’s stated objective under the arrangement.

Details — communication with public office holder

(2) In the case of influence activities described in paragraph (a) of the definition arrangement in section 2 of the Act, the details that are to be provided in respect of those activities are

• (a) if the person has communicated or expects to communicate under the arrangement with no more than five public office holders, the following information in respect of each of them:
  • (i) their full name,
  • (ii) their position title, and
  • (iii) the name and jurisdiction of the entity of which they are an employee, officer, member or appointee and the name of their organizational unit, if any; and
• (b) in any other case, the classes — as set out in section 2 of these Regulations or in the definition public office holder in section 2 of the Act — of the public office holders with whom the person has communicated or expects to communicate under the arrangement.

Details — communication and dissemination of information

(3) In the case of influence activities described in paragraph (b) of the definition arrangement in section 2 of the Act, the details that are to be provided in respect of those activities are

• (a) the means by which the information relating to the political or governmental process has been or is to be communicated or disseminated, such as social media, television, radio, audio or visual recordings, emails, text messages, telephone calls, electronic or print publications, including newspapers and newsletters, and virtual or in person events or meetings;
• (b) if the means referred to in paragraph (a) include social media content or advertising,
  • (i) the names of all social media platforms that have been or are to be used,
  • (ii) all usernames or other identifiers that are associated with the accounts that have been or are to be used on each of those platforms, and
  • (iii) the name and URL of any forums, groups, threads, communities or channels that have been or are to be managed on each of those platforms by the holder of an account referred to in subparagraph (ii);
• (c) if the means referred to in paragraph (a) include television or radio programming or advertising, the names of the networks or stations on which the programs or advertisements have been or are to be broadcast;
• (d) if the means referred to in paragraph (a) include recorded audio or visual content or advertising, the titles of the recordings, if any, and the names of the platforms through which they have been or are to be made available;
• (e) if the means referred to in paragraph (a) include content or advertising in electronic or print publications, the names of those publications; and
• (f) if the influence activities target public office holders, the classes — as set out in section 2 of these Regulations or in the definition public office holder in section 2 of the Act — of those public office holders or, if no more than five public office holders are targeted, the following information in respect of each of them:
  • (i) their full name,
  • (ii) their position title, and
  • (iii) the name and jurisdiction of the entity of which they are an employee, officer, member or appointee and the name of their organizational unit, if any.

Details — provision of benefit

(4) In the case of influence activities described in paragraph (c) of the definition arrangement in section 2 of the Act, the details that are to be provided in respect of those activities are

• (a) if the influence activities include distributing money,
  • (i) the estimated maximum value in Canadian dollars of any single distribution of money, and
  • (ii) the estimated total value in Canadian dollars of all money that has been or is expected to be distributed;
• (b) if the influence activities include distributing items of value,
  • (i) a description of the items that have been or are expected to be distributed,
  • (ii) the estimated maximum value in Canadian dollars of any single item that has been or is expected to be distributed, and
  • (iii) the estimated total value in Canadian dollars of all items that have been or are expected to be distributed;
• (c) if the influence activities include providing services,
  • (i) a description of the services that have been or are expected to be provided,
  • (ii) the estimated maximum value in Canadian dollars of any single service that has been or is expected to be provided, and
  • (iii) the estimated total value in Canadian dollars of all services that have been or are expected to be provided;
• (d) if the influence activities include providing the use of a facility, for each facility, the purposes for which it has been or is expected to be used, such as hosting an event, conducting business or providing accommodations; and
• (e) if the influence activities target public office holders, the classes — as set out in section 2 of these Regulations or in the definition public office holder in section 2 of the Act — of those public office holders or, if no more than five public officer holders are targeted, the following information in respect of each of them:
  • (i) their full name,
  • (ii) their position title, and
  • (iii) the name and jurisdiction of the entity of which they are an employee, officer, member or appointee and the name of their organizational unit, if any.

Exception

(5) The details referred to in subparagraphs (1)(a)(iv), (b)(viii) and (d)(vi) are not required in respect of influence activities that are carried out before the day on which these Regulations come into force.

Updates

5 For the purpose of subsection 5(2) of the Act, the person must provide the Commissioner with an update setting out any change to the information referred to in section 4 no later than 14 days after the change occurs.

Registry

Contents

6 The registry must contain the information provided under section 5 of the Act that is included in the following classes, other than information for which there are reasonable grounds to suspect that it is false or misleading or that making it public would present a threat to an individual’s personal safety:

• (a) in respect of each individual who has entered into an arrangement, the information referred to in subparagraph 4(1)(a)(i) and the country and province, state or other political subdivision of their primary civic address referred to in subparagraph 4(1)(a)(iii);
• (b) in respect of every other person who has entered into an arrangement,
  • (i) the information referred to in subparagraphs 4(1)(b)(i), (vi) and (vii),
  • (ii) the country and province, state or other political subdivision of their primary civic address referred to in subparagraph 4(1)(b)(ii), and
  • (iii) as applicable, the information referred to in subparagraphs 4(1)(b)(iv) and (v), other than the parent entity’s primary civic address;
• (c) in respect of each individual referred to in subparagraph 4(1)(a)(iv) or (b)(viii), their full name and a description of the influence activities they have carried out or are expected to carry out;
• (d) in respect of each foreign principal with which a person has entered into an arrangement, the information referred to in subparagraphs 4(1)(c)(i) and (iii), the country and province, state or other political subdivision of their primary civic address referred to in subparagraph 4(1)(c)(ii) and the full name and position title of their primary representative referred to in subparagraph 4(1)(c)(iv); and
• (e) in respect of each arrangement, the information referred to in subparagraphs 4(1)(d)(i) to (v) and (vii), other than the amount of any compensation referred to in subparagraph 4(1)(d)(ii) and,
  • (i) if the arrangement involves influence activities described in paragraph (a) of the definition arrangement in section 2 of the Act, the information referred to in subsection 4(2),
  • (ii) if the arrangement involves influence activities described in paragraph (b) of the definition arrangement in section 2 of the Act, the information referred to in subsection 4(3), and
  • (iii) if the arrangement involves influence activities described in paragraph (c) of the definition arrangement in section 2 of the Act, the information referred to in subsection 4(4).

Retention of information

7 The Commissioner must retain the information contained in the registry for 20 years after the day on which the arrangement to which it relates ends.

Disclosure of Information

Disclosure to the Commissioner

8 The following entities are authorized to disclose information to the Commissioner and any other individual referred to in subsection 11(1) of the Act for the purpose of assisting the Commissioner in the performance of their duties and functions under the Act:

• (a) the government institutions set out in the schedule to the Privacy Act;
• (b) the office of the Conflict of Interest and Ethics Commissioner;
• (c) the office of the Commissioner of Canada Elections; and
• (d) the Canadian Armed Forces.

Disclosure by the Commissioner

9 For the purpose of paragraph 15(e) of the Act, the Commissioner and any person acting on their behalf or under their direction may, if they are satisfied that the disclosure will not affect any person’s privacy interest more than is reasonably necessary in the circumstances, disclose information that comes to their knowledge in the performance of their duties and functions under the Act to

• (a) a government institution set out in the schedule to the Privacy Act, the office of the Conflict of Interest and Ethics Commissioner, the office of the Commissioner of Canada Elections, the Canadian Armed Forces or any provincial, territorial or municipal body responsible for elections, lobbying or conflict of interest matters, if the disclosure is, in the opinion of the Commissioner, necessary to obtain from that institution other information that may assist in the performance of the Commissioner’s duties and functions under the Act; and
• (b) a Government of Canada institution set out in column 1 of Schedule 3 to the Security of Canada Information Disclosure Act, if the Commissioner believes on reasonable grounds that the disclosure may assist that institution in identifying the existence of an activity that undermines the security of Canada, as defined in subsection 2(1) of that Act.

Administrative Monetary Penalties

Penalties

10 (1) The range of administrative monetary penalties that may be imposed in respect of a violation is from $250 to $1,000,000.

Factors

(2) The Commissioner must take into account the following factors in relation to the imposition of an administrative monetary penalty on a person who has committed a violation, including when determining the amount of the penalty to which the person is liable:

• (a) the person’s history of compliance with the Act;
• (b) the impact of the violation, including the severity of actual or potential harm to the transparency of foreign influence activities;
• (c) whether the violation was intentional or inadvertent;
• (d) any actual or potential benefit to the person arising from the violation;
• (e) the person’s capacity to pay; and
• (f) the person’s responsiveness to and cooperation with the Commissioner.

Compliance agreement

11 (1) The Commissioner may, in a notice of violation issued to a person or following representations made by the person to the Commissioner with respect to the violation or penalty, offer to enter into a compliance agreement with the person, whereby a lesser specified penalty, or no penalty, will be imposed if the person satisfies the requirements of the compliance agreement within the time specified in the agreement.

Non-satisfaction

(2) The compliance agreement must specify the amount of the penalty that will be imposed if the person does not satisfy the requirements of the agreement, which amount must not exceed the amount set out in the notice of violation.

Service

12 (1) A notice of violation issued under subsection 19(1) of the Act or a notice of a decision made under subsection 20(2) or (3) of the Act may be in paper or electronic form and must be served using the most recent contact information provided to the Commissioner under section 5 of the Act or, if no contact information has been provided under that section, contact information that the Commissioner has obtained from a reliable source.

Presumption

(2) The notice is presumed to be served 10 days after the day on which it is sent using the contact information referred to in subsection (1).

Debt due to His Majesty

13 An administrative monetary penalty that has been imposed on a person constitutes a debt due to His Majesty in right of Canada and may be recovered in the Federal Court or any other court of competent jurisdiction.

Delegation of powers, duties and functions

14 An individual referred to in subsection 11(1) of the Act may exercise any of the Commissioner’s powers or perform any of their duties and functions under sections 19 to 21 of the Act in respect of which they have been designated — as an individual or as a member of a class of individuals — in writing by the Commissioner.

Coming into Force

S.C. 2024, c. 16, s. 113

15 These Regulations come into force on the day on which section 5 of the Foreign Influence Transparency and Accountability Act, as enacted by section 113 of the Countering Foreign Interference Act, comes into force, but if they are registered after that day, they come into force on the day on which they are registered.

REGULATORY IMPACT ANALYSIS STATEMENT

(This statement is not part of the Regulations.)

Executive summary

Issues

The Foreign Influence Transparency and Accountability Act (FITAA) creates a new regime to make foreign influence activities more transparent, including the creation of a public registry of foreign influence activities and an independent Commissioner to oversee it.

The Regulations are required to implement the FITAA.

Background

Foreign entities, including foreign states, seek to influence Canada through various means, such as lobbying, in areas like political dialogue, trade negotiations, and policy decisions. When these activities are conducted openly and transparently, they are considered legitimate foreign influence activities and are appropriate international diplomacy. However, some activities by foreign entities are carried out secretly or in a non-transparent manner, often using proxies and tactics such as spreading misinformation. Non-transparent foreign influence activities that aim to affect political and governmental processes for the undisclosed benefit of a foreign power undermine Canada’s sovereignty and democracy. They compromise Canada’s ability to make informed decisions free from manipulation or hidden agendas, ultimately posing a threat to Canada’s national interests.

Unlike some of its allies, Canada lacks a transparent mechanism to ensure the public is informed about attempts by foreign entities to influence Canadian political and governmental processes. As a result, foreign principals and their proxies can secretly seek to shape Canadian decisions and public opinion. To address this gap, Parliament approved the FITAA in June 2024 as part of the broader Countering Foreign Interference Act (Bill C-70).

The FITAA establishes a new framework to make legitimate foreign influence activities more transparent. It requires individuals or entities to register when they have entered into an agreement to act under the direction of, or in association with, a foreign principal to influence Canadian political or governmental processes. This information will be submitted to the Commissioner. Some of this information will then be published in a public registry, supporting greater openness and accountability in foreign influence activities.

Objective

By making foreign influence activities more transparent, the Regulations aim to strengthen national security by distinguishing between legitimate and transparent foreign influence and covert and non-transparent foreign influence. The Regulations will also allow security and intelligence partners to focus their efforts on activities that pose a greater threat to Canada’s interests.

The Regulations will build public trust in Canada’s democratic institutions by demonstrating a strong commitment to preventing non-transparent foreign influence.

These objectives support Canada’s broader efforts to modernize its national security posture and respond to new and evolving threats.

Description

The Regulations are organized into five sections: Interpretation, Provision of Information, Registry, Disclosure of Information, and Administrative Monetary Penalties.

Interpretation

The Regulations define the following key terms used throughout the regulatory framework:

• Act, meaning the Foreign Influence Transparency and Accountability Act (FITAA);
• Influence activities, meaning activities as defined in the FITAA; and
• Registry, meaning the public-facing registry established by the Commissioner under the Act.

The Regulations include the following additional classes of individuals to the definition of public office holder in the FITAA:

• officers or employees of the federal public administration, a departmental corporation, or of a Crown corporation, under certain sections and schedules of the Financial Administration Act;
• Officers or employees of His Majesty in right of a province or territory, including officers or employees of a provincial or territorial (PT) board, commission, office or tribunal, and any individual who is appointed by a lieutenant governor in council or a PT minister other than a judge;
• Officers or employees of a corporation that is wholly owned directly by His Majesty in right of a province or territory;
• Officers or employees of a municipal board or commission; and
• Trustees, officers and employees of a school board.

Provision of information

The Regulations exempt arrangements in which specified entities or individuals are a party from the obligation to provide information to the Commissioner.

The Regulations identify the information that must be provided to the Commissioner by a person who enters into an arrangement with a foreign principal. Under the FITAA, a person includes a corporation, a trust, a joint venture, a partnership, a fund, an unincorporated association or organization and any other legal entity, as well as individuals. Therefore, the Regulations establish specific information requirements depending on whether the person entering into the arrangement is an individual or another entity that meets the definition of a person.

The Regulations also establish details that must be provided for the type of arrangement based on the three different activities that meet the definition of an arrangement under the FITAA. These activities and their reporting requirements are identified in the Regulations as

• communication with public office holder,
• dissemination of information, such as radio, print publication, or social media, and
• provision of benefits, such as money or other items of value or services.

The Regulations establish requirements to update information on an arrangement provided to the Commissioner, which requires persons to submit changes to the Commissioner no later than 14 days after the day the change occurred.

Registry

Under the FITAA, the Commissioner is required to maintain a public-facing registry containing information. The Regulations establish the information to be provided in the registry, including

• identifying information about individuals and entities that have entered into the arrangement;
• information about the foreign principal; and
• details of each arrangement, including its purpose and the types of influence activities involved.

The Regulations allow certain information not to be published if there are reasonable grounds to believe that disclosure poses a threat to personal safety or if the information is suspected of being false or misleading. The Regulations require that the Commissioner retain registry information for 20 years after the arrangement ends.

Disclosure of information

The Regulations authorize the following entities to disclose information to the Commissioner and any person authorized to act on the Commissioner’s behalf or at their direction to assist in carrying out duties under the FITAA:

• Institutions listed in the Schedule to the Privacy Act;
• The Office of the Conflict of Interest and Ethics Commissioner;
• The Office of the Commissioner of Canada Elections; and
• The Canadian Armed Forces.

The Regulations also allow the Commissioner to disclose information to these entities and any provincial, territorial, or municipal bodies responsible for elections, lobbying, or conflict of interest matters, provided that a person’s privacy interests are not affected more than is reasonably necessary and disclosure is necessary to fulfill the Commissioner’s mandate. In addition, the Regulations allow the Commissioner to disclose information to institutions listed in Schedule 3 to the Security of Canada Information Disclosure Act where there are reasonable grounds to believe the disclosure may assist in identifying or investigating activities that undermine Canada’s security.

Administrative monetary penalties

The Regulations establish a range of administrative monetary penalties (AMPs) for violations under the FITAA from $250 to $1,000,000. The Regulations also define the following as factors the Commissioner must consider when determining whether to impose a penalty and its amount:

• The person’s history of compliance with the Act;
• The impact of the violation, including the severity of actual or potential harm to transparency;
• Whether the violation was intentional or inadvertent;
• Any actual or potential benefit to the persons from the violation;
• The person’s capacity to pay; and
• The person’s responsiveness and cooperation with the Commissioner.

The Regulations allow the Commissioner to offer to enter into compliance agreements, which allow for reduced or no penalties if the person meets specified conditions within an agreed time frame.

The Regulations establish how a notice of violation can be issued, the date it is considered served, and establish an AMP as a debt to the Crown.

Regulatory development

Consultation

Comments received during prepublication and those received outside of the prepublication process are discussed below.

Consultations prior to the publication of the Regulations

Public Safety Canada (PS) held targeted consultations with key stakeholders to help inform the Regulations. Between August and November 2025, more than 37 engagement activities took place, including bilateral, multilateral meetings and virtual sessions. Participants included provincial, territorial and municipal governments and associations, civil society organizations, such as those who advocate for human rights, democracy and political freedoms in Canada and abroad, diaspora communities, public interest law firms, international partners, and national security experts.

A summary of the feedback received and a description of how it was taken into account in the development of the Regulations can be found in the Regulatory Impact Analysis Statement (RIAS) for the proposed Regulations prepublished in the Canada Gazette, Part I, on January 3, 2026.

Prepublication in the Canada Gazette, Part I

Prepublication of the proposed Regulations was followed by a consultation period of 30 days. Ninety-nine comments were received from 13 stakeholders during this time. Comments were received from the following stakeholders:

• four civil liberties and human rights organizations;
• two legal and professional associations;
• two public policy and parliamentary democracy organizations;
• one coalition focused on foreign influence transparency and human rights;
• one diaspora or community organization;
• two national post-secondary education associations; and
• individuals.

Fifty-five comments were also received anonymously. Comments received are summarized below by theme.

Administrative monetary penalties

Fifteen individual and anonymous commenters expressed concern about the proposed administrative monetary penalty (AMP) framework. Four commenters highlighted that the proposed minimum penalty of $50 was too low to have any meaningful compliance or deterrent effect, while eight commenters raised concerns that the proposed maximum penalty of $1,000,000 may be insufficient for well-resourced actors. Commenters noted that foreign states, large corporations, wealthy individuals, and affiliated organizations could absorb low or fixed penalties as a cost of doing business.

Nine distinct submissions recommended strengthening the penalty framework, including by raising the minimum penalty, increasing or removing the maximum penalty, or introducing escalating penalties linked to the duration of non-compliance or financial capacity. Additional suggestions included tying penalties to an individual’s or organization’s assets or revenues to ensure proportional and impactful consequences.

Five submissions argued that AMPs alone may be insufficient to address serious or intentional misconduct, particularly where foreign principal-directed influence or public office holders are involved and recommended complementary enforcement tools. Three submissions also raised concerns about how concepts such as “potential harm” would be assessed and whether penalty levels would be applied consistently across different registrants.

In response, the minimum penalty has been increased to $250 while maintaining the maximum penalty of $1,000,000. This minimum penalty amount was chosen to align with minimums in other federal legislation, like the Canada Labour Code. Comments about the $$1,000,000 threshold being too low were considered, but the maximum penalty was maintained. The purpose of administrative monetary penalties under the FITAA and the Regulations is to encourage compliance, not to punish. A person may also be subject to multiple penalties for multiple violations. Decisions related to violations must be made public, creating a strong reputational consequence for non-compliance. Administrative monetary penalties are one component of a broader compliance and enforcement framework. While administrative penalties provide a proportionate and flexible tool to address instances of non-compliance, they are not intended to operate in isolation. The Commissioner may also refer matters for criminal investigation under the FITAA. For these reasons, it was determined that a $1,000,000 maximum administrative monetary penalty is sufficient.

Penalty amounts will be determined based on the factors set out in the Regulations; the identity or type of registrant is not a determining factor. To support consistent application and transparency, policies set out how the factors are assessed and how administrative monetary penalties are calculated. This approach ensures that regulated parties understand in advance how violations are assessed and the potential consequences of non-compliance.

Clarity, scope, and application of the registry requirements

Some commenters raised concerns about the FITAA more generally. Six submissions, including the International Civil Liberties Monitoring Group, commented that some of the key terms, like “foreign principal,” “arrangement,” “in association with,” and “political or government process,” were too broad and could cover every day, low-risk activities that are not directed or controlled by a foreign state, potentially creating legal uncertainty and chilling legitimate civic, academic, charitable, and diaspora engagement. They warned that this could create extra work for people and groups who are already transparent and could discourage normal civic, academic, community, or charitable activities.

Four other submissions also emphasized that these concepts must be sufficiently clear to capture informal or indirect influence, noting that foreign influence is often exercised through non-contractual or proxy-based arrangements that could otherwise fall outside the regime. In addition, the Canadian SHIELD Institute for Public Policy raised distinct concerns that the Act may not capture indirect foreign influence conducted by private companies, donors, think tanks, or non-governmental organizations that are not directly owned or controlled by foreign states. They called for clearer guidance on when such activities, including corporate lobbying and funding of domestic causes, could be considered acting “in association with” a foreign state, warning that gaps could result in limited transparency around significant influence efforts.

Seven submissions also raised concerns about how the requirements could affect immigrant and diaspora communities. They worried that people might avoid public events or community discussions because they are afraid of being told to register or being watched. Some said that these fears are already affecting how public officials interact with certain groups.

Four submissions asked for more information on how the registry would work in unclear situations. This included whether people could register “just in case,” how rejected applications would be handled, and whether registration decisions could set rules for future cases without meaning to.

Eight submissions raised concerns about the practical application of the registry requirements. These commenters emphasized the need for clear guidance on what information must be submitted, the level of detail required, and applicable thresholds, noting that uncertainty in these areas could lead to inconsistent compliance and inconsistent application by the Commissioner. While these concerns relate to the implementation of the FITAA rather than the substance of the definitions themselves, they cannot be addressed through regulatory amendments where the underlying concepts are set out in legislation. Instead, these issues are being addressed through guidance materials, interpretation bulletins, clear instructions in the registration form, and engagement with stakeholders.

In addition, eight submissions argued that specific sectors needed clear exemptions or special rules. These included universities and researchers, who argued they already follow strict rules on research security and ethics; registered charities, some of which contended that being subject to Canada Revenue Agency rules was sufficient; lawyers who raised concerns about protecting solicitor-client privilege; journalists who need to share information freely; and advocates who work for international organizations like the United Nations, the North Atlantic Treaty Organization, or the World Health Organization, where participation should not require registration.

Universities and business groups also said they needed more guidance about who must register in large, complex organizations. They asked whether the responsibility would fall on the institution or the individual, how related arrangements should be grouped, and whether members of an association would have to register individually.

Twelve submissions supported clearer definitions based on real foreign direction, control, or coordination, the inclusion of safeguards to avoid capturing low-risk activities, and measures to reduce potential impacts on minority and diaspora communities.

Based on these comments, PS considered whether regulatory changes were required and identified areas where issues could be addressed through guidance and policy instruments. However, ultimately, no changes were made to the Regulations in response to these comments. Instead, the issues raised are being addressed through guidance materials, interpretation bulletins, and ongoing engagement with affected stakeholders.

No exemption has been provided for the legal sector. Activities undertaken by legal professionals would need to be assessed to determine whether they meet the definition of an agreement under the FITAA. The Office of the Foreign Influence Commissioner of Canada (OFICC) will be developing an interpretation bulletin specific to the legal sector for the coming into force of the Act. It was therefore determined that an exemption via regulation for these types of activities was not necessary.

PS considered the comments recommending an exemption for universities, the media, and non-profits; however, no exemptions are being considered. The breadth of activities that these sectors are engaged in makes it complex to design an exemption, which does not create loopholes for those engaged in non-transparent foreign influence activities. General guidance has been provided to clarify what constitutes an arrangement. Engagement with these stakeholder groups is already underway and will continue, informing the development of sector-specific guidance as needed. Finally, PS considered the comments on the broad nature of the definitions; however, these comments cannot be addressed in the Regulations, as the terms are defined in legislation. Clarity on the application of these definitions may be supported through non-regulatory measures, such as interpretation bulletins, as appropriate.

Registry design, disclosure and public access

Ten submissions provided detailed comments on the scope of public disclosure and the use of safeguards within the registry, with differing views on what information should be made public and what should be withheld.

Four submissions, including the Canadian Coalition for a Foreign Influence Transparency Registry and the Human Rights Action Group, argued for stronger public disclosure to enable meaningful accountability and deterrence. These commenters recommended that the public registry include the names of public office holders targeted by influence activities and greater transparency regarding the amount and type of compensation received, asserting that this information is necessary for public and parliamentary scrutiny and to understand the scale and seriousness of foreign influence efforts.

By contrast, five submissions, including the Churchill Society for the Advancement of Parliamentary Democracy, emphasized the need for proportionality and data minimization in public disclosure. These respondents cautioned that overly granular public information could expose individuals to safety, privacy, reputational, or intimidation risks, particularly in the context of transnational repression. They recommended a tiered or structured disclosure model, under which full information would be provided to the Commissioner, while the public registry would display a more limited, standardized extract. These submissions also supported granting the Commissioner explicit discretion to withhold or redact information where disclosure would pose credible safety risks or be false or misleading, while still confirming the existence of a registrable activity.

One submission, from the Canadian Bar Association (CBA), raised distinct concerns regarding the potential impact of registry disclosure on solicitor-client privilege and lawyers’ duties of confidentiality and loyalty. The CBA cautioned that publicly disclosing information about arrangements, objectives, targets, or compensation could permit inferences about legal advice or strategy and recommended explicit procedural safeguards or carveouts to allow privileged information to be withheld or redacted prior to publication.

Twelve respondents emphasized the importance of clear guidance, predictable implementation, and transparent criteria governing redactions and public disclosure to ensure that the registry advances transparency objectives without chilling legitimate activity or creating unintended legal or safety harms.

The proposed Regulations, as published in the Canada Gazette, Part I, authorized the Commissioner to withhold or redact information from the public registry where disclosure could pose a safety risk or where information may be false or misleading. The Regulations limit public disclosure to information necessary for the public to understand the nature of the arrangement, whereas personal information, which is necessary to identify individuals, such as date and place of birth, and to contact them, such as telephone numbers, will not be published. Therefore, no changes to the proposed Regulations were made in response to the comments on public disclosure.

In response to comments on compensation and benefits, PS intends to include in the registry whether compensation or other benefits are provided but does not intend to publish specific dollar amounts and include only a high-level description of other types of benefits. This approach is intended to enhance transparency for the public while avoiding unnecessary disclosure of sensitive or detailed information.

Provision of information and scope of registrable activities

Eight respondents emphasized that information-collection requirements must balance transparency around foreign influence activities with avoiding unnecessary complexity for those who are subject to the Act.

Four commentators pointed to the ambiguity of the requirement, which called for the names of all individuals who had or will participate in the arrangement in a “significant manner.”

Eight submissions called for greater clarity regarding which activities are subject to registration and how key concepts, such as who is required to register, what constitutes an “arrangement,” and the scope of covered communication activities, should be interpreted. Questions were raised about whether obligations apply to individuals or organizations, how ongoing or informal interactions between diaspora groups and foreign representatives should be treated, and whether an arrangement exists when no explicit objective has been stated. Respondents also sought clarification on the scope of communication activities covered, including private messaging platforms, mailing lists, public speeches, and educational or academic contexts.

Five submissions requested clearer guidance on what constitutes the provision of a benefit. Submissions questioned whether activities such as providing meeting space, hosting or supporting events, or assisting with visits by foreign representatives would trigger registration.

The proposed requirements put forward in the Canada Gazette, Part I, concerning the information collected, were limited to what was considered essential to implement the FITAA. Twelve submissions said that the proposed Regulations asked for too much information and too much detail from people who would need to register.

In response to the comments on the ambiguity of the requirement, the proposed Regulations were amended to remove the reference to “significant manner” and to require that the following details of every individual who has or is expected to carry out influence activities under the arrangement be provided: the individuals’ name, date and place of birth, and a description of the activities that they will carry out.

In response to criticisms that registrants were required to provide too much information, information that did not meet one of the following objectives was removed: information needed to understand the arrangement, to identify the person involved, and to allow the Commissioner to contact them. For instance, as a person’s employment may not necessarily be tied to the arrangement, the requirement to provide this information was removed.

The proposed Regulations were also amended to remove the requirements to provide information about the frequency and reach of the influence activities, including removing the requirement that the registrant estimate how many people would receive a benefit and the number of communications they would have with a public office holder. This responds to calls that too much information is being collected but to still collect enough information to understand who is in an arrangement with a foreign principal, what activities are being conducted, and which political or governmental processes are being targeted.

Requirement to update information

Three submissions indicated that the proposed requirement to report updates to agreements within up to 46 days may be too long, particularly during elections. Commenters noted that election periods last between 37 and 51 days, meaning influence activities could occur without timely disclosure, and suggested shorter or distinct reporting timelines during such periods.

In response to this feedback, the proposed Regulations have been amended to require that all changes to agreements be reported no later than 14 days after the change occurs. This shorter reporting timeline will enable the Commissioner and the public to receive more timely information about foreign influence activities, including during voting periods. It also establishes a single, consistent reporting deadline that aligns with the FITAA’s existing requirement to report new arrangements within 14 days, thereby reducing complexity and potential confusion for registrants.

Public office holders

Two submissions noted that the definition of “public office holders” in the proposed Regulations may not be sufficient to capture all of the positions that manage Canada’s political and governmental processes. Commentators noted that positions at the provincial, territorial and municipal level, such as school board trustees, may be missed by the current definition.

In response, PS conducted an in-depth analysis of what positions are captured and amended the proposed Regulations to add several positions responsible for managing a political or governmental process to the definition of public office holder. This includes, but is not limited to, heads and staff of school board trustees, police board members and staff of government entities.

Cost-benefit analysis

One commenter argued that the cost-benefit analysis significantly underestimates both regulatory and administrative costs and relies on flawed baseline assumptions. The commenter stated that the FITAA explicitly requires the creation of a registry and the associated office, and therefore costs related to staffing, systems, and a public-facing website should be treated as integral to the regulatory scenario rather than as baseline or sunk costs.

The commenter further contended that estimated compliance burdens are unrealistically low, particularly the assumption that registrants will require approximately one hour to understand obligations and submit information, and that federal institutions will spend minimal time disclosing information to the Commissioner. In the commenter’s view, the complexity and breadth of the Regulations will require substantially more time and resources for both registrants and federal departments.

The commenter also questioned the benefit estimates, noting that they are largely qualitative and that the economic impacts claimed lack clear evidentiary support. Additional concerns were raised regarding the estimated number of registrants, which the commenter suggested is understated due to the broad definition of “arrangement,” particularly with respect to unpaid actors.

An explanation of changes made to the cost-benefit analysis in response to these comments is presented in the “Regulatory analysis” section.

Comments considered out of scope

Some submissions raised broader issues related to the FITAA itself or to matters not directly addressed by the proposed Regulations. The following issues were outside the scope of this consultation, and were not used to inform amendments to the Regulations:

• General support for or opposition to the FITAA, including views that the Act is unnecessary, duplicates existing tools, or should go further by prohibiting certain foreign influence activities rather than focusing on transparency.
• Broad comments on national security, immigration, or foreign relations, including concerns that the FITAA could harm international relationships, affect economic ties, or create risks for immigrants.
• Suggestions related to transparency more generally, such as publishing registry information as open data or requiring government bodies to maintain updated lists of public office holders.
• Calls for changes to policy areas not addressed in the Regulations, including stronger protections against stigma, greater recognition of harms experienced by diaspora communities, including concerns for transnational repression, enhanced independence for the Commissioner, or additional enforcement mechanisms.
• Another submission clarified that the mandatory parliamentary review set out in the FITAA occurs in the year following a general election, rather than in a fixed five-year cycle. This comment relates to statutory review provisions in the Act and does not affect regulatory design. The commenter also noted that because the regime applies the same way to all countries, more registrations may involve countries that Canada works closely with.

Additional changes made following the prepublication in the Canada Gazette, Part I

Following the prepublication in the Canada Gazette, Part I, PS met with provincial and territorial partners in January 2026 to seek feedback and support the development of the Regulations and implementation considerations. PS also engaged municipal and federal partners during this period. Both federal and provincial-territorial partners raised concerns that the Act’s exemption for arrangements involving the federal Crown does not clearly cover all federal institutions acting in their official roles.

PS considered the feedback and determined that the FITAA only exempts arrangements involving the federal Crown, which clearly covers federal departments, agencies, and office holders, but does not explicitly include all federal institutions. PS consulted PTs on the proposed changes related to provincial/territorial and municipal public office holders and excluded arrangements. The proposed Regulations were amended to exempt certain federal institutions from registration requirements, including Parliament and some Crown corporations, when they are acting in their official capacities.

PS also determined that provinces, territories, and municipalities do not act on behalf of the federal Crown and are therefore not covered by the exemption in the FITAA that applies to federal departments and agencies. Without a regulatory exemption, these public-sector bodies could have been required to register their official activities, even though they were not the intended focus of the regime.

The proposed Regulations were amended to exempt provincial, territorial, and municipal governments from registration requirements when acting in their official capacities. This amendment ensures that the regime focuses on foreign influence activities, rather than routine government-to-government interactions, and applies registration requirements consistently across orders of government.

Finally, the requirement to submit an update within 15 days when no changes have been made to an agreement for five consecutive months has been removed. As registrants are required to submit an update within 14 days of any change, information is considered up to date 15 days after the last change.

Indigenous engagement, consultation and modern treaty obligations

Modern treaty obligations

As required by the 2015 Cabinet Directive on the Federal Approach to Modern Treaty Implementation, an assessment of modern treaty implications was conducted. It was determined that there are no direct modern treaty implications or obligations for the Regulations.

Indigenous engagement and consultation

In December 2025, PS sent letters to national Indigenous organizations and to cross-border communities, which face unique challenges stemming from their geographic location. These letters informed them of the upcoming regulatory requirements and offered to meet to discuss their perspectives. No comments were received from Indigenous groups in response to the letters.

Instrument choice

The FITAA establishes a legal requirement for individuals and entities acting for foreign principals to report certain activities, subject to regulations.

As such, regulations are the only viable option.

Regulatory analysis

The Regulations will increase transparency around foreign influence activities in Canada by establishing detailed requirements for the collection and publication of information about individuals and entities engaged in such activities, as well as the nature of those activities.

From 2026 to 2035, the Regulations are estimated to result in a total cost of $31.06M in present value (2024 Canadian dollars, discounted to the base year 2026 at a 7% rate). Of this amount, $1.65M is attributed to compliance costs for individuals or entities submitting information about foreign influence activities conducted on behalf of a foreign principal. The Government of Canada is expected to incur an additional cost of $29.41M for the development of an IT system to support the public registry, the establishment and operation of OFICC and disclosure activities.

Over the same period, the Regulations are expected to generate total benefits of $37.11M. These benefits are attributed to an increase in economic benefits from enhanced transparency through the implementation of a public registry of foreign influence activities. The resulting net benefit is estimated to be $6.05M between 2026 and 2035.

Changes to the cost-benefit analysis since prepublication in the Canada Gazette, Part I

Changes to the cost-benefit analysis in response to stakeholder comments

Feedback received during consultations led to several refinements to the cost-benefit analysis, including adjustments to costing assumptions for OFICC, registrant compliance time, and efforts for disclosures, while other methodological choices were maintained where comments did not alter the overall conclusions of the analysis.

As a result, the cost-benefit analysis was updated as follows:

• The estimated time for initial registration was increased from one hour to five hours to reflect the need for registrants to read and understand the Regulations and, where necessary, seek support from the registry.
• Staffing costs for OFICC were removed from the baseline scenario and are considered only under the regulatory scenario, as the office would not exist in the absence of the Regulations.
• The estimated time for federal institutions to disclose information to the Commissioner was increased from two hours per year to seven and a half hours per year to avoid underestimating departmental workload; this figure represents an average, recognizing that many institutions may have no interactions, while others engage more frequently.
• The estimated time for submitting updates was increased from 15 minutes to one hour.

Certain comments were not taken into consideration for the regulatory analysis, for the reasons summarized below:

• The comment suggesting that development of a website to support the Commissioner’s mandate should be treated as a regulatory cost was not incorporated. All costs incurred prior to the final Regulations being published in the Canada Gazette, Part II, are treated as sunk costs under federal guidance and, therefore, are not included in the regulatory cost estimates.
• The comment that benefit estimates are largely qualitative and that the monetization approach is unreliable was considered but did not result in changes to the analysis. Benefits that are difficult to quantify continue to be described qualitatively. The key benefit of the Regulations is increased transparency, and the monetization of this benefit relies on the well-documented and widely accepted relationship between transparency and key economic performance indicators, such as gross domestic product (GDP). The World Bank’s Statistical Capacity Indicator (SCI) was used as a proxy measure for transparency. While the SCI has since been replaced by the Statistical Performance Indicator (SPI), the two indicators are strongly correlated, with a correlation coefficient of 0.765 between the overall SPI score and the SCI. Given Canada’s already high level of transparency in the baseline, the incremental impact on GDP is expected to be small. As a result, no changes were made to the benefit estimates.
• The comment arguing that the estimated number of registrants is too low, particularly with respect to unpaid actors, could not be incorporated. No alternative methodology or evidence was provided to support revising the estimate. Given the absence of data, the approach used in the analysis is considered reasonable, though actual registration numbers may differ. Further, the sensitivity analysis illustrated different scenarios where the number of registrants was doubled.

Changes to the cost-benefit analysis resulting from regulatory changes made after prepublication in the Canada Gazette, Part I

Changes made to the proposed Regulations in response to consultations with provincial, territorial and municipal partners, as well as other federal entities, resulted in the following impacts on the cost-benefit analysis.

• The requirement for registrants to submit confirmation of no change was removed, as registrants are already required to submit updates within 14 days of any material change. This amendment reduces administrative burden on registrants and results in a modest reduction in estimated costs.
• The Regulations were amended to clarify that certain federal entities that are not “agents of the Crown,” including Parliament and certain Crown corporations when acting in their official capacities, are exempt. This change aligns the Regulations with the original intent of the FITAA and does not affect the cost-benefit analysis, as these entities were not included in the estimated registrant population.
• The Regulations were amended to explicitly exempt provincial, territorial, and municipal governments, including their departments, agencies, legislatures, and certain office holders when acting in their official capacities. This clarification ensures consistent treatment across orders of government and does not result in changes to estimated costs or benefits, as these entities were not assumed to be registrants.

Summary of cost-benefit impacts between the Canada Gazette, Part I and Part II

As a result of the updates above, the total net benefit impact of the Regulations was updated from $11.21M to $6.05M. More specifically, the costs increased from $25.90M to $31.06M. The changes in costs include the following:

• The total cost to the Government of Canada was updated from $25.45M to $29.41M; and
• The total cost to registrants was updated from $442.5K to $1.65M.

The benefit estimates remain unchanged from estimates presented in the Canada Gazette, Part I.

Detailed quantitative impacts associated with these changes are documented in the Cost-Benefit Analysis Report.

Analytical framework

The costs and benefits for the Regulations have been assessed in accordance with the Treasury Board Secretariat (TBS) Canadian Cost-Benefit Analysis Guide, which can be found through the Cabinet Directive on Regulation: Policy on Cost-Benefit Analysis. Where possible, impacts are quantified and monetized, with only the direct costs and benefits for stakeholders being considered in the cost-benefit analysis.

Taxes, levies and other charges constitute transfers from one group to another and are therefore not considered to be compliance or administrative costs, including if intended as incentives to foster compliance and change behaviour. Correspondingly, the costs to pay for AMPs, as well as the revenue to the Government of Canada generated through AMPs, are not considered costs nor benefits within the scope of the regulatory analysis, since they are outside the normal course of business, occurring only in instances of non-compliance.

Benefits and costs associated with the Regulations are assessed based on comparing the baseline scenario against the regulatory scenario. The baseline scenario depicts what is likely to happen in the future if the Government of Canada does not implement the Regulations. The regulatory scenario provides information on the requirements needed to produce the intended outcomes of the Regulations. Details are further discussed below.

The analysis estimated the impact of the Regulations over a 10-year period from 2026 to 2035, with the year 2026 being when the final regulations are registered. Unless otherwise stated, all values are expressed in present value based on 2024 Canadian dollars and discounted to the base year of 2026 at a 7% discount rate.

A detailed cost-benefit analysis report is available upon request.

Affected stakeholders

The Regulations apply to individuals and entities that enter into arrangements with a foreign principal, defined broadly to include foreign states, powers, economic entities, and individuals acting on their behalf, for the purpose of conducting influence activities targeting Canada’s political or governmental processes. It is estimated that approximately 2 422 businesses and individuals (872 individuals and 1 550 businesses^{footnote 1}) will be affected. These individuals and businesses will also be subject to AMPs in cases of non-compliance with the Regulations.

The estimated number of registrants was derived by comparing figures from Australia’s Government Registries of Lobbyists (both federal and state) and its Foreign Influence Transparency Scheme (FITS). Analysis showed that FITS registrants represent approximately 10% of those in the lobbying registries. Given the structural and economic similarities between Canada and Australia, this proportion was applied across Canadian lobbying registries at the municipal, provincial, territorial and federal levels to establish a baseline. To estimate annual growth, the Canadian federal Registry of Lobbyists was used to calculate the average yearly increase in registrants from 2020 to 2024, with 10% of that figure applied to project new registrants for the Regulations.

Among the affected stakeholders, approximately 93% are Canadian citizens, Canadian institutions or individuals residing in Canada, while the remaining 7% are foreign stakeholders. Consequently, cost estimates focus only on Canadian stakeholders, totalling approximately 2 252 (1 441 businesses and 811 individuals).^{footnote 2} This breakdown was derived using Australia’s FITS data by identifying registered entities and confirming whether they maintained an office in Australia. Entities with an office were classified as domestic; those without were considered foreign. This approach produced the 93%–7% split, which was then applied to individuals as well.

The Government of Canada will also be impacted, as it is responsible for staffing the Commissioner’s office, acquiring the IT infrastructure required to support the public registry and disclosure activities, and ensuring that investigators are appropriately trained and equipped to administer the new AMPs regime.

Canadians are also affected, as they will benefit from an increase in economic benefit from enhanced transparency through the implementation of a public registry of foreign influence activities. They will also benefit from qualitative benefits, such as improved transparency and accountability in political processes, stronger democratic institutions, increased public awareness of foreign interference threats, enhanced national security capacity, and greater alignment with international best practices.

Baseline and regulatory scenarios

Baseline scenario

Under the baseline scenario, the public registry would not be implemented. As a result, the associated information submission and data management requirements would not be developed, nor would an AMPs regime be established to support compliance with the Regulations. Further, the OFICC would not be created.

Individuals and entities acting on behalf of foreign principals would be expected to continue their influence activities in Canada. However, there is currently no data on how many there are, their identities, or the specific foreign interests they represent.

Regulatory scenario

Under the regulatory scenario, the Regulations require individuals or entities entering into arrangements with a foreign principal for the purpose of conducting influence activities targeting Canadian political or governmental processes to provide certain information to the Commissioner, including requirements for timely updates to submitted data. These arrangements will be made publicly accessible through the public registry. The Regulations also authorize specific entities to disclose information to the Commissioner to assist in carrying out duties under the FITAA, as well as allow the Commissioner to disclose information to specific entities, provided that privacy impacts are minimized and disclosure is necessary to fulfill the Commissioner’s mandate, or the disclosure may assist in identifying or investigating activities that undermine Canada’s security.

The Regulations also establish specific data management requirements, including provisions for retention and disclosure. The Commissioner’s office is fully operational, with dedicated staff supporting IT infrastructure, data management, investigations and enforcement. An AMPs regime is implemented, with the Commissioner and their office responsible for investigating potential non-compliance and administering penalties.

Benefits and costs

The Regulations are expected to enhance transparency and accountability regarding individuals and entities seeking to influence Canadian political and governmental processes. By specifying the information to be included in a public registry and further clarifying the AMPs regime, the Regulations aim to differentiate legitimate, transparent foreign influence from activities conducted covertly.

Over the 10-year analytical period from 2026 to 2035, the Regulations will result in incremental costs of approximately $1.65M to individuals and businesses to report and update their information on the public registry and $29.41M to the Government of Canada to develop the necessary IT infrastructure, establish the Commissioner’s office and disclose information to the Commissioner. The Regulations will also result in an estimated benefit of $37.11M due to an increase in economic benefit from enhanced transparency through the implementation of a public registry of foreign influence activities. The resulting net benefits of the Regulations are estimated to be $6.05M.

In addition to these quantified benefits, the Regulations are expected to deliver a range of qualitative benefits, including improved transparency and accountability in political processes, stronger democratic institutions, increased public awareness of foreign interference threats, enhanced national security capacity, and greater alignment with international best practices.

Benefits

The benefits associated with the Regulations are presented both qualitatively and quantitatively in the section below.

Qualitative benefits

Countering non-transparent foreign influence

Non-transparent foreign influence, which is covert efforts by foreign states or their proxies to shape Canadian policy or public opinion, poses a growing threat to national interests. The Regulations will address this challenge by requiring transparency in foreign influence activities, thereby reducing the space for clandestine operations. By shining a light on legitimate activities, the Regulations will deter covert actors and support Canada’s broader efforts to counter covert and non-transparent foreign influence. Further, investigations and enforcement will serve as essential instruments in addressing this type of influence, enabling the Commissioner’s office to impose penalties on individuals or entities attempting to covertly influence Canadian democratic processes.

Strengthening democratic institutions

By promoting openness and accountability, the Regulations will help strengthen Canada’s democratic institutions. The public registry, along with the Commissioner’s enforcement tools, will play a key role in protecting the fairness and integrity of political decision-making across all levels of government. This will help ensure that public policy is shaped by actors who are transparent and accountable.

Public awareness

The full establishment of the Commissioner’s office includes activities for outreach, education, and public engagement. These efforts aim to raise awareness of covert and non-transparent foreign influence threats and strengthen Canada’s ability to respond to them.

Alignment with international best practices

Canada has lagged key allies, such as the United States, the United Kingdom, and Australia, in implementing dedicated legislation and regulations to address covert and non-transparent foreign influence. The Regulations help close this gap by establishing a strong transparency framework aligned with the best international practices. This alignment also strengthens Canada’s credibility as a trusted partner in advancing global security and protecting democratic institutions.

Support for national security objectives

The Regulations support Canada’s national security. While Canada has tools to address lobbying, these were not designed to counter the unique threats posed by covert and non-transparent foreign influence. The Regulations to operationalize the FITAA fill this gap by introducing a targeted regime that enhances the government’s ability to detect, deter, and respond to this type of foreign influence.

Restoring public trust in institutions

The Regulations help rebuild public trust in Canadian institutions by enabling the Commissioner’s office, an independent and apolitical body, to operate transparently and effectively. In recent years, growing concerns about covert and non-transparent foreign influence have led many Canadians to question whether government officials or processes are being unduly influenced by foreign principals. By making specific information available in a public registry, the Regulations will provide Canadians with a clear and accessible tool to see who is engaging in foreign influence, the nature of their activities, and any enforcement actions taken. This visibility will help reassure the public that influence activities are being monitored and addressed appropriately.

Monetized benefits

The Regulations are expected to increase transparency related to foreign influence activities in Canada. The economic literature demonstrates a statistically significant relationship between transparency and economic performance. Transparency is generally defined as a government’s ability to produce and disseminate consistent, reliable, and accessible information related to economic and governance conditions. Greater transparency is associated with improved economic outcomes, including higher levels of economic growth (Dradek & Payne, 2002; Montes et al., 2018; Barry & DiGiuseppe, 2019; Islam & Lederman, 2024; Seti, Mazwane & Christian, 2025).

This relationship exists because reliable, accurate, and accessible information reduces investor uncertainty related to factors such as corruption, political instability, and governance quality, and signals that a country is a stable and predictable environment for investment (Dradek & Payne, 2002; Islam & Lederman, 2024; Seti, Mazwane & Christian, 2025). In addition, consistent and accessible data is indicative of effective public administration and adherence to the rule of law, further reinforcing investor confidence (Dradek & Payne, 2002).

This body of research was used to inform the quantification of the benefits of the Regulations on Canada’s Gross Domestic Product (GDP). A 2024 study^{footnote 3} found that a 1% increase in a country’s Statistical Capacity Indicator (SCI)^{footnote 4}, a measure of transparency, results in an average increase of 0.03% in GDP. Based on the most recent available data from 2020, Canada’s SCI score is estimated to be 89.1 out of 100.

To estimate the benefits of the Regulations, it is necessary to estimate the extent to which the implementation of a public registry of foreign influence activities could contribute to an improvement in Canada’s transparency, as measured by the SCI. The SCI is a broad indicator, and the marginal contribution of a single transparency initiative, such as the registry, is expected to be very small. Due to the absence of direct data linking foreign influence registries to changes in SCI scores, this analysis relies on related literature examining the relationship between political instability, transparency and economic performance.^{footnote 5}

Drawing on this literature, covert and non-transparent foreign influence activities are estimated to increase the political instability index, as measured by the Risk Guide,^{footnote 6} by approximately 0.67%.^{footnote 7} Subject-matter experts at PS assessed that assuming a corresponding increase of this magnitude in Canada’s SCI score would significantly overstate the likely impact of the registry. As a result, a conservative fractional increase of 0.0067% in Canada’s SCI score was applied as a proxy for the incremental transparency effect of the Regulations. The study used to quantify the relationship between transparency and GDP relies on data from developing countries. Research indicates that transparency policies typically have a smaller marginal impact on GDP in developed countries, such as Canada, given their higher baseline levels of transparency^{footnote 8} than in developing countries. To account for this, an adjustment factor was applied based on a comparison of average SCI scores of developing and developed countries. Using 2020 World Bank data, the average SCI score for developing countries was 64, compared to 88 for developed countries. This difference yields an adjustment factor of 0.73, reflecting that the GDP impact of increased transparency in developed countries is estimated to be 73% of that observed in developing countries.

The relationship between GDP and transparency, the incremental impact of the Regulations on the transparency index and the transparency adjustment indicator to account for different levels of development are combined to approximate the benefits. While the resulting estimate is subject to significant uncertainty, it provides an order-of-magnitude approximation consistent with available empirical evidence. On this basis, the implementation of a public registry of foreign influence activities is expected to generate a benefit of approximately $37.11 million over a 10-year period (2026 to 2035).

Costs

The total cost associated with the Regulations over the 2026 to 2035 time period is estimated to be $31.06M. Of this amount, approximately $1.65M will be incurred by individuals and entities that enter into arrangements with a foreign principal for the purpose of conducting influence activities targeting Canada’s political or governmental processes. The remaining $29.41M will be borne by the Government of Canada.

Costs to the Government of Canada

IT Solution

To support the public registry and the collection of information required under the Regulations, the Government of Canada will procure an IT solution. Through a third-party contract, the Government of Canada is expected to incur a cost of $1.25M in 2026 for the development and acquisition of the IT system, which will support both the registry and case management system.

A website has been developed to support the Commissioner’s mandate, as well as a simple form using GC Forms to allow affected stakeholders to submit their information, as well as a mechanism to publish this information until the full registry and IT system are implemented by the end of 2026. This is estimated to cost approximately $250K. However, since its development will be completed prior to the registration of the Regulations, it is considered a sunk cost. As such, it falls outside the scope of this analysis and is not included in the cost estimates. However, the cost of maintaining the website is within scope and has been accounted for in the IT staffing cost estimates.

Maintenance and support costs will be provided by a third-party vendor. These services will include system updates, bug fixes, performance monitoring, helpdesk and user support, security patches and audits, and feature enhancements.

Based on vendor estimates, annual maintenance and support costs are estimated to be $500K per year from 2026 to 2030^{footnote 9}. Beginning in 2031, these responsibilities will transition to OFICC with associated costs captured in OFICC’s staffing costs below. As a result, the total costs for maintenance and support costs from the vendor are estimated to be $1.82M between 2026 and 2035.

Office of the Foreign Influence Commissioner of Canada

The Commissioner is responsible for ensuring compliance with the Regulations, including managing the public registry, registry support, investigating compliance, disclosure and enforcing penalties through an AMPs regime. To support these activities, OFICC has been established and operational.

To support the implementation of the FITAA and the Regulations, under the OFICC structure, two teams have been established: Policy, Public Affairs and Registry, and Compliance and Enforcement. The Policy, Public Affairs and Registry team includes Policy, Communications, and Registration Support. The Compliance and Enforcement team consists of Investigation and Enforcement. The Commissioner’s position (GCQ-06) would also be created and staffed.

As a result, the Government of Canada is expected to incur approximately $24.87M^{footnote 10} in staffing costs for OFICC between 2026 and 2035^{footnote 11}.

Disclosure by the Commissioner

Under the regulatory scenario, the Commissioner may exchange information with federal and intelligence partners, other federal entities, and provincial, territorial, or municipal bodies responsible for elections, lobbying, or ethics if the disclosure will not affect any person’s privacy interests more than is reasonably necessary in the circumstances. Disclosure may also occur to designated institutions under the Security of Canada Information Disclosure Act if the Commissioner believes, on reasonable grounds, that the disclosure may assist that institution in identifying the existence of an activity that undermines the security of Canada. This cost is part of the office’s operations and is captured through the work of the Commissioner and their office. The cost is not estimated separately.

Disclosure to the Commissioner

Under the regulatory scenario, approximately 268 federal institutions are authorized to disclose information to the Commissioner for the purpose of supporting the Commissioner’s duties and functions under the FITAA.

It is assumed that a manager-level employee (typically at the EC-07 classification, or equivalent) from each affected organization will spend about seven and a half hours per year on disclosure activities to the Commissioner. This estimate was revised from the previous assumption of one hour, twice per year, in response to comments received during prepublication in the Canada Gazette, Part I, which indicated that the original estimate significantly underestimated the effort required.

Therefore, this is expected to result in an incremental cost of $1.48M to these federal institutions over the period 2026 to 2035.

Guidance material

PS has developed plain-language guidance materials, including frequently asked questions, step-by-step registration instructions, and infographics outlining obligations under the Regulations. These materials were developed prior to the Regulations coming into force as part of preparatory implementation activities. Therefore, the associated costs are considered sunk costs and are not incremental costs attributable to the Regulations for the purposes of this cost-benefit analysis.

Costs to individuals and entities

Initial registration activities

Under the regulatory scenario, affected individuals and entities are required to familiarize themselves with the regulatory requirements. This could be done by reading the Regulations, consulting guidance materials available that are available on Canada.ca, or by contacting the registry support team. Registrants need to create an account and submit required information for each arrangement with a foreign principal, including details of the foreign organization, and disclose the nature of the activities related to influencing Canadian governmental or political processes.

These activities are expected to take five hours for each registrant. This estimate was revised in response to comments received during prepublication in the Canada Gazette, Part I, which noted that the previous estimate of one hour significantly underestimated the time required.

The five-hour estimate assumes that registrants will need sufficient time to complete several tasks: reviewing guidance materials, understanding compliance requirements, contacting registry support as needed, creating an account, and submitting the necessary information for each arrangement with a foreign principal.

It is anticipated that approximately 1 767 registrants will submit information annually, with an additional 54 new registrants each year. As previously noted, the annual number of registrants was estimated using data from provincial, territorial, municipal, and federal lobbying registries, resulting in approximately 950 paid registrants per year. However, this figure does not include unpaid individuals or entities, such as individuals and entities working pro bono. For example, an individual or entity could engage in foreign influence activities, free of charge, for their country of origin. To account for these, the estimate was adjusted to approximately 1 900 registrants annually. This figure was doubled based on input from subject matter experts at PS, who indicated that for every paid lobbyist, there is typically an unpaid advocacy group on the opposite side. Accordingly, the estimate was increased from 950 to 1 900 to account for unpaid advocacy efforts. The estimate for new registrants each year was similarly increased to reflect both paid and unpaid individuals and entities (58 new registrants). To estimate annual growth, the Canadian federal Registry of Lobbyists was used to calculate the average yearly increase in registrants from 2020 to 2024, with 10% of that figure applied to project new FITAA registrants, resulting in an estimate of 29 new registrants per year, which was then doubled to account for unpaid individuals and entities.

The resulting figures were then multiplied by 93% to estimate the number of Canadian stakeholders affected (1 767 registrants and 54 new registrants). This breakdown was derived using Australia’s FITS data by identifying registered entities and confirming whether they maintained an office in Australia. Entities with an office were classified as domestic; those without were considered foreign. This approach produced the 93%–7% split, which was then applied to individuals as well.

Because no direct data exists on the number of stakeholders likely to be affected by the Regulations, lobbying registries were used as a proxy to establish a reasonable estimate. The proportion was derived by examining Australia’s FITS in relation to its lobbying registries, where registrants under the Australia’s scheme represented approximately 10% of those in their state and federal lobbying registries. This 10% ratio was then applied to the Canadian context. This approach was considered appropriate given the economic and structural similarities between Australia and Canada, and it provided a practical basis for estimating potential stakeholders.

Based on national security expertise within PS, roughly half of affected stakeholders are expected to be paid for their services, while the other half are expected to be unpaid. It is assumed that each registrant will submit one registration per year (i.e. each registrant will have only one arrangement).^{footnote 12} A registration refers to the formal obligation for individuals or entities acting on behalf of a foreign principal to disclose their arrangements and activities when those activities aim to influence political or governmental processes in Canada.

As a result, initial registration activities are estimated to take 10 hours per registrant, at an hourly rate of $56.60,^{footnote 13} resulting in a total cost of $808.7K in 2026.

Ongoing updates

In addition to initial registration, the Regulations require registrants to update their information. It is assumed that each registrant will complete one update annually.^{footnote 14} For example, a registrant who previously disclosed an arrangement with a foreign organization might update their submission to reflect a change in the scope of activities.

According to PS subject matter experts, updates are expected to take, on average, one hour. This estimate was revised from the previous estimate of 15 minutes to align with adjustments made to the initial registration time estimates following comments received during prepublication in the Canada Gazette, Part I, which indicated that time requirements had been underestimated.

For updates, a registrant will reopen their submission and make any necessary changes, rather than re-entering all information from scratch. Therefore, one hour is considered sufficient for this task. Using the same wage rate assumptions as previously stated, the total cost of these activities is estimated to be $842.2K over the 10-year period.

Cost-benefit statement^{footnote 15}

• Number of years: 10 (2026 to 2035)
• Price year: 2024
• Present value base year: 2026
• Discount rate: 7%

Table 1: Monetized benefits (present value in millions)

Impacted stakeholder	Description of benefit	Base year: 2026	Annual average (2027-2034)	Final year: 2035	Total (present value)	Annualized value
Canadians	Increase in GDP due to enhanced transparency	$4.60	$3.70	$2.91	$37.11	$5.28
All stakeholders	Total benefits	$4.60	$3.70	$2.91	$37.11	$5.28

Table 2: Monetized costs (present value in millions)

Impacted stakeholder	Description of cost	Base year: 2026	Annual average (2027-2034)	Final year: 2035	Total (present value)	Annualized value
Registrants	Initial registration activities	$0.50	$0.04	$0.03	$0.81	$0.12
	On-going updates	$0.10	$0.08	$0.07	$0.84	$0.12
Government of Canada	IT system	$1.38	$0.21	$0.00	$3.07	$0.44
	Disclosure to the Commissioner	$0.20	$0.15	$0.11	$1.48	$0.21
	Staffing the Commissioner’s office	$2.99	$2.51	$1.83	$24.87	$3.54
All stakeholders	Total costs	$5.16	$2.98	$2.03	$31.06	$4.42

Table 3: Summary of monetized benefits and costs (present value in millions)

Impact	Base year	Other relevant years	Final year	Total (present value)	Annualized value
Total benefits	$4.60	$3.70	$2.91	$37.11	$5.28
Total costs	$5.16	$2.98	$2.03	$31.06	$4.42
Net impact	−$0.57	$0.72	$0.89	$6.05	$0.86

Qualitative impacts

Positive impacts

• Enforcement powers deter covert and non-transparent foreign influence and support national efforts to protect Canadian policy and public opinion.
• Promoting openness and accountability helps safeguard the fairness and integrity of political decision-making across all levels of government.
• The implementation of the FITAA, supported by OFICC, will result in outreach and education initiatives that will raise awareness of covert and non-transparent foreign influence threats and strengthen Canada’s capacity to respond.
• The Regulations bring Canada in line with allies like the United States, the United Kingdom, and Australia, enhancing its credibility in global security and democratic protection.
• A targeted regime fills gaps in existing tools, improving the government’s ability to detect, deter, and respond to covert and non-transparent foreign influence.
• A public registry managed by an independent body provides transparency and reassurance that foreign influence is being monitored and addressed.

Sensitivity analysis

As previously described, a number of assumptions have been made to estimate the costs of the Regulations. To address the effect of uncertainty and variability on these assumptions, a sensitivity analysis is conducted, where variables are assigned different values, and outcomes are re-evaluated. A sensitivity analysis was performed on the following variables: number of registrants and transparency adjustment indicator for developed countries.

Number of registrants

The central analysis assumes 1 767 registrants per year. The sensitivity analysis presents the results if this number was doubled and decreased by 50%.

Table 4: Sensitivity analysis results — Number of registrants (in millions of dollars)
Note: the “1 767” cost and benefit values represent the central case.

Parameter	Total cost	Total benefit	Net benefit
884	$30.24M	$37.11M	$6.87M
1 767	$31.06M	$37.11M	$6.05M
3 534	$32.71M	$37.11M	$4.40M

Table 5: Sensitivity analysis results — Transparency adjustment indicator for developed countries (in millions of dollars)
Note: the “73%” cost and benefit values represent the central case.

Parameter	Total cost	Total benefit	Net benefit
25%	$31.06M	$12.71M	−$18.35M
73%	$31.06M	$37.11M	$6.05M
90%	$31.06M	$45.75M	$14.69M

Distributional analysis

Aside from the cost to the Government, the Regulations will primarily affect individuals, small and medium/large businesses, and non-profit organizations, including charities and universities.^{footnote 16} Collectively, they are expected to incur approximately $1.65M in costs. Individuals are expected to account for approximately 35.9% of the total estimated costs. Small businesses will bear the largest share among entities, representing about 39.8%, while medium and large businesses will incur roughly 16.9%. Non-profit organizations, charities, and universities combined are anticipated to experience a smaller impact, contributing about 7.4% of the costs.

Table 6: Costs by impacted stakeholder (in millions of dollars)

Stakeholders	Total costs to stakeholders	Share of costs
Individuals	$0.593M	35.9%
Medium/Large businesses	$0.279M	16.9%
Small businesses	$0.657M	39.8%
Non-profits organizations/Charities/Universities	$0.122M	7.4%
Total	$1.651M	100%

Small business lens

The small business lens applies, as there are impacts on small businesses associated with the Regulations. It is estimated that approximately 70% of entities^{footnote 17} (1 009 businesses) who enter into an arrangement with a foreign principal are a small business. The Regulations will result in an incremental cost of $657.0K (or an average of $651.19 per business) over the 10-year analytical period to small businesses, or an annualized cost of $93,549 (or an average of $92.71 per business).

Following publication in the Canada Gazette, Part I, several refinements were made to the cost-benefit analysis. These changes primarily reflect updated time assumptions for registrant activities, including increased estimates for initial registration and updates, and the removal of “no-change” confirmations, as well as revised costing for OFICC. These adjustments were made to better reflect expected effort and are discussed in greater detail in the “Regulatory analysis” section.

Small business lens summary

• Number of small businesses impacted: 1 009
• Number of years: 10 (2026 to 2035)
• Price year: 2024
• Present value base year: 2026
• Discount rate: 7%

Table 7: Costs

Administrative or compliance	Description of benefit	Present value	Annualized value
Compliance	Cost to register and updates	$657,046	$93,549
Total	Total costs	$657,046	$93,549

Table 8: Net impacts

Amount	Present value	Annualized value
Net impact on all impacted small businesses	$657,046	$93,549
Average net impact on each impacted small business table b8 note a	$651.19	$92.71
Table b8 note(s) Table b8 note a Costs per impacted small business are average values and may not reflect the actual costs per business. Return to table b8 note a referrer

One-for-one rule

The one-for-one rule does not apply, as the Regulations will not result in an incremental change in administrative burden for business. Under the Red Tape Reduction Act (RTRA), administrative burden is those requirements that are intended to demonstrate compliance with regulatory requirements. In this case, disclosure is not secondary and is the core purpose of the Regulations. The reporting obligation is therefore considered a compliance activity, not an administrative one under the RTRA definition. While the process of submitting information is an administrative process, in this it falls outside the legal definition because it is integral to achieving the objective of the Regulations.

Regulatory cooperation and alignment

The Regulations were developed following a comprehensive assessment of regulatory approaches in relevant domestic and international jurisdictions to identify opportunities for alignment and cooperation while meeting Canada’s policy objectives.

To reduce burden and improve transparency, PS reviewed federal, provincial, territorial, and municipal lobbying registries. The Office of the Commissioner of Lobbying of Canada was identified as a key reference because it shares the goal of promoting transparency and keeping a public registry. The Regulations set data retention periods in a similar manner to the Lobbying Act. The Regulations set registration requirements, update timelines, and data retention periods in a similar manner to the Lobbying Act to make compliance easier for those who interact with both regimes. However, not all provisions were replicated, as the scope of individuals required to register with the Commissioner is broader than under the Lobbying Act, and the types of activities that trigger registration under the FITAA also differ. Further, changes made after publication in the Canada Gazette, Part I, have moved certain aspects of the Regulations further from the Lobbying Act, including adjustments to initial and update timelines for registration.

The review also confirmed the need for OFICC’s 20-year data retention policy and highlighted the importance of having the ability to disclose information with provinces and territories to facilitate the exchange of intelligence on non-compliance and support coordinated enforcement efforts.

International jurisdictions

The Regulations aim to align Canada with international best practices and were informed by a detailed analysis of foreign influence registries in key jurisdictions, including the United States, the United Kingdom, France, and Australia, which have implemented similar transparency regimes.

Although the Regulations share some features with international counterparts, such as independent oversight, a Canada-specific approach was deemed necessary to meet domestic goals and maintain independence. Any potential challenges from diverging from international models are mitigated through ongoing engagement with international partners and alignment with best practices.

International obligations

The Regulations do not engage any of Canada’s international obligations.

Effects on the environment

In accordance with the Cabinet Directive on Strategic Environmental and Economic Assessment (SEEA), a preliminary scan was conducted for the Regulations. The scan concluded that a strategic environmental and economic assessment is not required.

Gender-based analysis plus

Racialized groups may experience suspicion or discrimination as a result of information posted in the public registry, particularly if certain countries appear more often than others. To address this, the Regulations are designed to be country-neutral and apply equally to all individuals and entities acting on behalf of any foreign principal, regardless of origin.

PS has developed guidance materials and led outreach initiatives to mitigate potential stigma. These communications emphasize that registration supports Canada’s transparency and national security objectives, as outlined in the FITAA.

Investigations into potential non-compliance may use information from anonymous sources who could face retaliation from foreign states. To protect these individuals, many of whom are presumed to belong to diaspora or racial minority communities, the Commissioner, and any person acting on their behalf or under their direction, cannot disclose any information obtained in the performance of their duties except as authorized by the FITAA.

OFICC intends to continue to work closely with diaspora communities during implementation to ensure communities are not unintentionally targeted. This collaboration will help shape the approach and outreach strategy.

The FITAA also includes a mandatory five-year review by Parliament and oversight by both the National Security and Intelligence Committee of Parliamentarians (NSICOP) and the National Security and Intelligence Review Agency (NSIRA). These bodies can look at and address any issues related to gender, nationality, race, religion, or sexual orientation.

Implementation, compliance and enforcement, and service standards

Implementation

The Regulations come into force on the same day as the FITAA. If the Regulations are registered after that day, they come into force on the day they are registered.

Upon coming into force of the FITAA, reporting obligations for registrants will apply immediately. To support implementation and early compliance, a suite of outreach and educational materials is available on Canada.ca, including plain-language guidance, frequently asked questions, step-by-step registration instructions, information bulletins, accessible digital tools, and visual aids to help individuals and organizations assess their registration readiness and understand their obligations under the Regulations. The Canada.ca web presence serves as the dedicated site for the Commissioner’s office and is the primary point of access for registration, the public registry, and public inquiries about the regime.

An interim registration solution is in place for registrants to submit the required information. Information is collected using GC Forms and securely stored in a protected government system with access limited to authorized personnel only. Information submitted through GC Forms populates a public-facing registry hosted on Canada.ca. Validation activities may include cross-checking submitted information against publicly available sources, sharing relevant information with national security and law enforcement partners where appropriate, and assessing whether submissions meet legislative requirements. In certain circumstances, the Commissioner may also determine that a registration should not be published and should instead be referred for further examination or investigation.

As the volume of registrations stabilizes and processes operate at scale, registry updates will occur on a regular and systematic basis, consistent with operational capacity and risk considerations, ensuring timely public access to validated information.

Registrants who need to provide updates on existing arrangements are required to submit a new GC Forms entry and identify whether the submission reflects an update.

Compliance and enforcement  

Detection of non-compliance

Non-compliance will be detected through multiple channels, including the assessment of information contained in registration submissions, proactive disclosures from the public to the Commissioner’s office, disclosure between partners, and independent investigations conducted by the Office, as required.

These mechanisms support proactive and reactive detection of violations. Detection of a potential violation could lead to the initiation of an investigation to confirm compliance with the FITAA. Investigations will determine whether the subject is compliant with the Regulations and the FITAA. If non-compliance is found, the Commissioner may impose an AMP. The Commissioner may also pursue non-compliance as an offence under the FITAA.

Penalties for non-compliance

The FITAA designates the following as violations:

• Failure to provide information within 14 days of entering into an agreement with a foreign principal.
• Failure to update required registration information; and
• Knowingly providing false or misleading information to the Commissioner.

In the case of non-compliance, the FITAA allows the Commissioner to impose an AMP or to pursue a criminal conviction. The FITAA also allows the Commissioner to pursue a conviction for persons who knowingly obstruct the work of the Commissioner or people acting on the Commissioner’s behalf or direction. This could result in the following:

• On summary conviction, a fine of up to $200,000, up to two years in prison, or both; or
• On conviction on indictment, a fine of up to $5,000,000, up to five years in prison, or both.

The Commissioner may also leverage non-punitive enforcement tools to encourage compliance with the FITAA, such as entering into a compliance agreement with a person after a notice of violation may be issued. Fulfillment of a compliance agreement may reduce or eliminate a monetary penalty.

Contact

Office of the National Counter Foreign Interference Coordinator
National Security Branch
Department of Public Safety
340 Laurier Avenue West
Ottawa ON
K1A 0P9
Email: fipublicconsultations-consultationspubliqueei@ps-sp.gc.ca