Before Jan 2026
"Significant part"
interpretation
After Jan 2026
Concrete time-based
threshold
What Changed
Registration vs. Enforcement
More Lobbyists Will Register — This Is Good
The lower threshold means that individuals who previously lobbied below the 20% "significant part" line will now need to register if they lobby for 8+ hours in any four-week period. This captures part-time lobbyists, consultants who do occasional government relations work, and corporate employees who lobby intermittently. More registration means more visibility — more names, more communication reports, more data in the public registry. This is a genuine improvement in transparency.
But Registration Has Never Prevented Capture
The 5,000+ lobbyists and 13,000+ communication reports documented in the lobbying industrial complex analysis are all registered. Every meeting between a lobbyist and a public office holder is filed. The registry is public. And yet the regulatory capture documented across this site occurred with full registration and disclosure. The CRTC is captured. OSFI serves banks. The PMPRB failed to control drug prices. All while the lobbyists were registered. Registration is visibility. It is not enforcement.
The Commissioner Cannot Compel Change
The Commissioner of Lobbying can investigate violations and refer cases for prosecution. But the Commissioner cannot change regulatory outcomes. The Commissioner cannot reverse a CRTC decision that favours telecoms. The Commissioner cannot restore drug prices that the PMPRB failed to control. The Commissioner can ensure lobbyists register correctly — but cannot prevent the policy outcomes that lobbying produces. The scorecard applies: the Commissioner can investigate but cannot enforce systemic change.
Transparency Without Enforcement = Documentation, Not Accountability
More lobbyists on the registry means more data for investigations like TENET5. It does not mean fewer captured regulators.
The threshold change is welcome. It does not change the fundamental architecture of institutional capture.
Search the registry yourself: lobbycanada.gc.ca →