FIT For Purpose: Canada’s Foreign Influence Transparency Regime And Registry Going Live

Years in the making, Canada’s Foreign Influence Transparency regime will take effect on August 4, 2026, establishing the Foreign Influence Transparency Registry and launching new reporting requirements.

The Foreign Influence Transparency and Accountability Act (“FITAA“) received Royal Assent on June 20, 2024, but the regime sat dormant pending the coming-into-force order and its supporting regulations.¹ That wait is now over. Anyone already party to an arrangement with a foreign principal should not wait for the dust to settle: compliance obligations begin immediately.

Canada Gets a Commissioner

Following approval of both Houses of Parliament, on March 13, 2026, the Minister of Public Safety, the Honourable Gary Anandasangaree, announced Anton Boegman as the proposed Foreign Influence Transparency Commissioner.² Mr. Boegman previously served as the Chief Electoral Officer of British Columbia from 2018 to 2025. As Commissioner, he will administer and enforce FITAA, including managing and overseeing the public registry.

The Story So Far

McMillan has tracked FITAA since its introduction. In our June 2024 Bulletin, we canvassed who qualifies as a “foreign principal,” what constitutes a registrable “arrangement,” and how the regime differs from its American counterpart, the Foreign Agents Registration Act (“FARA“).

In our January 2026 Bulletin, we reviewed the first draft of the Foreign Influence Transparency and Accountability Regulations (“FITAR“), noting that the draft regulations introduce broad and detailed disclosure obligations, require the submission of sensitive personal and financial information, and establish significant administrative monetary penalties for non-compliance. FITAR has since been finalised and comes into force alongside FITAA on August 4.

Watch Points as the Registry Goes Live

The final Regulations, published on June 22, 2026, introduced several notable changes from the proposed regime — while leaving some previous concerns unresolved:

• No legal advice exemption: We previously cautioned that the draft regulations contained no exemption for lawyers providing legal advice to foreign principals. The final regulations are no different — legal professionals will need to assess their exposure under FITAA, though the Office of the Foreign Influence Transparency Commissioner of Canada (“OFICC”) has committed to releasing a dedicated interpretation bulletin for the legal sector.³
• Personal information required: Registrants must provide highly personal and financial information, such as dates of birth and details of financial arrangements between the registrant and the foreign principal. However, this will not appear in the public registry.⁴ Overall, the final Regulations significantly reduced the information registrants are required to disclose compared to the proposed Regulations — requirements to provide citizenship details, employment information, estimated communication frequency, and reach of dissemination activities were all removed.⁵
• Timing of Reporting Requirements: The proposed regulations stated that updates to registered arrangements would need to be submitted within 15 days after the end of the month in which a change occurred, with a no-change confirmation required every five months.⁶ The final Regulations have amended both rules: updates must now be submitted within 14 days of the change occurring, and the no-change confirmation obligation has been removed entirely.⁷
• Administrative Monetary Penalties (“AMPs”): The final Regulations establish AMPs for contraventions of FITAA ranging from $250 to $1,000,000 — up from $50 in the proposed Regulations.⁸ The Commissioner must consider a number of factors in determining the amount, including severity of harm, intent, and capacity to pay.⁹ The Commissioner may also enter into compliance agreements to reduce or cancel penalties.¹⁰
• Expanded definition of “public office holder”: The final Regulations expanded the classes of individuals constituting a “public office holder” beyond those captured in the FITAA alone, now expressly including officers and employees of provincial, territorial, and municipal governments, school board trustees, and police board members.¹¹

What happens next?

Looking ahead, organisations with arrangements involving foreign principals should begin finalising their compliance frameworks for initial disclosures and ongoing reporting obligations. Given the volume of sensitive information required and the severity of potential penalties, early preparation will be essential.

Footnotes

1. Bill C-70, the Countering Foreign Interference Act, received royal assent on June 20, 2024 and enacted the FITAA.

2. “Minister Anandasangaree names proposed Foreign Influence Transparency Commissioner” (13 March 2026), online: Government of Canada.

3. Foreign Influence Transparency and Accountability Regulations, SOR/2026-152, Canada Gazette, Part II, Vol 160, No 13 (22 June 2026) (FITAR), Regulatory Impact Analysis Statement, see under “Clarity, scope, and application of the registry requirements”.

4. FITAR, ss 4(1)(a)(i)–(ii), (d)(ii); see also Regulatory Impact Analysis Statement, “Registry design, disclosure and public access”.

5. FITAR, see “Provision of information and scope of registrable activities“.

6. FITAR, s 5(1)–(2) (proposed).

7. FITAR, s 5; see also Regulatory Impact Analysis Statement, “Requirement to update information”.

8. FITAR, s 10(1).

9. FITAR, s 10(2).

10. FITAR, s 11(1).

11. FITAR, s 2; see also Regulatory Impact Analysis Statement, “Public office holders“.