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Canada’s new foreign influence reporting regime is now in force. The Foreign Influence Transparency and Accountability Act ("FITAA") and the accompanying Foreign Influence Transparency and Accountability Regulations (the "Regulations") came into force on August 4, 2026, establishing a new foreign influence transparency regime requiring certain persons and organizations to register arrangements with foreign principals involving specified influence activities related to political or governmental processes in Canada.
The regime creates a public registry administered by the Foreign Influence Transparency Commissioner, imposes registration and ongoing reporting obligations, and provides for significant administrative and criminal penalties for non-compliance.
Important deadline: Organizations with registrable arrangements already in place when FITAA came into force generally have until October 3, 2026, to complete the required initial filings.
While FITAA has largely been discussed in the context of foreign state influence, its scope extends beyond traditional lobbying and government relations activities. In addition to private sector businesses, NGOs, cultural and community organizations, universities, research institutions, and industry associations may be affected by the regime.
When does FITAA registration apply?
At a high level, a registration is required where:
- there is an arrangement;
- the arrangement is with a foreign principal; and
- the arrangement involves specified influence activities relating to a political or governmental process in Canada.
Registrations generally must be filed within 14 days of entering into a registrable arrangement, with updates required within 14 days of changes to registered information. Existing arrangements that became subject to FITAA on August 4, 2026, are subject to a one-time 60-day transition period.
What counts as an “arrangement” under FITAA?
An arrangement exists where a person undertakes to carry out specified influence activities under the direction of, or in association with, a foreign principal. The Commissioner's recently issued Interpretation Bulletin: Influence Activities confirms that the concept is intended to be interpreted broadly and is not limited to traditional lobbying mandates.
Who is a “foreign principal” under FITAA?
The definition of foreign principal is broader than many organizations may expect. FITAA incorporates the definitions of foreign economic entity, foreign entity, foreign power and foreign state from the Security of Information Act. As a result, the concept is not limited to foreign governments or diplomats and includes foreign political parties, state-owned or controlled entities, and persons acting at the direction or for the benefit of, or in association with, foreign governments.
What activities trigger registration?
Registration obligations arise only where an arrangement involves specified influence activities relating to a political or governmental process in Canada. These activities generally include:
- communications with public office holders;
- communications or dissemination of information relating to a political or governmental process; and
- the distribution of money, items of value, services or the use of facilities.
The Commissioner's guidance includes examples of such activities, including communications concerning proposed legislation or regulations, public advocacy campaigns, the distribution of educational materials, and public events involving foreign representatives.
Importantly, FITAA applies to federal, provincial, territorial, municipal and Indigenous political and governmental processes. Certain exemptions exist, but there is no general exemption for charitable, academic, research, or cultural activities.
Who must register?
FITAA applies to both individuals and organizations. Depending on the nature of the arrangement, the registrant may be a corporation, non-profit organization, industry association, university, research institution, government relations firm or individual acting on behalf of a foreign principal.
Determining whether a registration obligation exists is often less about the identity of the registrant and more about whether the arrangement, foreign principal and influence activity elements of the statutory test are met.
What information must be disclosed under FITAA?
FITAA requires disclosure of detailed information regarding the registrant, the foreign principal, the arrangement and the influence activities being undertaken, including certain information regarding individuals carrying out those activities.
Much of this information will be included in a publicly accessible registry.
What are the penalties for non-compliance with FITAA?
FITAA establishes both administrative and criminal enforcement mechanisms. Administrative monetary penalties range from $250 to $1 million, and the Commissioner may publicly identify persons found to have contravened the legislation.
The Act also creates criminal offences for certain registration failures, the provision of false or misleading information, and obstruction of the Commissioner. Maximum penalties include significant fines and imprisonment.
FITAA compliance: What organizations should do now
Organizations should review existing relationships with foreign counterparties to determine whether any arrangements may be subject to FITAA, particularly arrangements that were already in force on August 4, 2026. Organizations should also identify responsibility for FITAA compliance, and establish processes for meeting FITAA's filing and update requirements.
The Office of the Foreign Influence Commissioner has also published interpretation bulletins and registration guidance that organizations should review as part of their compliance assessment, including:
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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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