Frequently asked questions
Understanding foreign influence
What is foreign influence?
Foreign influence refers to activities carried out under the direction of, or in association with, a foreign principal to influence political or governmental processes in Canada. A foreign principal includes entities such as a foreign government or state-owned enterprise.
Many foreign influence activities are lawful and legitimate. A person who has diplomatic credentials or who is employed by a foreign principal, and is acting openly in that capacity, does not need to register. Registration obligations do not apply to arrangements entered by governments and parliamentary entities acting within their official mandates.
Other foreign influence activities may be less transparent and can therefore require registration. For example, a media interview with a foreign principal that is published or streamed may need to be registered. This process ensures these activities are transparent to Canadians.
What is a foreign principal?
A foreign principal may include:
- Foreign Power
- The government of a foreign state
- An entity exercising or purporting to exercise the functions of a government outside Canada
- A political faction or party whose purpose is to assume the role of government of a foreign state
- Foreign State
- A state other than Canada
- A province, state or other political subdivision of a state other than Canada
- A colony, dependency, possession, protectorate, condominium, trust territory or any territory falling under the jurisdiction of a state other than Canada
- Foreign Entity
- A foreign power
- A group or association of foreign powers
- A person acting at the direction of, for the benefit of, or in association with a foreign power
- Foreign Economic Entity
- A foreign state or a group of foreign states
- An entity that is controlled, in law or in fact, or is substantially owned, by a foreign state or a group of foreign states
Who must register?
People or organizations in Canada may be required to register when they enter into arrangements with foreign principals to influence political or governmental processes.
Registration applies when all three of the following conditions are met:
- There is an arrangement with a foreign principal
- The arrangement involves certain activities, such as:
- communicating with a public office holder
- sharing or publishing information to the public
- providing money, services, facilities, or other benefits in support of the arrangement
- The goal is to influence a political or governmental process in Canada.
Most Canadians are not required to register. For the full legislative text and regulatory framework, consult Foreign Influence Transparency: Act and regulations
What types of activities may require registration?
An individual or entity that has an arrangement with a foreign principal may need to register if the arrangement involves any of the following activities:
- Communicating with a public office holder
- Communicating with, or disseminating, information to the public
- Distributing money or items of value, or providing services or facilities
What activities constitute "communicating with a public office holder"?
Communication with a public office holder can take many forms, including:
- Meetings or discussions, whether in person, virtual, or by telephone
- Written communications, such as emails, letters, briefing notes, or text messages
- Presentations or briefings, including slide decks or background materials shared with a public office holder
- Participation in consultations, roundtables, or working groups where public office holders are present
- Requests for meetings or follow-up exchanges, even if no decision is ultimately made
The communication does not need to be formal, persuasive, or confidential to be covered.
Which public office holders can be subject to foreign influence?
Foreign influence can relate to communications with public office holders at all levels of government in Canada, including:
- Federal, provincial, territorial, municipal, and Indigenous governments
- Ministers, parliamentary secretaries, and elected officials
- Political staff and senior public servants
- Employees of departments, agencies, boards, and Crown corporations
A public office holder is broadly defined and is not limited to elected officials.
Which public decisions and policies can be influenced by foreign actors?
Foreign influence activities may relate to a wide range of government processes, including:
- Development or amendment of legislation, policies, or programs
- Funding decisions on government grants or contracts
- Regulatory or licensing decisions
- Immigration, health, education, or economic programs
- Decisions by ministers, departments, agencies, or government bodies
- Political processes, such as elections, referendums, party leadership contests, or political party activities
What activities are considered to be "communicating with or disseminating information to the public"?
Communicating with or disseminating information to the public refers to activities that are intended to inform, shape, or influence public understanding or opinion about a political or governmental process in Canada. Examples include, but are not limited to:
- Publishing or sharing content on websites, blogs, or social media platforms
- Issuing press releases, statements, or media advisories
- Giving interviews or participating in media appearances
- Organizing, sponsoring, or participating in public events, such as conferences, panels, roundtables, or seminars
- Distributing written or visual materials, including reports, pamphlets, flyers, open letters, or petitions
- Running awareness-raising or advocacy campaigns, including coordinated messaging efforts
- Conducting surveys, polls, or public consultations intended to influence views on a government or policy issue
When can someone ask to be removed from the registry?
Registrants must update or end their registration when circumstances change, in accordance with the Act and regulations. Registered information will only be removed when it is determined to be factually inaccurate. Disclaimers that document the amendment or removal of information will be added to the registry.
What if I did not conduct the activities under the arrangement?
If the activities under the arrangement are not conducted, you are still required to update your registration information. A public disclaimer will indicate that the activities did not occur, ensuring the accuracy and transparency of the registry.
When will the registry be searchable?
The registry will be publicly searchable once entries have been received and validated by the Office.
Compliance, enforcement and safeguards
What happens if someone does not register when required?
Failure to comply with the Act may result in enforcement measures:
- Administrative monetary penalties (fines) may be imposed, ranging from $250 up to $1,000,000, depending on the nature and seriousness of the violation
- In more serious cases, subject to criminal prosecution under the Act
- Criminal offences under the Act may result in criminal charges, which can include fines of up to $5 million or imprisonment of up to five (5) years for a conviction or indictment
For the full legislative text and regulatory framework, consult Foreign Influence Transparency: Act and Regulations
What factors will be considered when a fine is issued?
When deciding on the amount of any fine, the Commissioner must consider the following factors :
- whether the person or organization has complied with the Act in the past
- the impact of the violation, including how serious it was and whether it caused, or could have caused, harm to transparency around foreign influence activities
- whether the violation was intentional or the result of an error or misunderstanding
- the person's or organization's ability to pay
- any actual or potential benefit to the person arising from the violation
- the person's responsiveness to and cooperation with the Commissioner
These factors help ensure penalties are fair, proportionate, and appropriate to the circumstances.
How is personal information protected?
The registry operates within Canada's legal framework for privacy and data protection. Only information as defined in the Foreign Influence Transparency and Accountability Regulationsis made public. Collection, disclosure, and retention of information are governed by statutory safeguards.
For the full legislative text and regulatory framework, consult Foreign Influence Transparency: Act and Regulations