Interpretation bulletin: Influence activities
Effective date: August 4, 2026
Purpose
This interpretation bulletin describes the term influence activities for the purposes of the Foreign Influence Transparency and Accountability Act (FITAA or the Act).
Interpretation bulletins are not binding and are not a substitute for the law. They are intended as a guide for compliance with FITAA, but should be read in light of FITAA, the Foreign Influence Transparency and Accountability Regulations (Regulations), court decisions and decisions of the Commissioner. If there is a discrepancy between an interpretation bulletin and FITAA or the Regulations, FITAA and the Regulations take precedence. Interpretation bulletins may evolve and be further refined over time.
Summary
- A person, which may include individuals or organizations, who enters into an arrangement with a foreign principal to influence a Canadian political or governmental process must provide information to the Foreign Influence Transparency Commissioner via the registration form
- Anyone who conducts influence activities as a part of an arrangement must be included in the registration
- Influence activities consist of:
- communicating with a public office holder
- communicating or disseminating information
- providing money, items of value, a service or the use of a facility
Legislative framework
As per section 2 of FITAA, an arrangement means an arrangement under which a person undertakes to carry out, under the direction of or in association with a foreign principal, any of the following activities in relation to a political or governmental process in Canada:
- Communicating with a public office holder
- Communicating or disseminating or causing to be communicated or disseminated by any means, including social media, information that is related to the political or governmental process
- Distributing money or items of value or providing a service or the use of a facility
Subsections 4(1)(a)(iv) and 4(1)(b)(viii) of the Foreign Influence Transparency and Accountability Regulations establish that the following information must be provided to the Commissioner about any individual who has carried out or is expected to carry out influence activities as a part of the arrangement. These regulations are as follows:
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
- if the person is an individual,
- (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
- if the person is not an individual,
- (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
Interpretation
Influence activities intend to affect, shape or alter the decisions, actions, opinions or conduct of public office holders or others in relation to Canadian political or governmental processes. Influence activities may seek to reach as many people as possible or may be targeted to specific individuals, including public office holders.
The concept of influence activities is intentionally broad to ensure that if they are undertaken as a part of an arrangement that they are registered and made transparent. The below table outlines examples of influence activities which, if undertaken at the direction of or in association with a foreign principal to influence a Canadian political or governmental process, would trigger an obligation to register.
Examples of influence activities
Under FITAA, influence activities include, but are not limited to:
Communicating with public office holders
- Sending correspondence to public office holder providing feedback on proposed regulations
- Lobbying a member of a legislative assembly to support or oppose an upcoming bill
Communicating and disseminating information
- Conducting a social media campaign targeting a Canadian audience about the importance of Canada maintaining strong relations with a foreign state
- Publishing an article or video about the benefits of voting a certain way in an upcoming referendum
Distributing money or items of value
- Providing donations to an election campaign
- Providing flights and accommodations to Canadian public office holders to facilitate meetings with foreign representatives abroad
- Distributing teaching materials, such as books, that advocate for a position of a foreign principal
Providing a service
Conducting “get out the vote” activities to support the election of a foreign principal's preferred candidate.
Providing the use of a facility
- Hosting a public event where a foreign ambassador speaks about the importance of Canada's continued support for an initiative
- Arranging for the use of a space for a community meeting
Who carries out influence activities under FITAA
The person who enters into an arrangement with a foreign principal is required to register and provide all information in the registration form.
Must be listed in registration
Persons carrying out an influence activity: If other individuals or entities carry out, or expect to carry out, influence activities as a part of the arrangement.
Example: an organization with an arrangement directs the manager of the organization's communications team to disseminate information via a company newsletter. Because the communications manager is carrying out an influence activity under the arrangement, the organization must identify the manager in the registration.
Not listed in the registration
Persons providing a good or service to enable others to execute an influence activity: If other individuals or entities are providing goods or services as a part of their regular business to another person to enable their execution of an influence activity, the provider of the goods or services is not considered to be carrying out the influence activity.
Example: an individual with an arrangement hosts an event for the public as part of an influence activity. To execute this event, the individual hires a caterer. The caterer does not need to be included in the registration, because the caterer provided a service in the course of their regular business and is not itself carrying out the influence activity. The individual who organized the event remains responsible for the influence activity.
Questions and further information
If you require registration assistance or have questions regarding the interpretation or application of FITAA contact the Office of the Foreign Influence Commissioner of Canada.
Consult other interpretation bulletins that serve as a guide for complying with the Act: Interpretation bulletins issued by the Commissioner.
Anton Boegman
Foreign Influence Transparency Commissioner