Interpretation bulletin: Entering into an arrangement

Effective date: August 4, 2026

Purpose

This interpretation bulletin provides guidance on whether a person, which includes individuals or organizations, is considered to have entered into an arrangement with a foreign principal 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

An arrangement falls within the definition under FITAA when all of the following three elements are satisfied: 

1. A person (individual or organization) acts at the direction of, or in association with a foreign principal
2. They undertake to carry out one or more influence activities as defined in the Regulations
3. The activities are in relation to a Canadian political or governmental process

An arrangement may be formal or informal, written or unwritten, and does not require the foreign principal to have control over the individual or organization, such as through employment, contract or membership.

Legislative framework

As per section 2 of the Act, the following definitions apply.

Definition of 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:

Definition of a person

Includes a corporation, a trust, a joint venture, a partnership, a fund, an unincorporated association or organization and any other legal entity.‍

Definition of a foreign principal

Means a foreign economic entity, a foreign entity, a foreign power or a foreign state, as those expressions are defined in subsection 2(1) of the Security of Information Act.‍

Definition of a political or governmental process

Includes:

Interpretation

The three elements of an arrangement

The following three elements must exist to constitute an arrangement under FITAA. If any one of these elements is missing, an arrangement has not been established:

1. A person acts under the direction or, or in association with, a foreign principal
2. The person undertakes to carry out  one or more influence activities as described in section 2 of the Act
3. The influence activities are done in relation to a  political or governmental processes in Canada at any level of government

It is not necessary for the individual or organization to conduct influence activities solely or primarily for the foreign principal’s benefit. An arrangement can exist even if the individual’s or organization’s motivation for carrying out the arrangement is to advance their own interests or mandate.

Application to Indigenous political and governmental processes and Indigenous public office holders not yet in force

There is currently no obligation to register influence activities that target Indigenous public office holders nor Indigenous political and governmental processes as paragraphs (c) and (d) of the definition of public office holder in section 2 and paragraph 4(c) of the Act are not yet in force.

Acting under the direction of a foreign principal

An individual or organization may be under the direction of a foreign principal when the foreign principal exercises control or provides instruction concerning  influence activities. While an arrangement may be based on contract, employment or membership, this type of formality is not necessary in order for an arrangement to exist.

Direction may be:

• explicit or implicit
• formal or informal
• communicated through instructions, requests, or expectations

Indicators of direction may include, but are not limited to the foreign principal:

• providing input or approval of messaging, strategy, or timing
• assigning or encouraging activities
• supervising or monitoring performance
• evaluating compliance with requirements provided by the foreign principal

Acting in association with a foreign principal

An individual or organization may be acting in association with a foreign principal where they conduct activities to advance the interests of a foreign principal in regard to a Canadian political and governmental process. It is not necessary for the foreign principal to exercise formal control of, or authority over, the individual or organization for an arrangement to exist.

Indicators of acting in association with may include, but are not limited to the foreign principal and the individual or organization:

• aligning, coordinating or sequencing activities or messaging
• sharing resources, platforms, or distribution channels

What may not be an arrangement

Canadian enterprises, organizations and individuals regularly engage with foreign principals to develop business relations, support knowledge transfers and foster cultural exchanges.

An arrangement may not arise solely from having:

• shared political views or policy positions
• a private or professional relationship with a foreign principal
• a meeting with a foreign principal
• cultural or intellectual exchanges
• ideological alignment or common advocacy goals
• parallel or coincidental actions

Only arrangements which are with a foreign principal and involve undertaking specific activities in relation to a Canadian political or governmental process are required to be registered.

Questions and further information

For 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 of Canada