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Interpretation bulletin: What is a foreign principal

Effective date: August 4, 2026

Purpose

The interpretation bulletin describes what a foreign principal is for the purpose of understanding whether an arrangement must be registered under 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

  • Individuals and organizations must submit information to the Commissioner via the registration form if they undertake to carry out, under the direction of or in association with a foreign principal, certain influence activities in relation to a political or governmental process in Canada
  • The definition of foreign principal is broad and not limited to foreign governments

Legislative framework

Definition of a foreign principal

Section 2 of FITAA defines a foreign principal as 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.‍

Subsection 2(1) of the Foreign Interference and Security of Information Act defines these terms, as:

Foreign economic entity

  1. a foreign state or a group of foreign states
  2. an entity that is controlled, in law or in fact, or is substantially owned, by a foreign state or a group of foreign states 

Foreign entity

  1. a foreign power
  2. a group or association of foreign powers, or of one or more foreign powers and one or more terrorist groups
  3. a person acting at the direction of, for the benefit of or in association with a foreign power or a group or association referred to in paragraph (b)

Foreign power

  1. the government of a foreign state
  2. an entity exercising or purporting to exercise the functions of a government in relation to a territory outside Canada regardless of whether Canada recognizes the territory as a state or the authority of that entity over the territory
  3. a political faction or party operating within a foreign state whose stated purpose is to assume the role of government of a foreign state

Foreign state

  1. a state other than Canada
  2. a province, state or other political subdivision of a state other than Canada
  3. a colony, dependency, possession, protectorate, condominium, trust territory or any territory falling under the jurisdiction of a state other than Canada

Interpretation

The definition of foreign principal is broad and is not limited to governments. Some organizations clearly state their role and affiliations, making them easier to identify as foreign principals. In other cases, it may be less clear.

A foreign principal may include:

  • a country, a province, a territory, or a city outside of Canada 
  • an organization that is, or has aspirations of forming, a government and/or controlling an area outside of Canada, including political parties, political movements, and terrorist organizations
  • an organization representing the interests of one or more foreign governments or authorities or bodies
  • a business or organization owned or controlled by a foreign state, such as a state-owned enterprise
  • an organization (for example: a business, cultural group, educational institution, non-governmental organization, media outlet, charity) that is effectively controlled by another foreign principal or group of foreign principals, even if this relationship is not formally stated.The foreign principal may have editorial influence or some degree of control over the organization’s operations 
  • an individual or organization acting openly as an official representative of a foreign principal

An individual or organization is not considered a foreign principal solely because they: 

  • are based outside of Canada
  • hold non-Canadian citizenship
  • have independent views or positions which happen to align with that of a foreign government or authority
  •  receive funding from a foreign source, while remaining: 
    • independent in their decision-making and operations
    • accountable to an entity, such as a board, shareholders, owner(s) or creditor(s), which is not linked to a foreign principal

Registration guidance

Individuals and organizations entering into an arrangement that involves influencing Canadian political or governmental processes are responsible for determining whether the other party to the arrangement is a foreign principal.

The Office of the Foreign Influence Commissioner of Canada will verify all submitted registrations, including whether the organization listed as the foreign principal meets the criteria. 

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

Page details

2026-08-04