(September 2026)

The top 10 key changes needed to make Ontario municipal governments best-practice, fully democratic governments (meaning honest, ethical, transparent, representative and waste-preventing) are listed below (and similar changes are needed to the key democracy laws that apply to municipalities across Canada).

Cities and towns across Canada also have similar loopholes and gaps in key democracy laws, and weak enforcement of those laws, which makes them all vulnerable to authoritarian, dishonest, unethical, secretive and wasteful political leaders and their cronies, and also vulnerable to foreign interference.

The additional change needed in Ontario (and anywhere else it exists) is to cancel the strong mayor’s system that the Ford PC Party government enacted because it is fundamentally undemocratic, especially the part that allows the mayor and minority of councillors to make major changes.

1. Enact an honesty-in-politics bylaw that allows for complaints to a fully independent commissioner about broken promises, and about dishonest statements made anywhere (including at council, and during elections) by anyone involved in politics, with mandatory high fines as the penalty;
2. Create broad-based, citizen-funded and -driven watchdog groups in each mid-sized to large-municipality by requiring all hydro and water utilities, and the municipality when sending out property tax bills, to include a notice in their mailings and emails to households inviting them to join and fund citizen watchdog groups for hydro/water service, and for watching over government spending and ethics (as an umbrella group for ratepayer associations);
3. Establish a Public Appointments Commission (preferably at the provincial or regional level) whose members are not connected to any councillor, and require the Commission to conduct public, merit-based searches and choose a short list of a maximum of 3 candidates for all council appointments (especially watchdogs), with the council required to choose from the short list;
4. Enact a meaningful public consultation law provincially that requires all municipalities to undertake a broad, in-depth public consultation with voters before any council or municipal institution makes a significant decision;
5. Limit individual political donations to $100 (as in Quebec) and establish donation-matching public funding, and limit third-party interest group spending on advertising and campaign activities (including on issue-related ads) to a low amount per voter that the third -party represents (and set a very low amount that any individual acting as a third party is allowed to spend, given they only represent one voter);
6. Enact an actually effective bill to strengthen and close loopholes in Ontario’s Municipal Conflict of Interest Act (because the Ford government’s very weak Bill 9 which came into force recently is not enough to ensure ethical decision-making by municipal councils and strong mayors), to require councillors, their staff, municipal staff and local board officials and staff to only make truthful statements; and prohibit them from participating in any way in any decision-making process if they have even the appearance of a conflict of interest (even if the decision applies generally); and prohibit them from communicating with anyone in the municipal government (or advising others who to communicate with) about their decisions for 5 years after they leave their position, and; to make Ontario’s Integrity Commissioner the enforcer of the Act, and; establish high penalties for violators, and; require the Commissioner to issue a public ruling on every situation they review and to impose a penalty for every violation;
7. Enact a bill that strengthens and closes loopholes in Ontario’s Lobbyists Registration Act (LRA) to require councillors, their staff, municipal staff and local board officials and staff to disclose in an online registry any communication they have with anyone with regard to decisions they are making (to close the secret lobbying loopholes that now exist in municipalities across Ontario (except in Toronto, Ottawa and a few others); and to prohibit lobbyists from helping with political campaigns or fundraising (or, if they do, from lobbying until after then next election); and to make Ontario’s Integrity Commissioner the enforcer of the LRA for municipalities, and; establish high penalties for violators, and; require the Commissioner to issue a public ruling on every situation they review and to impose a penalty for every violation;
8. Change the voting system to a ranked ballot system with a runoff for the top candidates, to ensure that everyone who is elected is supported the most by the most voters;
9. Strengthen the municipal access-to-information law (Ontario’s MFIPPA) by closing loopholes, applying it to all government and government-funded institutions, requiring that records of all decisions and actions be disclosed regularly, and to establish high penalties for violators, and ensure effective whistleblower protection for people who reveal wrongdoing in government or by councillors, and;
10. Reduce waste by empowering Ontario’s Auditor General and/or Financial Accountability Officer (FAO) to: audit projected municipal spending to ensure truth-in-budgeting; order changes to clean up the financial management of any municipal institution, and; penalize violators of spending or procurement rules.

Democracy Watch has won for you more than 220 democracy, bank accountability and corporate responsibility changes to federal, provincial, territorial and municipal laws across Canada (See details below).

Between now and 2028 is the biggest window of opportunity in decades to win more key democracy, bank accountability and corporate responsibility changes across Canada. Please click here now to support the campaigns winning these key changes.

No matter what issue or problem concerns you about governments or big businesses, these changes will help stop their bad decisions and abuses of power that harm you, your family, the environment and your community.

When Democracy Watch started up in fall 1993, all of the following undemocratic, unethical and secretive political and big business activities were legal across Canada (with just a few exceptions):

1. Unlimited donations to political parties and politicians from businesses, unions, other wealthy private interests and wealthy individuals (except in Quebec)
2. Secret donations to riding associations
3. Unlimited spending during elections by businesses, unions and other wealthy private interests and wealthy individuals (except in Quebec)
4. Secret lobbying
5. Unethical decision-making by politicians and government officials
6. Unethical lobbying
7. False claims in government budgets and spending announcements
8. Politicians having secret trust funds
9. The PM and Premiers calling unfair snap elections
10. Politicians leaving their position and becoming lobbyists right away
11. Big businesses making decisions and doing things only to boost their profits
12. Banks gouging and putting unlimited holds on cheques, and refusing to open accounts for people with low incomes
13. Banks dodging billions in taxes every year

and

1. Ethics laws or codes for politicians and government officials didn’t even exist in most parts of Canada (except in SK and for federal Cabinet ministers, but both were full of loopholes)
2. Government officials enforced their own ethics standards (usually letting each other off for clear violations)
3. Politicians enforced their own ethics rules
4. Federal Cabinet ministers essentially enforced their own secrecy rules
5. The fines for violating federal lobbying and election laws were too weak to discourage violations
6. Whistleblowers were not protected from retaliation when they reported wrongdoing
7. There were almost no consumer protections for bank customers other than when a bank stole a customers’ money
8. There was no enforcement agency to protection bank customers
9. There were no penalties for banks mistreating their customers (other than, again, when a bank stole a customers’ money)
10. There was a legal barrier to lawsuits against many agencies, boards, commissions and tribunals (ABCTs) that governments across Canada had put in place to block members of the public from filing court cases challenging the decisions of the ABCTs

After all these campaigns Democracy Watch has led, almost always by organizing and coordinating a national coalition of citizen groups to push all together for key changes, and filing strategic lawsuits

And with the support of people from across Canada

 

And after an average of 700 media appearances every year (click here to see details)

Many undemocratic, unethical and secretive political and big business activities are now illegal:

1. Donations by businesses, unions and other wealthy interests are banned almost everywhere in Canada (except in Saskatchewan (SK), Newfoundland (NF) and the Yukon (YK))
2. Donations by individuals to political parties and politicians are limited to $100 annually (in Quebec) or $1,000 up to a few thousand dollars annually (everywhere else, except again in SK, NF and YK)
3. Donations to riding associations are required to be disclosed publicly at least every year
4. Spending is limited during elections by businesses, unions and other wealthy private interests and wealthy individuals (except again in SK, NF and YK)
5. Truth-in-budgeting watchdogs have been established at the federal level and in Ontario
6. Politicians secret trust funds have been banned
7. Ethics laws or codes have been enacted for politicians and government officials across Canada (although they have loopholes in them)
8. Most lobbying is required to be disclosed publicly across Canada
9. Ethics rules for lobbyists exist at the federal level, and in Ontario and B.C.
10. Federal politicians who leave their positions are banned for 5 years from most lobbying
11. Election dates are fixed somewhat at the federal level and in every province and territory (except Ontario)
12. Big businesses are now allowed to, and in some ways required to, make decisions and do things to protect the interests of all stakeholders
13. Bank cheque holds are limited and they are required to open accounts for people with low incomes
14. Banks are required to issue an annual Public Accountability Statement that discloses changes to their services across Canada
15. Banks are now paying an excess profits tax and some of their tax-dodging loopholes are being closed
16. Banks are now required to have policies and procedures to protect customers by ensuring that customers are only sold products and services that are in their financial interest, and to protect customers from fraud (although loopholes remain and enforcement is weak)

and

1. Ethics watchdogs have been established to enforce ethics rules that apply to politicians and government officials across Canada (and, even though the watchdogs are not as independent as they should be, the Prime Minister and several federal and provincial Cabinet ministers have been found guilty of violating ethics rules)
2. Lobbying watchdogs have been established to enforce lobbying transparency rules across Canada (and to enforce ethical lobbying rules at the federal level and in Ontario and B.C., and even though the watchdogs are not as independent as they should be, several lobbyists have been found guilty of violating the rules)
3. The fines for illegal lobbying and illegal election activities at the federal level have been doubled
4. The federal Information Commissioner now has the power to order the release of federal government information
5. Bank gouging and failures by banks to serve and protect consumers in several ways are now monitored by the Financial Consumer Agency of Canada (FCAC) and the Ombudsman for Banking Services and Investments (OBSI)
6. Banks face a max. $10 million penalty for violating consumer protection laws
7. Whistleblowers are protected in some ways when they report government and big business wrongdoing at the federal level, and in Ontario and Alberta
8. Democracy Watch won a unanimous Supreme Court of Canada ruling in July 2026 removing the legal barrier to lawsuits against many agencies, boards, commissions and tribunals (ABCTs) across Canada that governments across Canada had put in place to block members of the public from filing court cases challenging the decisions of the ABCTs

To see details about all these changes, click here.

But we need your support now to win even more changes to protect you and your family and the environment and your community from abuses and gouging.

No matter what issue or problem concerns you about governments or big businesses, these changes will help stop their bad decision and abuses of power that harm you, your family, the environment and your community.

How will these changes help? The changes we are going to win will require politicians and big business executives to be more honest, ethical, open and waste-preventing, and make them more accountable to you and all voters, which help stop their abuses of power.

Federal politicians, and politicians in Ontario, B.C., Manitoba and other provinces, will be reviewing their 7 key democracy laws, and key big bank, insurance and big business accountability laws, over the next couple of years. We need your support now to build 8 national coalitions, and to win 6 key lawsuits, all aimed at winning key changes:

• to stop the influence of big money interests completely (including foreign-funded groups)
• to stop all secret, unethical lobbying (including by foreign-backed lobby groups)
• to stop all excessive government secrecy
• to ban all secret investments by politicians and government officials in businesses they regulate
• to stop all unethical decisions by politicians, their staff, and government officials
• to stop all false claims that mislead voters
• to stop all unfair snap elections
• to stop all gouging by Canada’s big banks, insurance companies, TV, cell phone and Internet companies and other big business abuses of power
• to protect all whistleblowers who report wrongdoing
• to stop politicians choosing their own watchdogs (who often return the favour by acting like lapdogs)
• to ensure strong, independent, effective and quick enforcement of all rules
• and to ensure high penalties for all violations.

Please click here now and become 1 of the 1,000 Canadians giving $5-10 a month to make winning these changes possible

Thank you!  And please Share this page with anyone you think may be interested in helping win these key changes.

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(updated to August 2026)

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The following list of examples from the federal level in Canada, and various provinces and cities, show clearly that banning corporate and union donations, but still allowing a relatively high donation limit, is a sham that doesn’t stop big money in politics.

Every jurisdiction where donations by individuals of $500 and up are allowed and an analysis has been completed has found that funneling of money has likely happened. In fact, such systems actually hide big money as they make it more difficult to connect donations to businesses, unions and other organizations.

Donation systems that allow for big money donations essentially legalize bribery. Click here to see how studies worldwide show that giving even small gifts influence decision-makers.

The only way to stop big money in politics is to stop big money donations by limiting donations to no more than $100 annually (as in Quebec), with strict enforcement and high penalties. Join the call for these changes now by clicking here.

1. In Alberta in 2026, it was revealed that during the first half of 2025, the separatist Republican Party of Alberta received $190,000 in donations from fewer than 50 people, with more than half of them donating $5,000 (the maximum annual amount allowed in the province), in what appears to be a coordinated donation scheme (which raises questions about whether a business, lobby group or an individual (or a few individuals) funnelled the donations to the party through the other donors.
2. At the federal level in April 2025, it was revealed that Conservative Party leader Pierre Poilievre and Liberal Party leader Mark Carney both attended fundraising events hosted in private homes that cost $1,750 to attend, with lobbyists and big business executives in attendance.
3. At the federal level in February 2025, it was revealed that Liberal Party leadership contestants were receiving large donations from wealthy big business executives.
4. In Ontario in February 2025, it was revealed that from 2021-2024 the Ontario Progressive Conservative Party received on average 71% of its total donations from donors who each donated $1,000 or more, and those donors (including lobbyists) are 48% of its total number of donors, and other Ontario parties also received a large percentage of their donations from a relatively small percentage of their big donors.
5. In Ontario in November 2024, it was revealed that the Ontario Trucking Association had asked its members each to buy 50 to 60 tickets to a fundraising event for the Progressive Conservative Party and Doug Ford in order to influence the Ford government’s decisions about trucking issues.
6. In Toronto in September 2024, it was revealed that a city councillor had received 11% of his total donations from top donors connected to one property development company.
7. In May 2024, it was revealed that federal Conservative Party leader Pierre Poilievre had held about 50 exclusive, top donation fundraising events in private homes and clubs since he became leader in September 2022.
8. In May 2024, it was revealed that the families of behind the largest grocery store chains have donated more than $150,000 to the federal Liberal and Conservative parties.
9. At the federal level in February 2024, it was revealed that only only 11,000 voters out of Canada’s total of more than 27 million voters (5%) donate more than $1,000 annually to federal parties, while 75% donate only $75, and on average the donors who donate $1,000 or more each contribute 30% of the total raised by the main parties each year (especially to the Liberals and Conservatives).
10. At the federal level in November 2023, the Network 100 group of Muslim donors, which claims it has 400 members, wrote a letter to Prime Minister Trudeau saying that they were stopping their top-level donations of hundreds of thousands of dollars to the federal Liberal Party because Trudeau was not calling for a ceasefire in the Israel-Hamas conflict.
11. In Ontario in 2022, it was revealed that executives at nine of the property development companies who benefitted most from Premier Ford’s decision to open up the Greenbelt lands to development had donated thousands of dollars to Ford’s PC Party.
12. Also in Ontario, in 2021 a vaccine clinic company’s executives and their family members all donated the maximum annual amount of $3,300 to Premier Ford’s PC Party, and the Ford government gave the company a contract to deliver vaccines.
13. Also in Ontario, in 2020 it was revealed that many long-term care industry lobbyists are donors to the Ford PC Party government, and in 2019 it was revealed that Premier Doug Ford was promoting four companies whose executives had donated to Ford’s PC Party.
14. Also in Ontario, lobbyists sold tickets for Premier Ford’s Feb. 2019 fundraising dinner and in April several Ford Cabinet ministers held high-priced, exclusive fundraising events across the province, in 2016, executives at a bank involved in bidding on a government contract organized a fundraising event for the ruling party that was attended by Liberal Cabinet ministers.
15. An analysis in spring 2019 found that the Trudeau Liberals have received almost $1.5 million in donations from staff, executives and lobbyists at more than 110 companies, law and accounting firms and interest groups since 2015.
16. In 2015 and 2016, donors from B.C., some of whom were formerly connected to China’s government, donated large amounts to a riding in Ontario and to Prime Minister Trudeau’s riding in Quebec.
17. As finally revealed in spring 2019, SNC-Lavalin Inc. illegally funneled almost $118,000 to the federal Liberal and Conservative parties, riding associations and candidates through its executives and employees from 2004 to 2011, with CBC revealing the list of donors in April 2019.
18. As finally revealed in spring 2020, Norda Stelco Inc. illegally funneled more than $25,000 to the federal Conservative Party and its candidates, and more than $20,000 to the federal Liberal Party and its candidates, from 2004 to 2011.
19. As the Globe and Mail revealed, lobbyists attended approximately 90 high-priced, exclusive events the Liberals held from January to October 2016, and another 72 events held since April 2017.
20. The Liberals also offered special access to top party politicians and officials to “bundler” fundraisers in 2016.
21. Clearwater Seafoods lobbies the federal government, and board member Mickey MacDonald held a fundraising event in August 2014 that raised about $80,000 for the Liberal Party, an event Justin Trudeau attended.
22. Apotex Inc. lobbied the federal government at the time its then-Chair Barry Sherman held a fundraising event in August 2015 that raised about $150,000 for the Liberal Party, an event Justin Trudeau also attended.
23. An analysis in 2012 found that several construction company executives linked to Quebec’s political donation scandal donated large amounts to a federal Conservative Party riding in Quebec.
24. An Elections Quebec audit found $12.8 million in likely illegally funneled donations from 2006-2011 (see also article in the Globe and Mail), and the Charbonneau Commission inquiry into the construction industry donation scandal heard of many donation-funneling schemes (before Quebec limited donations to $100 a year in 2013).
25. An April 2019 CBC analysis found New Brunswick company executives and their families now donating the maximum after the province banned corporate and union donations.
26. A 2019 analysis of donations to candidates in Ottawa’s city council elections found some property developers claiming donations were made by their wives in order to avoid prosecution, and another analysis of Ottawa donations released May 2020 found that 58% of donations to councillors on the city’s Planning Committee came from people associated with the property development industry, and that 11 of 24 councillors received more 50% of their donations from people associated with the property development industry.
27. During the fall 2022 Vancouver election, it was revealed that the mayor’s party had a list of 40 property developers and businesspeople each tasked with raising money from others (known as “bundlers” because they bundle donations together), 15 of which the mayor had phone calls with during August.
28. A fall 2019 analysis of donations to Vancouver candidates and parties found employees of a major real estate and hotel company’s employees suddenly donating to right and left politicians.
29. In B.C. in 2017, provincial parties returned more than $260,000 in donations that had been funneled through lobbyists for companies, and people affiliated with unions.
30. When Elections Alberta did an audit in 2012 it found dozens of illegal donations. As well, in a 2013 scandal in Alberta, a coalition of construction companies made it clear that their big money donations were conditional on the Alberta government changing the labour law.
31. Donations from corporations, unions and other organizations were banned in Toronto elections in 2009, and individual donations limited to $750 annually, but a 2016 analysis by the Toronto Star found that big business and other special interest group executives and their families continue to give large amounts to city councillors.

Join the call for low political donation limits and other key changes that actually stop big money in politics – click here to send your letter now to your politicians at the federal and provincial level.

(July 2026)

Freedom of information / access to information laws across Canada set out key rules for transparency of government institutions and public officials.  However, the laws across Canada have so many secrecy loopholes in them, and are so weakly enforced (especially given there are no penalties for violating the laws), that they really should be called the “guide to keeping information secret that the public has a right to know” laws.

Democracy Watch calls on all political parties at the federal level, and in every province and territory to work together to enact the 17 key changes set out below to make their freedom of information laws effective, and enforcement of the laws independent, timely, transparent, effective and accountable, and to ensure adequate training and resources to ensure their open government system operates effectively.

Key changes are needed to convert all exclusions in the laws into exemptions, and to narrow the scope of all exemptions and limit them with a proof of harm test and a public interest override, and to ensure the enforcement system is fully independent of the Cabinet, fully resourced, timely, transparent, effective and accountable, and to ensure training of all public and government officials concerning how to create and maintain records to ensure the public’s right to know is always respected and upheld, and to ensure penalties for violations of the laws (as it has become very clear that a main reason the laws are routinely and regularly violated is because there are no penalties for violations).

A. Key Changes Needed to Ensure the Freedom of Information Law Requires Timely, Low-Cost Disclosure of Information the Public Has a Right to Know

1. The freedom of information law (FOI law) should be changed to cover fully every “public institution” – meaning any entity which forms part of any branch of government, or which is established by or under the Constitution or a statute, or which is owned or controlled by another public institution, or has core operations substantially financed by a public institution, or which carries out a statutory or public function.

2. The FOI law should be changed to require every public institution to create detailed records of the process and reasons for all decisions and actions taken, including background factual and policy research (i.e. there must be a duty to document), and to retain and maintain those records for several years, no matter how the records are created (including recordings of online calls, texts, direct messages, PINs etc.) and no matter what type of device the records are created on (including all electronic devices, cellphones etc.), to ensure the public has access to the full documented record of every decision and action, and the law should also set out a clear right of public access to all communications between anyone in government with anyone outside the government (especially with anyone trying to influence the decision, whether or not they are a registered lobbyist) with regard to every decision and action.

3. The FOI law should be changed to require every public institution to disclose records that are likely to be of public interest routinely and regularly, including online in a searchable database and in a machine-readable format.

4. The FOI law should be changed to require public institutions to respond to access requests “as soon as possible”.  An extension of the 30-day initial time limit for responding should require the permission of the Information Commissioner and should be limited to a maximum of an additional 60 days.

5. The exceptions to the right of access in the FOI law should be clearly and narrowly defined and limited to the areas in which secrecy is required in the public interest.  In particular:

a) The frequently abused Cabinet advice and Cabinet confidence secrecy exemptions in the FOI law should be changed by restricting the application of the exemptions to only the part of any record that actually contains advice or recommendations (in other words, all facts, statistics, policy options and proposals and communications with anyone outside of the government trying to influence the decision (whether or not they are a registered lobbyist) should be obtainable through a freedom of information/access to information request);

b) All officers of the legislature, and all law enforcement entities, agencies, boards, commissions and tribunals, and the heads of government institutions, should be required to to disclose investigation records after each investigation is completed.

6. All exceptions in the FOI law should be strictly limited by a proof of harm test and a public interest override, and this condition should also be imposed on exceptions set out in other laws listed in any part or regulation listed in the FOI law.  All exceptions which protect the public interest should be subject to sunset clauses of maximum 20 years (and less than that for Cabinet records).

7. The FOI law should be changed to allow anyone who does factual or policy research for the government in an area not covered by an exception to speak to the media and publicly about the topic, findings and conclusions of their research without being required to seek approval first from anyone (including their superior, the Privy Council, the Prime Minister, a Cabinet minister, or any ministerial staff person).

8. The FOI law should be changed to remove the current restrictions on who may make an access request so that everyone, regardless of citizenship or residence, can make a request.

9. The FOI law should be changed to prohibit charging an application fee for filing an access request, and to prohibit charging search fees for records that have not been maintained in a way that facilitates access.

B. Key Changes Needed to Ensure Independent, Timely, Transparent, Effective and Accountable Enforcement of the FOI law

10. The FOI law should be changed to give the person/entity that enforces the law explicit powers to require systemic changes in government institutions to improve compliance with laws requirements, including requiring systemic changes to ensure records are managed effectively to facilitate public disclosure.

11. The FOI law should be changed to empower and require the person/entity that enforces the law to impose a sliding scale of mandatory minimum fines (i.e. administrative monetary penalties (AMPs)) and unpaid suspensions as penalties for intentionally obstructing access, including by not creating records, not maintaining records properly or delaying disclosure, with loss of job and pension as the mandatory penalty for the most serious violations.  The penalties should include, for government officials that attempt to escape a penalty by resigning or retiring, loss or partial clawback of any severance payment and/or partial clawback of any pension payments.

12. The FOI law should be changed to require the person/entity that enforces thel aw to issue a public ruling published on a searchable website for every complaint they receive, and every situation they review, and the public must have a clear right in the FOI law to appeal any decision in court.

13. The FOI law should be changed to establish a fully independent, non-partisan appointments commission (with members, appointed by non-governmental organizations like the Canadian Judicial Council, serving fixed terms of office) to conduct a merit-based search for nominees for person who heads up the entity that enforces the law, and to nominate a single qualified candidate for approval by an all-party committee of the legislature.

14. If a fully independent appointments commission is established as recommended above, the commission should also have the power to decide if the person who heads up the entity that enforces the law will be reappointed for another term.  If the commission is not established, the FOI law should be changed to make that person ineligible for a renewal of their first fixed term in office (to ensure that they do not make decisions, especially during the last couple of years of their term, to try to get reappointed for another term).

C. Key Changes to Ensure Adequate Resources for an Effective Open Government System

15. The FOI law should be changed to require the legislature to provide annual funding to the person/entity that enforces the law based on the budget presented by that entity and an assessment by the Auditor General of the funding needed to ensure effective, timely enforcement of the FOI law, effective training, and effective promotion of the right of access.

16. The FOI law should be changed to require a set amount of regular training by the office of the entity that enforces the law for all federal politicians, staff, appointees and government employees concerning the requirements in the FOI law and best-practice information and record management systems.

17. The FOI law should be changed to expand the mandate and budget of office of the entity that enforces the law to include promotion of the right of access and public awareness activities.

To: [email protected]
From: [email protected]
09 Feb, 26 5:46:15 PM
Complaint re: ATIP file #A-2024-2025-005 Comm. of Lobbying illegal retractions

To whom it may concern,

I hope all is well.  I am filing this complaint about how the Commissioner of Lobbying has responded to the Access to Information Act (ATIA) request I filed with them in May 2024, their ATIP file #A-2024-2025-005. I tried to file the online form but it didn’t work.

I filed the request in May 2024.  I requested the records of concluded investigations of the Commissioner — specifically records of investigations that the Commissioner had referred to the RCMP for further investigation for violations of the federal Lobbying Act, and that the RCMP had returned to the Commissioner after deciding not to prosecute the lobbyists involved in each situation, and that the Commissioner had then concluded the investigation file.

Under subsection 16.2(2) of the ATIA, the Commissioner is required to disclose any record that contains information that was created by the Commissioner or on the Commissioner’s behalf in the course of an investigation conducted by, or under the authority of, the Commissioner once the investigation and all related proceedings, if any, are finally concluded.

As a result, the Commissioner is required to disclose the records that I specifically requested.  The RCMP concluded related proceedings, and the Commissioner’s office concluded her investigation.

I specifically stated in my request that I was not requesting disclosure in any record of any personal or third-party information covered by s. 19 or s. 20 of the ATIA. I did this in order to avoid the delay that still happened as the Commissioner blatantly violated the ATIA by failing to disclose the records for more than one year after the Commissioner’s own self-imposed extension of the disclosure deadline to October 18, 2024.

The Commissioner finally disclosed the records on December 11, 2025.  The records, split into 13 files (one for each investigation of alleged violation(s) by a lobbyist) are too large to email to you, but you can get them from the Commissioner’s office.

I am filing this complaint because the disclosed records contain several illegal redactions by the Commissioner.  As you can see in the attached cover letter from the Commissioner’s office that was sent to me with the disclosed records on December 11th, the Commissioner states that the RCMP returned 13 files to the Commissioner’s office, and it seems clear that the Commissioner has also concluded the investigations in those files.

As you can also see, the letter from the Commissioner cites subsection 16.2(1) as one of the reasons for redactions in the records.

As you will also see when you review the 13 files of records that the Commissioner disclosed, several of the records cite subsection 16.2(1) of the ATIA as the reason for a redaction in the records, a subsection that is overridden entirely by subsection 16.2(2) as soon as the Commissioner concludes the investigation.  Each instance in the records that the Commissioner invokes subsection 16.2(1) is a blatant violation of subsection 16.2(2).

The Commissioner of Lobbying testified on April 16, 2024 before the House Ethics Committee that she had referred 15 cases to the RCMP since she became Commissioner in January 2018, and they had let off the lobbyists in 9 cases returned to her, and that the RCMP still had 4 cases under investigation. See p. 12 of testimony at:
https://www.ourcommons.ca/Content/Committee/441/ETHI/Evidence/EV13024643/ETHIEV112-E.PDF.

Commissioner Bélanger gave an update on October 6, 2025 before the House Ethics Committee, saying that she had referred 18 cases to the RCMP since she became Commissioner at the end of December 2017, and the RCMP had let off the lobbyists in 10 cases returned to her, and that 2 lobbyists had been prosecuted by the RCMP, 2 cases were “in discussion” (whatever that means), and that the RCMP still had 2 cases under investigation.  See p. 19 of testimony at:
https://www.ourcommons.ca/Content/Committee/451/ETHI/Evidence/EV13632163/ETHIEV07-E.PDF.

As a result, at least 10 of the 13 files of records disclosed by the Commissioner are fully concluded and, therefore, it is a violation of the ATIA to cite subsection 16.2(1) of the ATIA as one of the reasons for redactions in the records.

In addition, you will see when you review the 13 files containing the records of each of the 13 investigations that the Commissioner’s office regularly cites as the reason for redactions all of the provisions in the ATIA from “16(1)(c) – 16.2(1)” — meaning all of the provisions of the ATIA from 16(1)(c) through to and including 16.2(1).

Provision 16(1)(c) of the ATIA can only be used as a reason for a redaction if the redacted information “could reasonably be expected to be injurious to the enforcement of any law of Canada or a province or the conduct of lawful investigations…”  It is completely unreasonable to expect that investigation records about a concluded investigation, which are required to be disclosed under subsection 16.2(2) (which arguably also overrides provision 16(1)(c)), would be injurious to the enforcement of the federal  Lobbying Act.

Provision 16(1)(d) of the ATIA can only be used as a reason for a redaction if the redacted information “could reasonably be expected to be injurious to the security of penal institutions.”  None of the investigations by the Commissioner have anything to do with the security of penal institutions.

Subsection 16(2) of the ATIA can only be used as a reason for a redaction if the redacted information “could reasonably be expected to facilitate the commission of an offence”.  It is completely unreasonable to expect that investigation records about a concluded investigation, which are required to be disclosed under subsection 16.2(2) (which arguably also overrides provision 16(1)(c)), would facilitate the commission of an offence.

Subsection 16(3) of the ATIA can only be used as a reason for a redaction if the redacted information “contains information that was obtained or prepared by the Royal Canadian Mounted Police while performing policing services for a province or municipality”.  None of the investigations by the Commissioner have anything to do with that kind of information.

Subsection 16(4) of the ATIA defines “investigation” — it doesn’t apply and, therefore, it is clearly illegal to cite it as a reason to redact any record.

Section 16.1 applies to other government institutions — it doesn’t apply to the Commissioner of Lobbying and, therefore, it is clearly illegal to cite it as a reason to redact any record.

To give you a summary of the 13 files of investigation records disclosed by the Commissioner, all of them are concluded investigations and, therefore, it is a clear violation of the ATIA  to cite subsection 16.2(1) of the ATIA as the reason to redact any record in each of the 13 files.  It is also a clear violation of the ATIA to cite subsections 16(3), 16(4) and 16.1 as the reason to redact any record in each of the 13 files.  It is also highly questionable, and clearly unreasonable, for the Commissioner to cite provisions 16(1)(c) and (d), and subsections 16(2) as the reason to redact any record in each of the 13 files.  It is very likely that the Commissioner could not actually point to any evidence or cite any reason at all that any of the redactions are in any way justified under provisions 16(1)(c) or (d) or subsection 16(2) of the ATIA.

As a result, a full investigation by the Information Commissioner is justified to reverse and sanction these clear violations of the ATIA by the Commissioner’s office.

Here is the list of the 13 files, and the dates which the records in each file say the Commissioner concluded her investigation:

File #1 — On the last page of this file of investigation records, it says the Commissioner made her final decision concerning this investigation on Dec. 12, 2023.

File #2 — On the last page of this file of investigation records, it says the Commissioner made her final decision concerning this investigation on May 2, 2024.

File #3 — On the last page of this file of investigation records, it says the Commissioner made her final decision concerning this investigation on March 31, 2023.

File #4 — On the last page of this file of investigation records, it says the Commissioner made her final decision concerning this investigation on May 2, 2024.

File #5 — On the last page of this file of investigation records, it says the Commissioner made her final decision concerning this investigation on November 23, 2021.

File #6 — On the last page of this file of investigation records, it says the Commissioner made her final decision concerning this investigation on March 31, 2023.

File #7 — On the last page of this file of investigation records, it says the Commissioner made her final decision concerning this investigation on March 31, 2023.

File #8 — On the last page of this file of investigation records, it says the Commissioner made her final decision concerning this investigation on March 31, 2023.

File #9 — On the last page of this file of investigation records, it says the Commissioner made her final decision concerning this investigation on January 15, 2021.

File #10 — On the last page of this file of investigation records, it says the Commissioner made her final decision concerning this investigation on July 2, 2019.

File #11 — On the last page of this file of investigation records, it says the Commissioner made her final decision concerning this investigation on February 6, 2023.

File #12 — On the last page of this file of investigation records, it says the Commissioner made her final decision concerning this investigation on May 15, 2023.

File #13 — On the last page of this file of investigation records, it says the Commissioner made her final decision concerning this investigation on January 28, 2025.

I look forward to hearing back from you and to a full investigation of these violations of the ATIA by the Office of the Commissioner of Lobbying.

Sincerely,
Duff Conacher, Co-founder of Democracy Watch
Democracy Watch
P.O. Box 821, Stn. B
Ottawa, Ontario
Canada
K1P 5P9
Tel: 613-241-5179
Fax: 613-241-4758
Email: [email protected]
Internet: http://democracywatch.ca
Twitter: @DemocracyWatchr
Facebook: https://www.facebook.com/DemocracyWatch

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Under Canada’s federal Lobbying Act, only some lobbyists are required to register and disclose only some of their lobbying activities and communications with federal Cabinet ministers, government officials, politicians, political staff etc.

The Act contains a “dirty dozen” loopholes that allow for secret, unregistered lobbying.  Click here to see the loopholes. 

Only lobbyists who are required to register under the Act are required to comply with the ethical lobbying rules in the federal Lobbyists’ Code of Conduct (Lobbyists’ Code), and the Code also has huge loopholes in it that allow even registered lobbyists to essentially bribe politicians and public officials they are lobbying with favours and gifts.

The loopholes were added to the federal Lobbyists’ Code in July 2023 after a skewed and dishonest public consultation process by Commissioner of Lobbying Nancy Bélanger, with the approval of MPs from all parties on the House of Commons Access to Information, Privacy and Ethics Committee.  In adding the loopholes, which essentially gut key ethics rules in the Code, Commissioner Bélanger ignored the fact that adding the loopholes was opposed by more than 20,000 voters, by 26 citizen groups with a total membership of 1.5 million Canadians, by 15 lawyers from 7 law firms (and also lawyers in private practice or other roles), and by 26 law, politics and ethics professors from 15 universities in 9 provinces (Click here to see details).

The following are the loopholes in the federal Lobbyists’ Code that allow for unethical lobbying and essentially legalize bribery of federal politicians:

1.  A lobbyist is allowed to do secret favours for politicians they are lobbying or are allowed to lobby them soon after doing the favours
         In the pre-July 2023 version of the Lobbyists’ Code, Rules 6 and 9 and a guideline by the Commissioner prohibited lobbying for 4 years (i.e. until after the next election) after a person did any significant campaigning or event organizing, or any fundraising, for a politician or party.
         Under Rule 4.2 in the new Code, depending on the level of campaigning or fundraising a person does for a politician or party, lobbying is allowed at the same time, or right afterwards, or at most only 1-2 years later (only at most 1 year later no matter how much money a lobbyist raises).
         Rule 4.2 also gives the Commissioner of Lobbying the power to secretly reduce those lobbying prohibition periods.
         When proposing the new loophole, Commissioner of Lobbying Bélanger made the very questionable claim that the Code’s previous 4-year cooling-off period violates the Canadian Charter right to freedom of expression, based on one opinion that the Commissioner paid law firm Goldblatt Partners for in a sole-source contract that was extended twice, increasing from $11,300 to $45,200 and then up to $90,400.
         In fact, several Supreme Court of Canada and other Canadian court rulings have clearly stated that Charter rights must be restricted to protect government integrity, and as a result it is clear that the previous 4-year cooling-off period complies with the Charter while the new shorter or non-existent cooling-off periods violate the Charter.
         The Lobbyists’ Code should be changed to again prohibit, without any exemptions, anyone from lobbying any party leader and any MP, Senator or their staff in their party and any party official for at least 4 years after they have done significant campaigning, fundraising, event organizing or any other favour for the party leader or party, and to prohibit anyone from lobbying any individual MP, Senator or their staff after they have done significant campaigning, fundraising, event organizing or any other favour for the MP or Senator. If the Commissioner is allowed to continue to have the power to grant exemptions, the Commissioner must also be required to publish each exemption as soon as it is granted in an online, searchable, public registry.

2.  Gifts and hospitality are allowed to be given by lobbyists to politicians and public officials they lobby
         Under Rules 3.1 to 3.3 of the Lobbyists’ Code, lobbyists are allowed to give a gift or hospitality (i.e. a meal or event) worth up to $40 each time, and up to $200 over any 12-month period.
         While those dollar amounts are not exorbitantly high, and can be afforded by most lobbying organizations, and while these rules are stronger than in past versions of the Code, the rules open up gift-giving and wining and dining as a means of influence, and the limits are difficult to enforce because lobbyist’s interactions with public officials can’t be monitored in any comprehensive, detailed way.
         In addition, the Rules allow the Commissioner to secretly exempt lobbyists from the limits.
         In addition, the Rules allow lobbyists to give gifts to political party officials (who can pass them on to politicians or political staff in their party), and the Rules also allow lobbyists to offer or give other benefits to politicians and public officials, such as a donation to their favourite charity, or a gift or benefit or job to a family member, or the promise of a job in the future after they leave their political or government position.
         The Lobbyists’ Code should be changed to prohibit lobbyists, without any exemptions, from offering or giving, directly or indirectly, any gift or any other type of benefit or advantage to any politician, political staff, political party official or public official or to any member of their family. This clear prohibition not only closes loopholes in the current Code rules, it is also a better system because clinical studies by psychologists in many countries show that even small gifts influence decisions.

3.  Lobbying for clients that have conflicting interests is allowed
         In a past, pre-2015 version of the Lobbyists’ Code, lobbyists were prohibited from representing clients that had conflicting interests unless the clients consented.  The current version of the Code allows lobbyists to representing clients with conflicting interests, which has led to some lobbying firms doing that.  Click here to see details.
         The Lobbyists’ Code should be changed to again prohibit, without any exemptions, anyone from lobbying for a client whose interests conflict with another client unless all the clients consent in writing.

4.  Lobbyists are allowed to use secret information obtained from politicians and public officials
         In the pre-July 2023 version of the Lobbyists’ Code, Rule 5 stated that “If a lobbyist obtains a government document they should not have, they shall neither use nor disclose it.” Rule 2.2 of the new Code says a lobbyist can use or share information obtained from a public official in confidence if the lobbyist has the official’s informed consent.
         The Lobbyists’ Code should be changed to again prohibit, without any exemptions, lobbyists from using or sharing secret information they have obtained from any politician, political staff or public official.

Click here to see key changes needed to make lobbying law and lobbying code enforcement effective.

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Join the call for key changes to stop secret, unethical lobbying across Canada at Democracy Watch’s Stop Secret, Unethical Lobbying Campaign

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