At least 5,000 were serious violations (likely more) – all have been let off in secret rulings without the lobbyist being identified, and without any penalty

Commissioner and the RCMP illegally hiding their investigation records in 13 cases of the most serious violations

Commissioner also gutted key rules in the lobbying code in ways that allow for unethical lobbying

House Ethics Committee must recommend many key changes to close loopholes in the law and code, and to require effective enforcement

FOR IMMEDIATE RELEASE:
Thursday, October 1, 2026

OTTAWA – Today, Democracy Watch released its report on Commissioner of Lobbying Nancy Bélanger’s negligently weak enforcement record of the federal Lobbying Act and Lobbyists’ Code of Conduct since she started in the position in January 2018 through to the end of March 2026.  Given her incredibly bad record, it was negligent for federal parties to have re-appointed her to a second term as Commissioner in November 2024.

The House Ethics Committee is currently conducting an illegally long-overdue review of the Lobbying Act for the first time since 2012 (the Act is required to be reviewed by a committee every five years), and its report (which will likely be released in November) clearly needs to call on the government to close huge loopholes in the Act and Code that allow for secret lobbying, and unethical lobbying, and to require independent, timely, transparent, effective and accountable enforcement, including public rulings and mandatory penalties for all violations.

A national survey in January 2025 showed that more than 80% of Canadian voters want all secret, unethical lobbying stopped.

Commissioner Bélanger, in testimony on October 6, 2025 before the House of Commons Ethics Committee, admitted that she allows up to 10 violations of the Lobbying Act every week by lobbyists who fail to disclose their lobbying activities by the required deadlines (See p. 17 of testimony just above the 1245 mark, and p. 19 at the top of the second column).  And in her testimony before the Ethics Committee on May 7, 2026 she admitted that she lets off many violations (8% of all registrations in 2025-2026 were late in violation of the Act and she let them all off – see p. 3 of testimony above the 1545 mark).

Democracy Watch’s 32-page report details that:

1. Commissioner Bélanger has let off 99.99% (31,803 out of 31,806) of the lobbyists she has caught violating the Act or Code with a secret ruling that hid the identity of the violating lobbyist and did not penalize the violator in any way, according to her annual reports (and she has likely issued even more secret rulings letting off lobbyists that she has not disclosed).

2.  For all 31,806 violations, Commissioner Bélanger could have issued a public ruling identifying and finding the lobbyist guilty of violating the Lobbyists’ Code as a former Commissioner did in a past case, and as the Commissioner acknowledged in her Feb. 2024 ruling finding a lobbyist in violation of the Code, because violating the Act is a violation of the Code. While it is reasonable that the Commissioner allowed lobbyists who violated the Act one time in a less serious way to just take corrective action, she also let off lobbyists involved in at least 5,054 significant violations, such as failing to register and disclose lobbying for more than 30 days (many up to 6 months late), filing significantly inaccurate registrations and/or failing to correct inaccurate registrations for up to 6 months.

3.  There are very likely many more significant violations of the Lobbying Act out of the 31,806 total violations. Many of Commissioner Bélanger’s annual reports hide details about exactly how many significant violations there have been each year since 2018. As well, there is no evidence in the reports that the Commissioner is proactively enforcing the ethical lobbying rules in the Lobbyists’ Code and, as a result, there are likely many more violations of the Code happening that are not being caught.

4. In addition, Commissioner Bélanger and the RCMP are both currently violating the Access to Information Act (ATIA) by hiding their investigation records in 13 cases of the most serious violations of the Lobbying Act that they both let go without any charges or penalties, including violations by lobbyists for SNC-Lavalin, and likely also including violations by lobbyists for Facebook, WE Charity and others that would have embarrassed the Trudeau Liberal Cabinet. Click here to see details.  The federal Information Commissioner’s office confirmed in February 2026 that investigating the Commissioner and the RCMP for violating the ATIA, but seven months have passed and still no one in the office has been assigned to investigate.

5. As well, Commissioner Bélanger let off two lobbyists who clearly violated the Code by helping Finance Minister Chrystia Freeland win an election, and serving on her riding association executive, and then lobbying her office and department soon afterwards. Click here to see details.

6. Of the 19 total cases of some of the most serious violations of the Lobbying Act that Commissioner Bélanger referred to the RCMP for prosecution, the RCMP has let off 94% (15 out of 16) of the lobbyists. As of March 2026, the RCMP had 3 other cases still under investigation.

7. A federal Crown prosecutor told the RCMP sometime after January 2018 that one key provision of the Lobbying Act was unenforceable and so no lobbyist would ever be prosecuted for violating that provision. Did the RCMP tell the Commissioner, or the government, or anyone, that obviously key information about a huge loophole in the Act?

8. Commissioner Bélanger also gutted key rules in the Code in 2023 in ways that allow for rampant unethical lobbying, ignoring the opposition to the changes from a coalition of 26 citizen groups with 1.5 million total supporters, and 41 lawyers and professors from across Canada, and 20,000+ voters. Click here for details.

9. Commissioner Bélanger has also used her power from January 2018 to April 2026 to grant 30 exemptions to the (loophole-filled) 5-year prohibition on lobbying after leaving public office.

As a result of Commissioner Bélanger doing essentially nothing effective to stop thousands of lobbyists from failing to register their lobbying on time, and accurately, and letting them get away with registering for up to 6 months after they started lobbying, almost all media reports over the past 8 years about “who is lobbying whom” in federal politics are very likely inaccurate.

Commissioner Bélanger’s and the RCMP’s negligently bad enforcement records makes it clear that many changes are needed to the Act to require the Commissioner and the RCMP to enforce the Act and Lobbyists’ Code strictly, strongly, effectively and transparently (in addition to closing a “dirty dozen” secret lobbying loopholes in the Act, and closing unethical lobbying loopholes in the Code).

“Commissioner of Lobbying Nancy Bélanger has a horribly negligent and weak enforcement record and has let thousands of lobbyists violate the federal lobbying law and code in serious ways without identifying the lobbyists publicly or penalizing them, and she also gutted the code in ways that allow for unethical lobbying,” said Duff Conacher, Co-founder of Democracy Watch. “To stop rampant secret, unethical lobbying, the House Ethics Committee’s current review of the lobbying law must result in recommendations that call for closing all the loopholes in the law and code, and requiring the Commissioner to enforce the law and code strictly, strongly, effectively and transparently, including imposing a penalty on every lobbyist who violates the law or code.”

The 13 violations Commissioner Bélanger and the RCMP are currently hiding include, in at least one of the 13 cases, lobbying by SNC-Lavalin lobbyists during the Trudeau Liberal Cabinet/SNC-Lavalin scandal, likely by former PCO Clerk Kevin Lynch that was not registered by SNC-Lavalin CEO Neil Bruce (click here to see DWatch’s March 2019 complaint), and by SNC-Lavalin lawyer Robert Pritchard and others.  The violations also likely include the following situations that have never been ruled on publicly by the Commissioner:

1. The unregistered lobbying and favours for Trudeau Liberal Cabinet ministers that Kevin Chan and others at Facebook did (click here to see DWatch’s April 2018 complaint to the Commissioner);

2. The unregistered lobbying that WE Charity lobbyists did of Trudeau Liberal Cabinet ministers from January 2019 to August 2020, and the trip gifts they gave to former Liberal Finance Minister Bill Morneau and his family;

3. The lobbying by Imperial Oil of then-Conservative Party Leader Andrew Scheer, and by CPA Canada of Minister Karina Gould, at a May 2019 event they sponsored, and/or;

4. The lobbying done by associates of Jenni Byrne, then at top adviser to Conservative Party leader Pierre Poilievre.

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FOR MORE INFORMATION, CONTACT:
Duff Conacher, Co-founder of Democracy Watch
Tel: (613) 241-5179
Cell: 416-546-3443
Email: [email protected]

Democracy Watch’s Stop Secret, Unethical Lobbying Campaign, Stop Bad Government Appointments Campaign and Open Government Campaign