Commissioner of Lobbying has covered up almost 32,000 lobbying law violations (99.99% of all violations) since 2018

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:
Monday, October 26, 2026

OTTAWA – Today, with federal Commissioner of Lobbying Nancy Bélanger scheduled to testify before the House Ethics Committee from 11 am to 1 pm EDT, Democracy Watch called on MPs on the Committee to ask the Commissioner key questions about her negligently bad enforcement record of letting off almost 32,000 violations in secret rulings since 2018, including more than 5,000 serious violations, and about other enforcement problems, and loopholes in the Lobbying Act and Lobbyists’ Code that allow for rampant secret, unethical lobbying.

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.

The 10 key questions for MPs on the Ethics Committee to ask Commissioner Bélanger today are:

1.  Is she aware of the national survey from January 2025 showing that more than 80% of Canadian voters want all lobbying disclosed, and don’t want lobbyists giving gifts to, or doing favours for, politicians and public officials?

2.  Given former Commissioner Karen Shepherd issued a public ruling identifying a lobbyist who violated the Lobbying Act by failing to register his lobbying, and found him guilty of violating the Lobbyists’ Code, and the Federal Courts ruled that the Commissioner has the clear legal power to do that, why did Commissioner Bélanger, in secret without identifying any of the lobbyists or finding them guilty of violating the Code, let off all the lobbyists who violated the Act a total of 31,803 times since 2018 by failing to register their lobbying on time and/or accurately as required by the Act?

3.  Many of the 31,803 violations were minor infractions, but almost 3,800 of the violations involved a lobbyist failing to register their lobbying for more than one month to more than 6 months after the Act’s registration deadline, and another more than 1,250 violations involved a lobbyist repeatedly failing to register their lobbying accurately. As the Commissioner herself has told the Committee on May 7th, “transparency delayed is no transparency at all” ( 7 of transcript above 1610 mark). So why did Commissioner Bélanger, in secret, let all of the lobbyists off who violated the Act in these serious ways more than 5,000 times?  Why didn’t she issue even one public ruling identifying even one of these lobbyists and finding them guilty of violating the Code, as the Federal Courts have ruled she is clearly empowered to do, and as she told the Committee she could do on March 9th (p. 14 of transcript above 1650 mark) and on May 7th (pp. 3 and 5 of transcript)?

4.  If Commissioner Bélanger makes the clearly false claim that she is only allowed to refer violations of the Act to the RCMP, then the question is why, since 2018, has she only referred 19 of the more than 5,000 serious violations of the Act to the RCMP?

5.  As of last May, the RCMP had only prosecuted 2 of the 19 violating lobbyists, and had referred 14 violations back to the Commissioner (with 3 still under RCMP investigation). Why did Commissioner Bélanger not issue even one public ruling identifying even one of the lobbyists involved in the 14 other cases and finding them guilty of violating the Code, as the Federal Courts have ruled she is clearly empowered to do, and as she told the Committee she could do on March 9th ( 14 of transcript above 1650 mark) and on May 7th (pp. 3 and 5 of transcript)? NOTE: The RCMP and Commissioner are currently violating the Access to Information Act by hiding their investigation records in these cases, and the Information Commissioner is investigating their violations.

6.  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 (Click here for details). Did the RCMP tell Commissioner Bélanger that information and, if so, when did the RCMP tell her?

7.  Commissioner Bélanger has told the Ethics Committee several times that the biggest loophole in the Act is that it doesn’t cover unpaid lobbying, and “that should be changed” (October 6, 2025, 13 above and below 1220 mark) and is “something that we should be looking into” (March 9th, p. 5 of transcript above 1600 mark and pp. 6-7, 13-14).  So why didn’t Commissioner Bélanger recommend closing this biggest loophole in her submission to the Committee?

8.  In addition to the huge unpaid lobbying loophole, is it true that the Act does not require you to to register as a lobbyist if:

a.  You lobby about “the enforcement, interpretation or application of any Act of Parliament or regulation” (clause 4(2)(b) of the Act) which is what much business lobbying is about?

b.  You lobby for a tax credit (according to an interpretation bulletin issued by former Commissioner Shepherd that Commissioner Bélanger has not clearly repealed) which, again, is something businesses often lobby about?

c.  You lobby political party officials who then pass on your demands to the party leader and Cabinet ministers (or opposition critics)?

So why didn’t Commissioner Bélanger recommend closing these secret lobbying loopholes in her submission to the Committee?

9.  Is it also true that, if you register as a lobbyist, the Act does not require you to disclose whether you have fundraised or campaigned for or assisted politicians or political parties or party leaders in other significant ways, nor do you have to disclose how much your business, organization or client is spending on its lobbying effort? So why didn’t Commissioner Bélanger recommend closing these secret, unethical lobbying loopholes in her submission to the Committee?

10.  ls it true that people who come to the federal government under the Build Canada Exchange program (formerly the Interchange Canada program) are exempt from the five-year ban on being a registered lobbyist when they return to their business after working in government? And doesn’t that exemption, combined with the many loopholes that allow for unregistered lobbying, mean that there really is no five-year ban on lobbying by former public office holders?

Commissioner Bélanger’s and the RCMP’s negligently bad enforcement records make 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 ethical lobbying 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.”

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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