Update: Registry of Foreign Influence Activities Now in Effect

The Foreign Influence Transparency and Accountability Act and associated Foreign Influence Transparency and Accountability Regulations officially came into force on August 4, 2026. That means individuals and organizations that have an “arrangement” with a “foreign principal” to conduct “influence activities” now need to register their arrangement with the foreign influence registry.

New arrangements entered into on or after August 4, 2026 must be registered within 14 days. Any arrangements that existed prior to August 4th must be disclosed by October 3, 2026. Penalties for compliance issues are hefty, with financial penalties ranging up to $1,000,000 and a risk of criminal prosecution, so understanding and complying with the legislation is critical.

The Act provides for two distinct enforcement tracks: administrative monetary penalties (“AMPs”) and offences. AMPs can reach $1,000,000 per violation and are intended to promote compliance with the Act, not to punish. A conviction for an offence can result in a fine of up to $5,000,000, imprisonment for up to five years, or both. A due diligence defence is available for offences but not for AMPs. Understanding and complying with the legislation is therefore critical.

For additional background, please see our previous article (here), which explains how to assess whether your activities fall within the Act’s scope and what information will be publicly available in the registry.

Since that article was published, the Office of the Foreign Influence Commissioner of Canada has issued a number of interpretation bulletins—plain-language guidance on how the Act is expected to be applied.[1] These bulletins, while non-binding and subject to change, provide some useful clarifications regarding what is expected to be caught (or not caught) by the Act. A few examples are as follows:

  • Legal advice which is subject to solicitor-client privilege is not considered an influence activity, and neither is representing a foreign principal in litigation;
  • An “arrangement” can arise in a contract, employment or membership context, but it need not be formal;
  • Direction of the foreign principal may be explicit or implicit, formal or informal or communicated via instructions, requests or expectations;
  • Influence activities are intentionally defined broadly and include, for example:
    • Sending correspondence to public office holders providing feedback on proposed regulations;
    • Conducting a social media campaign targeting a Canadian audience about the importance of Canada maintaining strong relations with a foreign state;
    • Distributing teaching materials, such as books, that advocate for a foreign principal’s position;
    • Hosting a public event at which a foreign ambassador speaks about the importance of Canada's continued support for an initiative.

The Commissioner’s Office also clarified that only arrangements which involve undertaking specific activities in relation to a Canadian political or governmental process are caught. The following, on their own, are not anticipated to constitute an arrangement:

  • 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; and
  • parallel or coincidental actions.

Additionally, while anyone who conducts influence activities as part of an arrangement must be included in the registration, the Commissioner’s Office clarified that involves only those persons directly involved in the influence activities. Persons providing a good or service that purely enables the execution of an influence activity (for example, a caterer hired for a public event) do not need to be included.

We anticipate further clarification from the Commissioner’s Office as the first rounds of disclosure are submitted so impacted businesses should keep an eye out for further interpretation bulletins or legislative amendments in the coming months.

Please contact Stuart Chambers or Lydia Roseman with any questions regarding this new legislation, including how it may apply to your organization.