Registration Requirements under the Foreign Influence Transparency and Accountability Act

On August 4, 2026, the Foreign Influence Transparency and Accountability Act, SC 2024, c 16, s 113 (“FITAA”) and its regulations come into force. FITTA requires those who have an arrangement with foreign entities, including governments, political parties or economic entities (collectively, “Foreign Entities”), to register with the Foreign Influence Transparency Commissioner (“Commissioner”). This blog post explains the purpose of the new legislation, when charities may need to register, and what is required when registering.  

What is the Purpose of the FITAA?

The purpose of the FITAA is to increase transparency, strengthen national security, and help the public understand when Foreign Entities try to influence Canadian political or governmental decisions. It applies when Foreign Entities do any of the following activities in relation to Canadian political or governmental processes (called an “arrangement” in the legislation):

• Communicating with public office holders;
• Communicating or sharing information;
• Distribute money or valuable items; or
• Provide a service or a facility to use.

Political and governmental processes include:

• Proceedings in the legislature or development of a legislative proposal;
• Developing or changing a program;
• Making a decision of a public office holder or government body;
• Holding an election or referendum; and
• Nominating a candidate or developing a political party’s platform.

FITTA applies at all levels of government – federal, provincial, and municipal.

When is Registration Required?

The three key conditions to determine whether registration is required:

1. The individual or organization has an arrangement with a foreign principal;
2. The arrangement aims to influence a Canadian political or governmental process; and
3. The arrangement includes the foreign principal engaging in influence activities.

You can also complete this questionnaire to help determine whether registration is required. Registration is required within 14 days of entering into an arrangement. Arrangements existing before August 4, 2026 must be registered by October 3, 2026. Failure to register may result in significant fines and/or criminal charges.

Registration is not required when foreign parliamentarians or governments are acting within their official duties.

What does this mean for Charities?  

Charities need to review how they interact with Foreign Entities. Many charities communicate with governments, participate in public policy discussions, or collaborate with organizations outside Canada. You could be communicating with members of public office through:

• In-person or virtual meetings or phone calls;
• Letters, emails, text messages, or other written communications;
• Presentations or briefings;
• Engaging consultations, working groups or round tables when members of public office are present; and
• Requesting meetings or follow-up communications, even if a decision is not made.

Canadian charities are permitted to engage in public policy and development activities, but should review whether any of these activities require registration under FITTA.

Example

A Canadian charity prepares a submission to the Federal Government about a proposed government program. While preparing the submission, the charity consults with officials from a foreign government through emails and virtual meetings to learn about a similar program in that country. The charity publishes its submission online and shares it with the federal government. In this example, the Canadian charity would be required to register with the Commissioner.  

How to Register

The registration form will be available on August 4, 2026. The following details will be requested when registering:

• Name, date of birth and place of birth for all individuals who entered into the arrangement and engaged in influence activities;
• Incorporation, business number, charitable number and website for entities;
• Contact information for individuals or entities that entered into the arrangement;
• Information about the foreign principal, including name, address, website, and
• Details about the arrangement, including applicable dates, the political or governmental processes being influenced, the activities being engaged in, and whether compensation was provided.

Once registered, organizations are required to keep their information up to date. The Office of the Commissioner provides helpful FAQs on registration and compliance.

We’re Here to Help

If you have questions or would like support, please contact our Member Support Team by phone or email.