Reforming Quebec’s Lobbying Regime: Overview of the Commissioner’s Special Report and Proposed Obligations

On May 26, 2026, Quebec’s lobbying commissioner tabled a special report (Report), titled Le devoir d’agir pour la transparence et l’intégrité (“The Duty to Act for Transparency and Integrity”) (available in French only), before Quebec’s National Assembly. The Report is set against an institutional and political backdrop marked by an explicit will to overhaul the province’s framework governing lobbying activities.

The Report follows the National Assembly’s unanimous adoption, on February 17, 2026, of a motion calling for the provincial government to pass legislation that would overhaul Quebec’s Lobbying Transparency and Ethics Act (Act), pursuant to recommendation no. 25 of the report by the Commission d’enquête sur la gestion de la modernisation des systèmes informatiques de la Société de l’assurance automobile du Québec (Inquiry Commission on the Management of the Modernization of the Société de l’assurance automobile du Québec’s IT systems) (Gallant Commission).

The Report highlights certain limitations of the current framework, particularly in ensuring effective transparency of lobbying communications. 

In this regard, the Report underscores the difficulties in interpreting the concept of “significant part,” which is central to the current regime. The term is used in the Act’s legal definition of corporate (or “enterprise”) lobbying, limiting the regime’s application to certain individuals who engage in lobbying activities as a “significant part” of their job or function. This approach, based on a qualitative threshold, is intended to exclude occasional or incidental activities from the regime’s scope.

However, the Report notes that, in practice, this threshold proves difficult to define and apply in light of case law, particularly since the Quebec Court of Appeal’s decision in Cliche c. Directeur des poursuites criminelles et pénales.

In this context, the Report emphasizes that the concept of “significant part” raises issues regarding evidence of the regime’s application and makes it difficult to determine whether certain lobbying activities qualify as a significant part of a lobbyist’s job or function. According to the Report, this results in certain activities being excluded from Quebec’s lobbying registry — activities that, although relevant from a public interest perspective, do not clearly meet this threshold.

According to Quebec’s lobbying commissioner (Commissioner), it can be difficult for citizens and public policymakers alike to determine whether lobbying activities have taken place, as the mere absence of an entry in the lobbying registry is not, in and of itself, evidence that no lobbying has occurred.

Proposed Legal Framework Based on Representation of Interests

The Report proposes a new bill based on a paradigm shift. 

This shift includes the suggestion to replace the terms “lobbyisme” (lobbying) and “lobbyiste” (lobbyist) with the more neutral “représentation d’intérêts” (representation of interests) and “représentant d’intérêts” (representative of interests), respectively. This change in terminology is intended to recognize the legitimacy of these activities while fostering a greater culture of transparency and understanding, breaking away from the stigma historically associated with lobbying.

The proposed reform focuses on five pillars:

1. Refocusing the scope of the regime on public decisions of significant interest to citizens

The proposed refocusing builds on an approach based on the nature, subject matter and significance of the decisions in question, rather than on rigid thresholds. To that end, the reform provides for, among other things, the elimination of the thresholds applicable to the concepts of “significant part” and “compensation” (contrepartie), as well as the expansion of the regime’s scope to capture a wider range of organizations, including certain nonprofit entities.

The Report provides a broad definition of the concept of “representation of interests” that encompasses any communication likely to influence a public decision, whether directly or indirectly. It also includes activities such as organizing meetings and making appeals to the public.

The term “entité” (entity) would now encompass any organization or business, regardless of its legal form, as well as individuals acting in an advisory capacity thereto.

2. Improving the quality and accessibility of public disclosures

The reform would provide for a maximum 10-day deadline for disclosing representations of interests, along with a requirement to track the activities actually carried out, with the aim of fostering timely oversight by citizens, the media and public institutions. The deadlines are currently set at 30 or 60 days, depending on the circumstances.

The proposed framework does, however, provide for certain exceptions, notably for communications falling under the category of “dialogue citoyen” (citizen dialogue), a newly introduced concept that encompasses normal interactions between citizens and public institutions, such as public consultations, petitions and individual undertakings. 

In addition, certain representations would be exempt from disclosure on grounds of proportionality, particularly those relating to a contract or financial contribution whose estimated total value or amount is less than C$25,000.

3. Shifting primary accountability to the organizations that initiate and benefit from representations of interests

The third pillar marks a fundamental shift in legal liability toward the entities that engage in representations of interests.

Unlike the current regime, which applies primarily to individuals, the proposed overhaul would now impose disclosure obligations and liability for violations on the entities that engage in representations of interests, regardless of whether they act on their own behalf or in an advisory capacity. This approach, similar to other administrative compliance regimes, aims to strengthen the accountability of actors who benefit from lobbying efforts and to foster a culture of compliance within enterprises and organizations. 

4. Committing public institutions to transparency: Prevention, training, reporting and post-term rules

The fourth pillar aims to place a greater burden of responsibility on public institutions. 

The proposed reform calls for the implementation of explicit governance obligations for public institutions, including the adoption of internal policies, the designation of a person in charge of advising their colleagues on compliance with the regime (“répondant”), the training of public officials and the application of reporting mechanisms. It also sets out direct obligations for public officials, including a requirement to refuse to meet with any representative of interests that isn’t listed in Quebec’s lobbying registry, as well as mandatory participation in training sessions.

In addition, the reform sets out supplementary transparency measures, namely the proactive publication of certain elected officials’ schedules, as well as the introduction of broad restrictions that would apply both during and after elected officials’ terms of office, particularly regarding conflicts of interest and the use of confidential information.

5. Expanding the Commissioner’s powers

The proposed reform also introduces administrative monetary penalties to expand the Commissioner’s scope of action, as the current regime only allows for disciplinary measures and criminal sanctions. 

The proposed reform would also strengthen the Commissioner’s educational mission and provide regulatory mechanisms to allow for the regime’s evolution. The Commissioner’s powers would be expanded in the areas of auditing, investigation, regulation and information dissemination.

Key Takeaways

In short, the Report proposes a substantial overhaul of the current framework governing lobbying activities, including replacing certain key concepts such as the notion of “significant part.”

The proposed changes would broaden the scope of activities subject to the regime, shorten disclosure deadlines and reassign certain responsibilities to entities that engage in representations of interests, while also strengthening the role of public institutions and widening the Commissioner’s powers.

With this in mind, organizations that are likely to interact with public policymakers may need to review their internal practices, particularly with respect to governance, monitoring strategic influence communications, and regulatory compliance.

The Report also calls on lawmakers to consider these proposals as part of their upcoming legislative work, which suggests that there may be short- or medium-term developments in the evolution of Quebec’s lobbying regime.

For more information, please contact the authors or any other member of our Public Sector Crisis & Compliance and Regulatory groups.