Snap Election, Strict Rules: Navigating Compliance While Engaging in B.C.’s Provincial Election

British Columbians are headed to the ballot boxes on October 24, 2026, as Premier David Eby has called a snap election.

The campaign, set against a backdrop of global geopolitical and economic uncertainty, provides an opportunity for businesses and other stakeholders to ensure their perspectives are considered, but this opportunity comes with certain obligations.

Engagement in the B.C. provincial election is subject to some of the strictest lobbying rules in Canada, stringent election financing and advertising legislation, and Canada’s new foreign influence rules.

In this bulletin, we provide a high-level overview of the key rules businesses must follow when trying to influence policy and public debates during the B.C. provincial election campaign.

Lobbying in a Snap Election

B.C.’s Lobbyists’ Transparency Act (LTA) continues to apply to certain candidates and staffers throughout the campaign. Activities undertaken by lobbyists may also need to be reported after the election if a candidate is elected and subsequently lobbied.

1. Registration Requirements

The LTA requires that virtually all communications with a “public office holder” in an attempt to influence an enumerated subject matter (including legislation, government policy and government contracts) be captured in a lobbying registration.

The Premier, his cabinet ministers and their respective staff remain “public office holders” until a new cabinet is sworn in, as do other public office holders who take a leave of absence to participate in the election. Communication with these individuals with a view to influencing policy (or any other enumerated subject matter set out in the LTA) is subject to the normal registration requirements.

Conversely, communications with candidates who are not public office holders are not subject to the LTA and will not require registration. This includes candidates who are incumbent Members of the Legislative Assembly (MLAs) not in cabinet, who ceased to be “public office holders” upon the dissolution of the Legislative Assembly.

Businesses will need to determine whether the candidates with whom they communicate over the course of the campaign are “public office holders” and, if so, ensure all necessary lobbying registrations and communication reports are filed on time.

2. Gift Giving and Contributions

Lobbyists are subject to ethical obligations in addition to reporting requirements.

The LTA prohibits lobbyists from providing gifts to public office holders they are lobbying (subject to very narrow exceptions) and requires lobbyists to disclose any gifts or contributions given to a public office holder being lobbied.

Even though a candidate may not be a public office holder during the campaign, if elected and subsequently lobbied, gifts and contributions provided over the course of the campaign to the now-MLA will still be reportable (even if they were not a “public office holder” when the gift or contribution was actually provided). Gifts provided to successful candidates during the election period will still be subject to prohibition and may limit which MLAs can be lobbied when the Legislative Assembly returns. Businesses are urged to exercise caution before providing any gifts or other benefits to candidates.

Election Advertising and Political Contributions

Third parties also have obligations under the B.C. Election Act, which places limits on political contributions and election advertising.

1. Corporations and Organizations Cannot Make Political Contributions

Political contributions in B.C. can only be made by individual persons resident in the province who are Canadian citizens or permanent residents. No contributions can be made by a corporation or other organization. This prohibition includes non-cash contributions, like free or discounted goods, services or use of facilities.

For individuals eligible to make contributions, the amount of such contributions is limited to C$1,513.29. In other words, eligible individuals are allowed to contribute up to this amount to each registered political party. An individual’s contribution record will generally be made publicly available; anonymous contributions are limited to C$50 or less.

2. Spending on “Election Advertising” Is Capped and Must Be Disclosed

Certain types of advertising that take place during the campaign period are subject to regulation. This campaign period election advertising covers the transmission of advertising messages to the public that promote or oppose a registered political party or candidate. All means of transmission are captured by this definition, and the definition applies regardless of whether the promotion or opposition is direct or indirect. Furthermore, advertising that promotes a stance on a certain issue that is connected to a candidate or political party also counts as election advertising.

If an individual or organization sponsors campaign-period election advertising, they will need to register with Elections BC. Importantly, this registration must be done prior to when the actual election advertising takes place. Unless specific requirements are met, registration is generally not required if you are not paying to publish, broadcast or transmit election communications. In this context, being a sponsor of election advertising means (i) being the individual or organization paying for the advertising, (ii) being the individual or organization receiving free advertising, or (iii) being the individual or organization that is having one of the two previous activities done on your behalf. In general, individuals or organizations are able to register as long as they are independent from registered political parties, registered constituency associations, candidates, and certain types of official and financial agents.

Once registered, advertising limits apply. Specifically, during a campaign period, spending must not exceed C$3,000 for a single electoral district and must not exceed C$150,000 for the entire province.

Don’t Accidentally Become a “Foreign Agent”

The B.C. election will also be an early test of Canada’s new foreign influence regime. Canada’s Foreign Influence Transparency and Accountability Act (FITAA) came into effect in August 2026. As set out in our earlier bulletin, FITAA is extremely broad and often subjective.

Registration is required under this regime when entering into an “arrangement” with a “foreign principal” to engage in “influence activities” related to a “political or governmental process.”

The terms are defined very broadly. The “arrangement” need not be paid or formalized — it includes any work done under the direction of or in association with a “foreign principal.” A “foreign principal” includes almost any person or entity controlled by, or associated with, a foreign state or government. The relevant “influence activities” are (i) communicating with a public office holder, (ii) communicating or disseminating information, (iii) distributing money, and (iv) providing a good or service, in each case to the extent related to a “political or governmental process.” A “political or governmental process” includes holding of an election, development of electoral platforms, candidate nominations and policy development.

Accordingly, businesses that work with foreign governments, state-owned enterprises, sovereign wealth funds, state-run media, government investment vehicles, state-backed financial institutions and other potential “foreign principals” should consider whether any engagement in the election would require registration under the foreign influence regime.

Consider the Consequences

While failure to comply with the ethical obligations and reporting requirements under the LTA can result in lobbying bans and monetary penalties, contravention of certain sections of the FITAA is considered an offence and can result in fines up to C$5-million or imprisonment. Furthermore, the B.C. Election Act includes monetary penalties that can apply to those sponsoring election advertising, as well as a number of separate offences.

Beyond these legal consequences, businesses face significant reputational risk from non-compliance, or the appearance of non-compliance. Journalists and other public actors may view intense lobbying of candidates, providing gifts or hospitality, or making contributions to candidates as an attempt to circumvent registration requirements or exploit “loopholes” in lobbying legislation. An adverse finding by the Foreign Influence Commissioner could see you deemed a “foreign agent” attempting to interfere in the election.

Conclusion

Despite the hectic pace of a snap election, businesses and stakeholders must proceed with care. Lobbying rules govern registration, gift giving and contributions, and election financing laws regulate political contributions and advertising. Canada’s new foreign influence regime presents another layer of compliance. A provincial election presents a valuable opportunity for stakeholder engagement, but only for those who understand and follow the rules.

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