Advocating for Institutional Change in Canada

Introduction

Women’s rights organizations that participated in regional discussion groups as part of CRIAW-ICREF’s “Countering the Rise of Anti-Feminism” project voiced the need for practical guides for feminists to engage on the ground, strengthen feminist movements, and push for institutional reform. This third action guide in the series focuses on lobbying as a mechanism for institutional change in Canada.  

The “Countering the Rise of Anti-Feminism”project used Feminist Participatory Action Research (FPAR) methods to prioritize feminist organizations’ input when co-creating solutions. Participants identified key concerns regarding the impact of regressive and anti-feminist movements on governments and institutions:

• Women’s rights organizations can be reluctant to speak out against anti-feminist policies and practices for fear of backlash and a withdrawal of funding.
• Funding scarcity can precipitate competition and individualism in organizations, rather than feminist collectivism and solidarity.
• Participating organizations identified the need for best practices for leveraging institutional mechanisms and sharing resources to promote institutional change.

It is important to understand the neoliberal context that informs the actions and tools that are available to not-for-profit feminist organizations. Regional discussion group participants identified the depoliticization of the feminist movement under neoliberalism as a key barrier to women’s rights and gender equality. In order to comply with legal requirements, not-for-profit organizations must adhere to guidelines for lobbying and practices established within a neoliberal system. Neoliberal practices encourage depoliticized service delivery and nonpartisan approaches to social issues, forcing not-for-profit organizations to move away from research and political advocacy to a service delivery model that measures ‘practical’ outcomes, such as the number of clients accessing services.¹

However, the ability to influence government policies, agendas and secure adequate funding remain fundamental goals for women’s rights organizations. This guide attempts to demystify government policy jargon regarding lobbying and provides comprehensive resources on lobbying from other progressive organizations. In divisive moments, such as in the aftermath of a close election, progressive movements have more opportunity to influence the government, and practical and accessible tools for organizing and lobbying are essential.

Overall Landscape

Lobbying in Canada is regulated under federal, provincial and municipal law; each jurisdiction has its own legislation, registration requirements and exemptions. Lobbying is most thoroughly regulated at the federal level by the Lobbying Act (1985). The Lobbying Act does not include an official definition of lobbying, but describes it in sections 5(1) and 7(1) as: 

“Communicating with public office holders, for payment with regard to: 

• The making, developing or amending of federal legislative proposals, bills or resolutions, regulations, policies or programs; 
• the awarding of federal grants, contributions or other financial benefits; and
• the awarding of a federal government contract (for consultant lobbyists only).”

IntegralOrg provides a summary of lobbying legislation by province, as well as information on different registration thresholds for non-profits and charities. 

The federal Lobbying Act focuses on transparency and regulation to maintain free and open access to the government and hold the government accountable to the public. The public registry of lobbyists and the requirement for non-profit organizations to file information returns also provide transparency for governments to monitor the actions of non-profits more closely and provide public records regarding who is lobbying the government and why.

Laws and Regulations

The Lobbying Act and Income Tax Act are the primary acts to keep in mind for non-profit feminist organizations advocating for institutional change. The following section identifies key components from each act and how they inform the practices of non-profit organizations.   

Lobbying Act

The Federal Lobbying Act describes lobbying as any communication with government officials, for payment, to change or oppose a policy or decision. It is important to note the monetary requirement in this definition of lobbying.

The legislation applies to two types of lobbyists:

• Consultant Lobbyists – those who are being paid to lobby on behalf of an organization.

and

• In-House Lobbyists – individuals who lobby for an organization where they are employed, or where a “significant part of the duties” includes lobbying (section 7(1)).

Therefore, if a non-profit organization is managed primarily with volunteers, lobbying requirements may not apply.

The Office of the Commissioner of Lobbying (OCL) oversees organizations and lobbyists for compliance with the Act. If an organization meets the threshold for lobbying, they must register their activities with the public registry.

The OCL released a notice in July 2025 that updates the federal guidelines for registration for In-House Lobbyists. These guidelines came into effect on January 19, 2026.

These requirements are key to the registration process for non-profit organizations.

The purpose of these new guidelines is to help the Lobbying Commissioner interpret the meaning of the federal Lobbying Act section 7(1) that refers to a “significant part of the duties.”

Previously, if 20% of an organization’s duties (or 32 hours per month) involved lobbying, it must register. New guidelines lower the threshold so organizations must register if they collectively spend eight hours (including the time spent preparing and communicating with public office holders) in four consecutive weeks on lobbying.

It is important to note that this applies to the hours of all employees in an organization. For example, if an employee spends  two hours writing a letter to a government official and another employee spends one hour editing, this counts as three hours of lobbying activity. Similarly, if eight  employees attend a one-hour meeting related to lobbying, that counts as eight  hours of lobbying activity.

Because they meet the threshold specified in the Lobbying Act under the new guidelines, many more non-profit and civil society organizations that engage in policy advocacy are required to register as lobbyists and dedicate more time to tracking activities related to lobbying.

Grassroots Lobbying

The new guidelines also reassert grassroots advocacy as a form of indirect lobbying. For example, if a grassroots or non-profit organization pays its workers to communicate with government officials on creating, changing or revising a bill or policy, it is considered lobbying and is subject to the rules in the Lobbying Act. According to the Office of the Integrity Commissioner of Ontario, Grass-roots advocacy can include:

1. reaching out to the public through ads, websites, or social media,
2. Asking members of the public to communicate with government, and
3. Activities that place pressure on the government on an issue

Some examples of activities that may constitute lobbying include: writing and publishing articles, making appeals to the public, signing onto or writing letters, holding meetings with public office holders, and creating social media posts for the purpose of influencing, changing, or creating a policy. This includes not only the materials produced but the time required to produce them. For example, an organization is now required to include and track lobbying hours for publishing a research paper and include not only the hours of research, but also the time taken to write and edit the report.  

Paid board members who engage in lobbying activities are required to register as Consultant Lobbyists. The rules do not apply to unpaid and volunteer board members.

Income Tax Act

The Income Tax Act is governed by the Canada Revenue Agency (CRA) and outlines rules and regulations for Canadian charities and non-profits, including the terms for conferring and retaining charitable status, and the ways in which charitable organizations allocate financial and human resources. Charities are registered with the CRA, allowing the agency to regulate the sector.

The CRA organizes status for organizations that operate exclusively for charitable purposes into four categories:

• Poverty Relief
• Advancing Education
• Advancing Religion
• Other Purposes Beneficial to the Community

An organization that wishes to be registered for charitable status must:

1. Operate exclusively for charitable purposes, and
2. Devote its resources to charitable activities that further those purposes.

Non-profits are defined as associations, clubs or societies that do not generate profit, and operate for various purposes including social welfare, civic improvement, pleasure, or recreation. For example, amateur hockey leagues, parade organizations, and curling clubs can all be non-profits.      

While all charities are non-profits, not all non-profits are charities.

Canadian charities cannotengage in partisan activity, defined as the direct or indirect support of, or opposition to, a political party or candidate. Non-profits can participate in partisan activity, under certain conditions.

The National Association of Women and the Law (NAWL)’s Federal Election Planning Toolkit provides a comprehensive overview of what constitutes partisan activity, including indirect partisan activity which can be more difficult to identify.

Amendments to the Income Tax Act in 2018 allow charities to engage in Public Policy Dialogue and Development Activities (PPDDA) that further charitable purposes. Therefore, a charity can advocate for changing or opposing government laws, policies and decisions if it furthers its charitable purpose, but cannot directly or indirectly support a specific political party or candidate. 

There are no limits on the amount of PPDDAs a charity can take part in, with the provision that these activities further the charity’s stated purpose.

The CRA considers the following as PPDDAs:

• Providing information about public policies to supporters or the general public
• Conducting research on public policy
• Disseminating opinions on public policy
• Advocacy
• Mobilizing
• Verbal or written representations
• Hosting forums
• Convening discussions
• Social media communications

Charitable status is important to many non-profits because it enables organizations to secure additional government funding, facilitate partnerships with other organizations, provide legitimacy for an organization’s purposes and actions, and provide tax receipts that encourage donations.² 

Charity and Lobbying Registration Remains Controversial. 

There is ongoing debate among feminist organizations about whether charitable status and registration impose limitations that can hamper advocacy work for institutional change. For some women’s rights organizations, political advocacy is considered part of their basic and everyday work, as they see advocating for change and challenging the status quo as their central mission. Charity registration remains controversial as it may impose limitations to the core work of organizations.

Non-profit lobbying also differs from lobbying for profit, where corporations may attempt to influence governments to enact or amend policies for their financial interests and gain. Some organizations question whether advocating for human rights should count as lobbying and require registration as it is not about generating profit or amending policies for personal gain.

Charity status may also encourage quiet diplomacy, in which private negotiations and backroom advocacy with government bureaucrats constitute the majority of political advocacy or lobbying.³ For example, some direct lobbying practices are not considered political activity under the Income Tax Act, so long as the organization lobbies the government directly, without involving the public.

As a result, private lobbying practices, while still important, can prevent organizations from providing information to the public about the nature of their advocacy work; this effectively relegates non-profit organizations exclusively to the service sector, leaving no room for mobilization or impacting public opinion.

As a result, private lobbying practices, while still important, can take away from the public nature of advocacy work, and reinforce the location of non-profit organizations primarily within the service sector, leaving little room for mobilization or impacting public opinion.

Lobbying for institutional change

The following resources provide a comprehensive overview for feminist and progressive organizations to consider in their advocacy:

Other Legislation to Keep in Mind for Institutional Advocacy