Gerry Chipeur, Aman Shah and Ashley Hamza write an article for Law360, entitled “New interpretation bulletins issued by Canada’s lobbying commissioner are unconstitutional”.
Both are stated to have affect as of Jan. 19, 2026. The first bulletin dramatically lowers the registration threshold for in-house lobbyists, and the second changes the interpretation of conditions for exemption from the five-year prohibition on lobbying that applies to a former designated public office holder (DPOH). While the commissioner frames the new bulletins as guidance, they raise serious questions about statutory authority, administrative overreach, and the role of Parliament in making federal law.
