FITAA Analysis: Self-Assessment Tool

Are you involved in a political or governmental process?

The Act only applies if you're involved in a Canadian political or governmental process. Let's determine if your activities relate to such a process.

§FITAA, Section 2: definition of "political or governmental process"

Are your activities related to any of the following?

Legislative proceedings or proposalsParliament, provincial legislatures, city councils, or development of legislative proposals at any level Development or amendment of ANY policy or programFederal, provincial, municipal, or Indigenous government policies or programs on ANY topic (healthcare, education, environment, transit, etc.) Decisions by public office holdersDecisions by ministers, MPs, MPPs, councillors, or public officials including contract awards, appointments, or other governmental decisions Elections, referendums, or candidate nominationsFederal, provincial, municipal, or Indigenous elections, candidate selection, or platform development None of the above

"Political or governmental process" is extremely broad

FITAA, Section 2 defines this to include virtually ANY government activity at ANY level:

"Development or amendment of ANY policy or program", no matter how small
Federal, provincial, territorial, municipal, AND Indigenous processes
Everything from bike lane advocacy to healthcare policy to school board decisions

Examples that may count as "political or governmental processes"

Advocating for bike lanes at city council
Writing about federal immigration policy
Attending a school board meeting
Discussing provincial healthcare funding
Commenting on municipal zoning decisions

Which level or levels of government?

The Act applies to political or governmental processes at ALL levels of government in Canada.

§FITAA, Section 4

Which level(s) of government does your involvement relate to? (Check all that apply)

FederalParliament, federal agencies, federal ministers and officials, federal programs and policies Provincial/TerritorialProvincial legislatures, provincial ministries, provincial programs (healthcare, education, etc.) MunicipalCity councils, mayors, local officials, municipal services and policies Indigenous Government or EntityFirst Nations, Inuit, or Métis councils, governments, or representative organizations

The Act captures all levels

FITAA applies to federal, provincial, territorial, municipal, AND Indigenous political or governmental processes.

This means: Attending a city council meeting, advocating to your school board, or engaging with your MPP can all trigger registration requirements if you have a foreign connection.

What are you doing in relation to this process?

The Act defines an "arrangement" to include specific types of activities. Let's see if what you're doing qualifies.

§FITAA, Section 2: definition of "arrangement"

Are you undertaking any of the following activities?

Communicating with a public office holderMeeting with, emailing, calling, or otherwise contacting MPs, MPPs, city councillors, ministerial staff, or public servants at any level Communicating or disseminating informationPosting on social media, writing articles, giving presentations, organizing events, or distributing materials about the political/governmental process Distributing money, items of value, services, or use of facilitiesProviding grants, hosting events, offering services or goods, or making facilities available in relation to the political/governmental process None of the above

These categories capture most civic participation

Notice how broad these are:

"Communicating" includes everything from emails to social media posts
"Disseminating information" covers virtually all public discourse
"Distributing" captures community events and organizing activities

Is there a "foreign principal"?

This is the most critical (and problematic) part. The Act requires registration if you're acting "under the direction of OR in association with" a foreign principal.

§FITAA, Section 2: "foreign principal" (references Security of Information Act definitions)

Are you doing your activities "under the direction of OR in association with" any of the following?

A foreign government or state agencyAny government department, ministry, agency, or official entity of another country (including close allies like US, UK, France, etc.) A foreign political partyPolitical parties or movements in other countries A foreign company or businessCompanies, corporations, or business entities based in or controlled by another country (including international companies) A foreign organizationCultural organizations, professional associations, academic institutions, foundations, or NGOs based in or connected to another country An international organization with state membersOrganizations like Organisation internationale de la Francophonie, UNESCO, etc. Any entity directed or substantially controlled by a foreign stateState-owned enterprises, entities with government funding or control None of the above / Not sure

"In association with" is undefined and may be extremely broad

FITAA never defines what "in association with" means. It could potentially include:

Financial connections: Having received funding, grants, or sponsorship (even years ago, even if small amounts)
Organizational membership: Being part of an organization that has foreign ties
Past attendance: Having attended conferences, workshops, or events in another country
Professional relationships: Working with, consulting for, or collaborating with foreign entities
Cultural/ethnic ties: Maintaining cultural connections to your country of heritage
Shared viewpoints: Advocating for policies that happen to align with positions of foreign states

No proof of coordination, direction, or even communication required.

Real-world examples of potential "association"

Your community organization once received a $500 cultural grant from an Irish foundation
You attended a conference on sustainable cities in Stockholm
You volunteer with an organization that has ties to a French cultural agency
You advocate for bike lanes (a policy Norway promotes) and have Norwegian heritage

Do any exemptions apply?

The Act provides limited exemptions. Let's see if any apply to you.

§FITAA, Section 6 (Non-application)

Do any of these situations apply to you?

I am a foreign diplomat with valid diplomatic acceptanceYou hold a passport with valid diplomatic, consular, official or special representative acceptance issued by Canada's Chief of Protocol I am an employee of a foreign principal acting openly in my official capacityYou work directly for a foreign government/entity and are acting transparently in that role This arrangement is with His Majesty in right of CanadaThe Canadian government is a party to the arrangement (government-to-government) None of these apply to me

Very limited exemptions

Notice what is NOT exempted:

Parliamentarians
Academic researchers
Human rights advocates, journalists and media organizations
Cultural workers and artists
Business consultants
Community organizations
Individual citizens with international connections

Most legitimate civil society activities are NOT exempt.