Ontario Government Proposes Raising Contribution Limits and Changing Election Dates

On October 27,  Attorney General Doug Downey announced comprehensive proposals to change Ontario’s dates of elections, increase its political contribution limits, eliminate pre-writ spending limits for third parties, and alter other provincial campaign finance laws.

The reforms, announced in a news release by the government of Ontario, would eliminate “American-style fixed election dates” in favor of provincial elections taking place on a date determined by the lieutenant governor on the advice of the premier, but within the five-year maximum limit mandated by the province’s constitution.

Beginning in 2026, individuals’ contribution limits to a political party would be raised from $3,400 to $5,000. Future increases would be indexed to the rate of inflation.

In addition to eliminating third party and political party pre-writ spending limits, the government proposes establishing new financial penalties for those not in compliance with the Election Finances Act.

The amendments to the law would also provide new investigative powers to the Chief Electoral Officer to request information from third parties to ensure they are in compliance with political advertising rules. The proposed changes to the law also include requiring third parties to provide proof of registration status to broadcasters and publishers before placing political advertisements during an election period. 

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On October 3, Federal Election Commission (FEC) Commissioner James E. “Trey” Trainor III plans to officially resign from his position.

The FEC will then have only two commissioners, Shana M. Broussard and Dara Lindenbaum, both members of the Democratic Party. The FEC requires at least four commissioners to agree on any official action. No more than three commissioners can be from the same party. As it stands, because all decisions must have four commissioners’ vote, no official action can be made by the FEC until the president nominates and the Senate confirms another two commissioners.

According to the Washington Examiner, Trainor is considering a run for the U.S. House of Representatives seat being vacated by Rep. Chip Roy, who has entered the Texas republican party primary to run for attorney general.

While Commissioner Broussard will continue to serve as Chair of the Commission for the remainder of 2025, Trainor’s resignation also means the position as Vice-Chairman will be vacant unless filled by the remaining commissioner, Lindenbaum.

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FEDERAL: On August 28, President Donald J. Trump signed a Presidential Memorandum directing U.S. Attorney General Pam Bondi to investigate whether federal grant funds are being illegally used to support lobbying activities.

The directive requires the Attorney General to report to the president within 180 days on the progress of her investigation.

According to the memorandum, the president states the impetus for this action is because “federal funding reviews by my Administration have revealed that taxpayer funds are being spent on grants with highly political overtones.” 

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On September 2, the Federal Election Commission (FEC) will release version 8.5 of its FECFile electronic filing software.

This update applies whether a committee uses FECFile or a third-party commercial product. Both will require an update to the software for filings on or after September 2.

Changes of electronic filing specifications required with the software update include the following: filers will be required to provide the FEC with the committee name, committee identification, and committee type when listing joint fundraising participants on form 1 or form 1-S; when filing a form 99 , committees will be required to categorize their submission; if a committee selects filing frequency change notice or form 3-L filing frequency change notice on a form 99, they will be required to denote whether their new filing frequency is monthly or quarterly; and when filing a loan agreement/loan forgiveness on a form 99, committees will now have the option to attach a pdf file of up to 150 pages.

On July 29, companion bills were introduced in both houses of the U.S. Congress to curtail corporate political action committee (PAC) activity in elections.

Senate Bill 2515 and House Bill 4799, entitled the Ban Corporate PACs Act, would amend the Federal Election Campaign Act of 1971 to eliminate the ability of for-profit corporations to establish and manage a PACs. The bills would also eliminate the ability of for-profit corporations or PACs to solicit contributions from corporate stockholders.

Additionally, the legislation would require existing certain corporate PACs, if no longer permitted to be established under this new law, to be terminated and its funds to be fully disbursed within one year after enactment of the Act.

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On August 12, by-elections will be held for District 9 (Charlottetown-Hillsborough Park) and District 15 (Brackley-Hunter RiverPark) for the Legislative Assembly of Prince Edward Island.

In District 9, the by-election was called because of the resignation of MLA Natalie Jameson, who resigned on February 11. Jameson will be the Conservative Party of Canada’s candidate for Charlottetown in the next federal election.

In District 15, the by-election was called because of the resignation of Premier Dennis King, who resigned on February 21. King has indicated he no longer wished to remain in politics.

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On July 14, legislation was introduced in the Council of the District of Columbia addressing campaign finance rules, including the use of artificial intelligence (AI) in campaign finance advertising.

Bill B26-0329, the Campaign Finance Modernization Amendment Act of 2025, would require a disclaimer on an advertisement containing an image, audio, or video that has been manipulated or altered by AI, and would prohibit the distribution of a deepfake within 90 days of an election.

The bill also enacts legislation requiring additional reporting from committees not currently required to submit more than two reports a year and prohibits the Office of Campaign Finance from accepting a report that omits certain legally required information. Other changes in the legislation include amending the definition of “coordinate” or “coordination” to capture conduct from other political committees, political action committees, and independent expenditure committees that are not affiliated with a public official; providing the Office of Campaign Finance a specified timeline to conduct an investigation on a complaint; and establishing an advisory group consisting of current and former campaign treasurers, campaign finance experts, and donation platforms to meet at least four times a year to consult on potential process improvements for the campaign finance system and the Fair Elections Program.

It would also prohibit a candidate who was expelled from the council from being certified under the Fair Elections Program.

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Beginning January 19, 2026, the Canadian federal lobbyist registration threshold for organizations and corporations will be lowered. On July 16, the Office of the Commissioner of Lobbying of Canada issued new interpretation bulletins concerning the “significant part of the duties” threshold for when organizations and corporations must be registered under the Lobbying Act.

One bulletin lowers the lobbyist registration threshold from the current 32 hours per month to 8 hours in a rolling four-week period.

A second updated interpretation addresses the Lobbying Act’s revolving door provision and interprets a significant part of a designated public office holder’s work as 8 hours or more in any given consecutive four-week period. This would include any time spent preparing for and participating in oral communications with public office holders as well as drafting written communications to public office holders.

An additional bulletin addressing the transitional period for former designated public office holders employed by corporations was also issued.

The commissioner believes these interpretations are consistent with the Lobbying Act.

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Beginning on July 14, a new federal procurement policy regarding foreign vendors took effect.

The new policy requires all new non-defense procurements over $10,000 involving an open competition by or on behalf of any federal department or agency of Canada by a foreign supplier be limited to whether the solicitation is subject to a trade agreement between Canada and the supplier’s jurisdiction. If a supplier is from a jurisdiction that does not have a trade agreement with Canada and applies to a procurement process, it will no longer be eligible to compete, with limited exceptions. Canadian suppliers will continue to be eligible to compete for all federal procurement opportunities.

The Treasury Board of Canada Secretariat issued a Contracting Policy Notice on July 10 regarding the policy, entitled the Interim Policy on Reciprocal Procurement, for all departments and agencies that have delegated authority for procurement from the Minister responsible for Public Services and Procurement Canada.

Contracts and solicitations posted prior to July 14 are not subject to this new rule

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On August 11, a by-election will be held in the electoral division of Arthabaska, in the Centre-du-Québec region, for a seat in the province’s National Assembly of Quebec. MNA Éric Lefebvre had resigned on March 18 to run with the Conservative Party of Canada for the federal riding of Richmond-Arthabaska (Quebec) for a seat in the Canadian House of Commons.

Under a decree issued by the Government of Québec on July 8, the Chief Electoral Officer, Mr. Jean-François Blanchet, will oversee the organization of the election. Advance polling for voting will begin on August 3.

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On June 30, Canada’s Prime Minister Mark Carney announced a federal by-election will be held on August 18 for the electoral district of Battle River-Crowfoot in Alberta.

Earlier this month, the Chief Electoral Officer of Canada, Stéphane Perrault, had received official notice from the Speaker of the House of Commons that the seat was vacant. MP Damien Kurek had resigned in order to allow Pierre Poilievre to run for his place in the House of Commons.

Perrault’s announcement of the vacancy, made on June 18, signaled the start of the election period.

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The U.S. Department of Justice (DOJ) has issued guidelines for the investigations and enforcement of the Foreign Corrupt Practices Act (FCPA).

These guidelines were issued because of an Executive Order issued by President Donald J. Trump on February 10, which stated, “FCPA enforcement impedes the United States’ foreign policy objectives and therefore implicates the President’s Article II authority over foreign affairs.” The order required a review by the U.S. Attorney General of current FCPA guidelines and policies, with new guidelines and policies issued if the Attorney General saw fit.

The guidelines mandate prosecutors focus on cases in which individuals have engaged in criminal misconduct and not attribute nonspecific malfeasance to corporate structures; proceed as expeditiously as possible in their investigations; and consider collateral consequences, such as the potential disruption to lawful business and the impact on a company’s employees, throughout an investigation, not only at the resolution phase.

The four-page guidelines go on to list some factors prosecutors must take into account, including prosecuting activities linked to cartels and transnational criminal organizations; considering whether “the alleged misconduct [of bribery] deprived specific and identifiable U.S. entities of fair access to compete and/or resulted in economic injury to specific and identifiable American companies or individuals;” and focusing “on the most urgent threats to U.S. national security resulting from the bribery of corrupt foreign officials involving key infrastructure or assets.”

The DOJ states that the guidelines govern all current and future investigations and enforcement actions of the FPCA.

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Commissioner of Lobbying Nancy Bélanger has submitted to the Parliament of Canada her annual report for 2024-25. The report highlights the Office of the Commissioner of Lobbying’s ongoing efforts to support transparency in lobbying at the federal level in Canada.

The report details information about lobbying registration and compliance activities. Additionally, the commissioner repeats her intention to issue a new interpretation in 2025 with respect to the registration threshold by employees of organizations and corporations. A new interpretation will also be issued regarding the five-year restriction on lobbying for individuals ceasing to be designated public office holders.

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The Vermont General Assembly adjourned sine die on Monday, June 16. During the session, lawmakers passed bills amending campaign finance laws, including modifying the definition of independent expenditure only committees and requiring the disclosure of distributed deceptive and fraudulent synthetic media depicting a candidate on the ballot. If not vetoed by the governor, the bills take effect immediately.

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