FITAA Analysis: Am I a Foreign Agent?
Do I need to register under the Foreign Influence Transparency and Accountability Act as a foreign agent? Use this tool to find out.
FITAA Analysis: Self-Assessment Tool
Do I need to register as a foreign agent under Canada’s Foreign Influence Transparency and Accountability Act (FITAA) once the Registry is established? Use this tool to find out. Remember that this tool is for educational purposes only and cannot be construed as legal advice. No information is collected by this tool. This project is a joint collaboration between Courtready.ca and Canadians United Against Modern Exclusion (CUAME).
Step 1: 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 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
• 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
Step 2: Which Level(s) of Government?
The Act applies to political or governmental processes at ALL levels of government in Canada.
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.
Step 3: 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.
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
Step 4: 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 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.
• 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
Step 5: Do Any Exemptions Apply?
The Act provides limited exemptions. Let’s see if any apply to you.
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.
⚖️ Important Disclaimer
This tool is for public education and civic discourse purposes only and does not constitute legal advice.
The Foreign Influence Transparency and Accountability Act (FITAA) contains vague and undefined terms that create legal uncertainty. The interpretation and application of this Act is subject to enforcement decisions by the Commissioner and potential judicial review.
If you believe this Act may apply to your situation, you should consult with a qualified lawyer. This self-assessment tool is designed to educate you about the Act’s provisions and potential implications, but it cannot provide legal advice specific to your circumstances.
Have Your Say:
If you have an opinion or feedback about FITAA or the proposed regulations, you have two options: 1. Email Canadians United Against Modern Exclusion and share your thoughts, or 2. Respond to the Government’s 30-day consultation no later than February 2, 2026, at 11:59 PM EST.
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