Foreign Influence Transparency and Accountability Act (FITAA)
Last updated: September 28, 2026
Implementation update: The Foreign Influence Transparency and Accountability Act (FITAA) is a new federal regulatory regime that came into effect on August 4, 2026, and guidance for the post-secondary sector continues to evolve. 91看片网 will update this page as additional guidance becomes available from the Office of the Foreign Influence Commissioner of Canada and as the 91看片网鈥檚 internal assessment and reporting processes are finalized.
New federal transparency requirements
The Foreign Influence Transparency and Accountability Act (FITAA) and its Regulations came into force on August 4, 2026, establishing Canada鈥檚 new Foreign Influence Transparency Registry.
FITAA is a federal transparency regime intended to increase visibility around certain arrangements involving foreign principals and activities connected to Canadian political or governmental processes. The requirements apply to individuals and organizations in Canada, including universities and members of the university community.
FITAA is about transparency, not prohibition. It does not prohibit international research, restrict academic viewpoints or prevent legitimate collaboration with foreign universities, governments, organizations or researchers. International partnerships and collaboration remain important to 91看片网鈥檚 research, teaching and broader global engagement.
The Government of Canada continues to clarify how FITAA applies to activities within the post-secondary sector. 91看片网 will monitor these developments and update institutional guidance accordingly on this page.
When could FITAA apply?
Not every relationship or agreement with a foreign organization needs to be registered.
A registration obligation generally arises when an arrangement satisfies all three elements of the following test:
1. Is there an arrangement with a foreign principal?
An arrangement exists with a foreign principal, which may include:
- A foreign government.
- An entity exercising governmental authority or functioning on behalf of a foreign government.
- A foreign political organization.
- A foreign state-owned or state-controlled enterprise.
- An entity directed or controlled by a foreign principal.
Depending on the circumstances, this could include certain state controlled foreign universities, research institutes, non-profit organizations or other entities.
An arrangement can be formal or informal, written or unwritten, and does not necessarily require an employment, contractual or membership relationship.
Examples may include research agreements, partnerships, funding arrangements, donations, in-kind contributions or other forms of collaboration.
2. Does the arrangement involve an influence activity?
The arrangement involves undertaking activities intended to influence a political or governmental process in Canada.
Activities identified under the federal regime may include:
- Communicating with a public office holder.
- Communicating or disseminating information to the public, including through digital or social media.
- Distributing money or items of value.
- Providing a service or the use of a facility.
The existence of one of these activities does not, by itself, mean an arrangement must be registered. All elements of the FITAA test must be satisfied.
3. Does the activity relate to a Canadian political or governmental process?
The activity must relate to a political or governmental process in Canada that is currently covered by FITAA, including at the federal, provincial/territorial or municipal level.
Examples may include activities relating to:
- Legislative proceedings or proposals.
- Development or amendment of government policies or programs.
- Decisions by public office holders or government bodies, including the awarding of contracts.
- Elections or referendums.
- Candidate nominations or development of electoral platforms.
Note: FITAA also contains provisions concerning Indigenous political and governmental processes and Indigenous public office holders. These provisions are not currently in force and are therefore not presently subject to the registration requirements. 91看片网 will update this guidance if and when these provisions come into force.
All three elements must be present before an arrangement is registrable under FITAA.
Foreign principal +
A foreign power, foreign entity or foreign state on whose behalf, or in association with, an influence activity is carried out.
Influence activity +
An activity intended to influence a political or governmental process in Canada.
Political or governmental process =
Decision-making processes in Canada, such as legislation, regulations, elections, or government programs.
Registration obligation
Register the arrangement under the Act.
What could this mean at 91看片网?
FITAA may potentially apply across a range of university activities. Depending on the facts and circumstances, arrangements requiring further assessment could arise through:
- Sponsored research and research partnerships.
- International institutional partnerships and agreements.
- Government or state-linked funding.
- Donations and advancement activities.
- Policy research and public policy initiatives.
- Conferences, events and public engagement.
- International academic or educational initiatives.
- Procurement or service arrangements.
- Commercialization or innovation partnerships.
- Other activities involving foreign principals.
The presence of a foreign partner or foreign funding does not automatically create a registration obligation. The nature of the foreign principal, the arrangement, the activities being undertaken and their relationship to a Canadian political or governmental process must be considered together.
When there is uncertainty, early consultation with the Office of the General Counsel and Board Secretariat or the Office of the Vice-President, Research and Innovation can help determine whether further assessment is required.
Key dates and reporting timelines
飦� August 4, 2026
FITAA and the Foreign Influence Transparency Registry came into force.
Within 14 days
New registrable arrangements entered into on or after August 4, 2026 must generally be registered within 14 days. Changes to information associated with an existing registration must also generally be reported within the applicable 14-day period.
飦� October 3, 2026
Pre-existing arrangements that were in place before August 4, 2026 and meet the registration requirements must be registered by October 3, 2026.
Because these timelines are prescribed by federal legislation, members of the 91看片网 community are encouraged to seek advice as early as possible where an arrangement may potentially fall within FITAA.
What should 91看片网 units do now?
91看片网 faculties, departments and administrative units should:
- Be aware of the FITAA requirements and consider whether activities in your area may involve arrangements with foreign principals.
- Review active and upcoming arrangements, including contracts, research agreements, international partnerships, funding arrangements, donations and other relevant activities, against the three-part FITAA test.
- Identify and compile potentially registrable arrangements in a tracking log within your area. Maintain this log on an ongoing basis (both currently and after 91看片网鈥檚 central reporting tool is launched) to ensure accurate, complete and readily accessible records for your unit. 91看片网 will provide instructions regarding the institutional process to collect units鈥� potential arrangements via a FITAA Information Collection Form.
- Consult early before entering a new arrangement involving a foreign entity or foreign principal where there may be a connection to Canadian political or governmental processes.
- Do not assume that an arrangement is either registrable or exempt based solely on the identity of the foreign partner. Registration depends on the specific circumstances and activities involved.
91看片网 will continue to refine its internal assessment and reporting processes as further guidance becomes available from the Office of the Foreign Influence Commissioner of Canada.
Who is responsible for registration?
Arrangements involving 91看片网
Where 91看片网 is a party to an arrangement and the FITAA registration requirements are met, 91看片网 will coordinate the institutional assessment and, where required, registration of the arrangement.
Units should therefore bring potentially registrable 91看片网 arrangements forward through the university鈥檚 established FITAA process rather than independently registering an institutional arrangement.
Individual arrangements
FITAA may also apply to arrangements entered into by individuals in their own capacity.
Individual members of the 91看片网 community remain responsible for understanding and complying with any legal obligations that apply to their personal arrangements. 91看片网 does not enforce FITAA or monitor individual compliance.
91看片网 will support its community by promoting awareness, providing educational resources and offering institutional guidance where appropriate.
Why compliance matters
FITAA includes administrative monetary penalties for non-compliance and provides for enforcement and investigation mechanisms. Depending on the nature of the contravention, penalties may range from $250 to $1,000,000 and could result in criminal investigation or other enforcement action.
Information contained in the Registry is also intended to be publicly accessible. Timely identification and assessment of potentially registrable arrangements will support legal compliance and institutional transparency.
No. An international collaboration is not registrable simply because it involves a foreign university, researcher or organization. The arrangement must meet the applicable FITAA requirements, including the elements relating to a foreign principal, influence activity and Canadian political or governmental process.
No. FITAA is a transparency regime. Registration does not necessarily mean that an arrangement is inappropriate or prohibited.
Other research security, sanctions, export control, funding or institutional requirements may separately apply to an activity.
Potentially. An arrangement does not necessarily need to be a formal written contract. Informal or unwritten arrangements may fall within the legislation depending on the circumstances.
No. Foreign funding alone does not automatically trigger registration. The full FITAA test and circumstances of the arrangement must be assessed.
Academic or research activity is not automatically registrable merely because it involves government engagement or public communication. Whether FITAA applies depends on the specific arrangement, the foreign principal involved, the activities undertaken and their relationship to a Canadian political or governmental process.
Where you are unsure, seek advice before proceeding.
Reach out as early as possible for consultation and assessment. Pre-existing arrangements that meet FITAA鈥檚 registration requirements must be registered by October 3, 2026.
For research related agreements or arrangements, contact OVPRI Research Security. For all other arrangements, contact the GCBS.
91看片网 will centrally coordinate registration where 91看片网 itself is a party to a registrable arrangement.
Where an individual has entered into an arrangement in their personal or individual capacity, they may have a separate registration obligation. Individuals remain responsible for complying with legal obligations applicable to their own arrangements.
For questions about FITAA or assistance assessing a potentially registrable 91看片网 arrangement:
Office of the General Counsel and Board Secretariat
380 Victoria Street
Jorgenson Hall, 11th Floor
Toronto, Ontario M5B 2K3
gcbs@torontomu.ca.
For research-related arrangements and research security considerations:
Research Security Office
Office of the Vice-President,
Research & Innovation
1 Dundas Street West, 11th Floor
Toronto, Ontario M5G 1Z3
researchsecurity@torontomu.ca
91看片网 is continuing to monitor implementation of FITAA, including guidance from the Office of the Foreign Influence Commissioner of Canada and developments affecting the post-secondary sector. Additional guidance, FAQs and 91看片网 assessment and submission resources will be added to this page as they become available.