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Political Financing Handbook for Candidates and Official Agents (EC 20155) – April 2024

9. Election Expenses

This chapter explains what election expenses are, describes how limits are calculated and applied, and gives examples of typical election expenses. It covers the following topics:

  • What are election expenses?
  • Who can incur and pay election expenses?
  • Limits on election expenses
  • Uncancellable advertising or activities
  • Typical election expenses (election advertising, websites and web content, voter contact calling services, other outreach, expenses related to the campaign office and workers)
  • Use of existing resources (websites, signs and parliamentary resources)

What are election expenses?

An election expense is:

  • any cost incurred or non-monetary contribution received by a candidate to the extent that the property or service that the cost was incurred for, or that was received as a non-monetary contribution, is used to directly promote or oppose a candidate during an election period
  • any non-monetary transfer received from a registered party or a registered association of the registered party to the extent that the property or services are used to directly promote or oppose a candidate during an election period

The concept of "directly promoting or opposing a candidate" is not limited to election advertising. It is to be understood broadly and includes expenses for running a campaign, such as office rental, telecommunication services, etc.

This means that most expenses reasonably incurred for property or a service used during the election period are election expenses, unless they:

The election period starts on the day the election is called and ends on election day when the polls close.

Election expenses may be eligible for partial reimbursement. See Chapter 18, Reimbursements and Subsidies, for more information.

Who can incur and pay election expenses?

The official agent or a person authorized in writing by the official agent can incur election expenses.

Candidates also need written authorization from their official agent to incur election expenses and can only incur the expenses in accordance with that authorization.

Only the official agent is allowed to pay election expenses, other than petty expenses paid from the petty cash with the official agent's written authorization.

Limits on election expenses

The Canada Elections Act imposes a limit on election expenses to facilitate a level playing field among candidates.

The limit applies to each candidate's election expenses in the electoral district where they are seeking election. The limit applies to the total of all election expenses, whether paid, unpaid, or accepted as non-monetary contributions or transfers.

The official agent and any person authorized in writing by the official agent to incur expenses all have to respect the election expenses limit. They cannot enter into contracts or incur election expenses that exceed the limit.

The campaign will need an expense approval process to help ensure that the official agent and any authorized persons, including the candidate, are informed and co-operate when incurring expenses. An expense approval process and a campaign budget created at the beginning of the campaign help to manage finances effectively.

Note: A campaign that exceeds its election expenses limit will have its reimbursement reduced based on a sliding scale. See Chapter 18, Reimbursements and Subsidies, for details.

How are the limits calculated?

The limit amount varies from one electoral district to another. Elections Canada calculates the limit for each electoral district as follows:

  1. Expenses limits are based on the number of names appearing on the preliminary lists of electors or on the revised lists of electors for the electoral district, whichever is greater.
  2. The Canada Elections Act provides for an adjustment for candidates running in electoral districts where there are fewer electors than the national average. In these districts the limit is increased.
  3. The Canada Elections Act also provides for an adjustment for geographically large electoral districts. If the number of electors per square kilometre of the electoral district is less than 10, the candidate's expenses limit is increased.
  4. The limit is then adjusted by the inflation adjustment factor in effect on the day the election
    is called.

Notification of election expenses limits

Shortly after an election is called, Elections Canada notifies each returning officer of the preliminary election expenses limit. The returning officer advises each campaign of the preliminary limit.

Approximately one week before election day, Elections Canada notifies the candidates directly of their final election expenses limit. The final election expenses limit may be higher but not lower than the preliminary limit.

Note: During an election, expenses limits are published on the Elections Canada website in the Political Entities section.

Uncancellable advertising or activities

Candidates might plan advertising or activities, promoting themselves or opposing another candidate, with a transmission or execution date that is before the expected start of an election period. If an election is called and the campaign is unable to cancel or stop the advertising or activity, it will not be considered an election expense even though it will take place during the election period.

However, campaigns must make every effort to stop the advertising or activity in order to exclude it from election expenses, even if there is a financial repercussion. For example, where reasonably possible, rallies must be cancelled, signs covered or removed within a few days of the election call, and online or broadcast ads stopped.

Despite the above, for a fixed-date election, any advertising transmitted or activity held in the 36 days preceding election day will be an election expense.

Typical election expenses

The following are examples of typical election expenses.

Traditional election advertising

What is election advertising?

Election advertising is the transmission to the public of an advertising message promoting or opposing the election of a candidate during the election period.

Promoting or opposing the election of a candidate may include but is not limited to:

  • naming the candidate
  • showing a photograph, cartoon or drawing of the candidate
  • identifying the candidate, including by political affiliation or by a logo
  • providing a link to a web page that does any of the above

Expenses incurred for advertising conducted during the election period, including the expenses for production and distribution, are to be reported as election expenses.

Tagline

Advertisements distributed through traditional means such as signs, billboards, flyers, pamphlets, radio, television, newspapers or magazines during an election period are election advertising and have to be authorized by the official agent.

This authorization has to be mentioned in or on the message—for example, "Authorized by the official agent of John Smith."

Blackout period

The Canada Elections Act prohibits the transmission of election advertising to the public in an electoral district on election day before the close of all polling stations in the electoral district.

The blackout does not apply to distributing pamphlets or putting up signs, posters or (non-web) banners during that period. Nor does it apply to transmitting a notice of an event that the party leader will attend or an invitation to meet or hear the party leader.

Examples
  1. In anticipation of an upcoming election, the official agent purchases flyers before the election is called and distributes them during the election period to promote the candidate. The expense for the flyers—including their design, printing and distribution—is an election expense. The flyers are election advertising and have to include an authorization statement from the official agent.
  2. The official agent purchases an advertisement that is broadcast during the election period on the local radio station, promoting the candidate. The expense for the advertisement—including its design, recording and transmission—is an election expense. The advertisement is election advertising and has to include an authorization statement from the official agent.

Election signs

Election signs are election advertising and are subject to the tagline requirement mentioned above for traditional election advertising. They are not subject to the blackout requirement.

Expenses incurred to obtain election signs for the candidate's campaign are election expenses. Even if some signs are never installed, the expense to obtain the signs counts toward the election expenses limit.

Sometimes election signs are vandalized or stolen. If the campaign has many affected signs, it may want to report the expense to replace vandalized or stolen signs as an other electoral campaign expense instead of an election expense. This can be done if the campaign:

  • replaces the vandalized or stolen signs with signs of the same cost (or, if the signs are more expensive, reports the increase in cost as an election expense)
  • files a police report that includes a description of the signs, their location and costs
  • keeps the police report and evidence of the vandalism or theft in its records (for example, photographs or a statement from the property owner)

Signs are often used for more than one election. For details, see the Use of parliamentary resources and other existing resources section below.

Note: Because uninstalled signs count toward the election expenses limit, a campaign should be mindful to purchase only the quantity of signs that it intends to install.

Election advertising on the Internet

What qualifies as election advertising on the Internet?

Election messages communicated over the Internet are election advertising only if:

  • they meet the general criteria for election advertising (see What is election advertising? above), and
  • they have, or would normally have, a placement cost (such as sponsored or boosted content)

For greater certainty, the following are not election advertising:

  • messages sent or posted for free on social media platforms such as X and Facebook
  • messages sent by email or through other messaging services (including texts sent through a cellular or mobile network)
  • videos posted for free on social media platforms such as YouTube and Instagram
  • content posted on the candidate's website (the ongoing expenses for creating and maintaining a website are not placement costs)

However, any associated expenses are election expenses. See the Websites and web content section below.

Note: If the candidate's campaign decides to sponsor or boost social media content that was originally posted for free, it will become election advertising and require a tagline.

Do posts by social media influencers qualify as election advertising?

Influencers are people with a strong online presence who are sometimes used by marketers to promote brands. They can be any person with an online reach that others are willing to pay for. Influencers regularly post unpaid and paid content to their social media accounts, which serve both personal and commercial purposes. As with any individual, if an influencer independently chooses to post their personal political views on the Internet without being paid, the communication is not election advertising.

If the candidate pays a social media influencer to post a message on the influencer's account in an election period, it is election advertising. Influencer advertising does not have to be captured in an online platform registry, but it is subject to the tagline requirement and blackout period.

A candidate simply asking for and receiving a free endorsement from an influencer will not trigger regulation. But if the candidate wants to discuss the posts with the influencer, see the rules and restrictions in Chapter 16, Interacting with Third Parties in the Pre-election and Election Periods.

Tagline

The official agent has to authorize any election advertising, and this authorization must be mentioned in or on the advertisement. Where the authorization statement cannot be included on the advertising message because of its size, this is acceptable if the statement is made immediately apparent to the viewer by following the link in the advertising message.

Information to be held in an online registry

Regulated online platforms (that is, websites or applications that meet certain criteria for monthly visitors or users) have to maintain a registry of political advertising.

When a candidate's campaign purchases election advertising online, to make sure it complies with the law, it should:

  • inform the platform that it is conducting political advertising
  • ask if the platform is regulated by the rules in the Canada Elections Act and needs information for its registry (unless the platform has already made this clear)

If the platform is regulated, the campaign must provide it with:

  • an electronic copy of the advertisement
  • the name of the official agent who authorized its distribution on the platform

The platform must publish this information in its registry from the day the ad runs until two years after election day.

Note: These rules also apply to partisan advertising conducted by a candidate's campaign in the pre-election period.

Blackout period

The Canada Elections Act prohibits the transmission of election advertising to the public in an electoral district on election day before the close of all polling stations in the electoral district.

The blackout does not apply to the transmission of a message on the Internet that was placed before the blackout period began and was not changed during that period—for example, an advertisement placed in a weekly online magazine.

However, if an Internet advertisement is actively transmitted to different users daily and the campaign is able to control the transmission date—for example, a paid social media or search engine advertisement—the blackout must be respected.

The blackout also does not apply to transmitting a notice of an event that the party leader will attend or an invitation to meet or hear the party leader.

Examples
  1. The candidate's campaign hires a media firm to place web banners on social media platforms during the election period, directing users to a video posted on YouTube. Because the web banners have a placement cost and promote the candidate, they are election advertising and have to be authorized by the official agent. They are subject to the blackout on election day. Because there is no placement cost to post the video, it is not election advertising, but all expenses related to designing and developing the video are election expenses.
  2. A group page has been created for the candidate on a free social networking site. Volunteers manage the page and post articles related to the candidate's campaign. This is not election advertising. As long as the volunteers are helping outside their regular working hours and are not self-employed in the business of managing social media, the volunteer labour is not an expense.
  3. The official agent hires a media firm to post content on the candidate's website during an election, promoting the campaign. The content is not election advertising, but all expenses related to designing, developing and posting the content are election expenses.
  4. A candidate asks a social media influencer for a free endorsement during the election period. The influencer, who is active on video platforms and supports the candidate's policies, agrees to the request. The influencer independently decides on the content of a short video, films it with their own equipment and posts it on Instagram for free. This is not election advertising.
OGI reference

For a detailed discussion of this topic, please refer to Elections Canada's interpretation note 2020‑05, Partisan and Election Advertising on the Internet, on the Elections Canada website.

Websites and web content

Candidates often create websites and social media accounts specifically for their campaigns, either during or in the lead up to an election. Pre-existing websites and social media accounts might also be used to promote the candidate during the election period.

The following table shows when a website or web content that remains online during the election period is an election expense of the candidate, taking into account the purpose of the material.

Type of website or web content Candidate's election expense
Campaign's website and social media accounts

The expenses incurred for the campaign website itself—including its design, hosting and maintenance—are election expenses.

Expenses to produce and distribute content on the website or social media accounts are also election expenses. Because the site and accounts exist for the purpose of the campaign, all content that is online during the election period counts as an expense, regardless of when it was posted.

However:

  • If content was produced entirely or in part using volunteer labour, only the actual expense incurred by the candidate is an election expense. This may include materials, equipment rental or paid labour.
  • If the candidate and its affiliated entities share each other's web content for free online, the expense to create the web content is reported only by the political entity that first created it (or the political entity that commissioned the content, if it was created on that entity's behalf).
Note: If the nomination campaign website is repurposed, the electoral campaign must pay its commercial value to the nomination campaign or accept it as a personal non-monetary contribution from the candidate.
Registered association's website and social media accounts If the registered association's website promotes the candidate and stays online during the election period, it is an election expense of the candidate. Elections Canada will accept the current commercial value of an equivalent website as the commercial value of a pre-existing website.

The official agent must approve this transfer from the association to the campaign. If the official agent does not wish to have this expense count toward the limit, the website must go offline during the election period.

Expenses to produce and distribute content on the website or social media accounts for the purpose of the campaign are also election expenses. Pre-existing content is only an expense if it was posted for the purpose of the campaign or promoted during the campaign.
Candidate's personal website and social media accounts A candidate's pre-existing personal website is an election expense if it is used for the purpose of the campaign. Elections Canada will accept the current commercial value of an equivalent website as the commercial value of a pre-existing website.

Expenses to produce and distribute content on the website or social media accounts for the purpose of the campaign are also election expenses. Pre-existing content is only an expense if it was posted for the purpose of the campaign or promoted during the campaign.

The expenses are also non-monetary contributions from the candidate. However, if the candidate did not incur any expenses for the website or web content, there is no expense or contribution to report.
Parliamentarian's website and social media accounts See the Use of parliamentary and other existing resources section below.

Note: The official agent has to report as election expenses all the expenses related to the design, development and distribution of online communications used during an election period, regardless of whether or not they are election advertising.

Examples
  1. The candidate's campaign launches a website two months before the election period. The campaign posts content such as the candidate's biography, blogs and videos. The election expense to report is the expense to create the website; to maintain and host it during the election period; and to produce all content, whether it was posted before or during the election period.
  2. The candidate has a personal X account and continues to post from that account during the election period. Sometimes she posts about her campaign. If the candidate is posting for free, there is no expense to report.
  3. During the election period, the candidate's registered party posts a video of the party leader speaking at a rally on its Instagram account. The candidate decides to share the video on her own Instagram account for free. The party reports the production and distribution cost of the video, if any, as an election expense. The candidate does not report an election expense for sharing an affiliated political entity's web content.
OGI reference

For a detailed discussion of a similar topic, please refer to Elections Canada's interpretation note 2018-04, Pre-existing Web Content of Registered Parties in an Election, on the Elections Canada website.

Voter contact calling services

Voter contact calling services are services involving the making of calls during an election period for any purpose related to an election, including:

  • promoting or opposing a candidate or any position on an issue with which a candidate is associated
  • encouraging electors to vote or to refrain from voting
  • providing information about the election, including information about voting hours and the location of polling stations
  • gathering information about how electors voted in past elections, or will vote in the election, or their view on a candidate or on any issue with which a candidate is associated
  • raising funds for a candidate

Expenses incurred for voter calls conducted during the election period, including their production and distribution, are election expenses.

Note: The candidate's campaign must register with the Canadian Radio-television and Telecommunications Commission (CRTC) if it uses a calling service provider or automatic dialing-announcing device to make voter calls during an election period. Refer to the CRTC's Voter Contact Registry web page for details.

OGI reference

For a detailed discussion of this topic, please refer to Elections Canada's interpretation note 2019-11, Application of Partisan and Election Advertising Rules to Telephone Calls, on the Elections Canada website.

Mass text messaging

When a candidate's campaign sends mass text messages during the election period to promote themselves or oppose another candidate, the expenses incurred for production and distribution are election expenses.

While they may result in election expenses, text messages sent by a candidate's campaign are generally not regulated by the CRTC under Canada's Anti-Spam Legislation. The messages are covered only if they are commercial in nature, excluding a text whose primary purpose is to solicit a contribution. This means that text messages promoting or opposing a candidate, asking for an elector's vote or asking for a contribution are not subject to CRTC rules.

Since a text message is not election advertising, there is also no requirement to identify the sender under the Canada Elections Act, though we recommend it as a best practice.

Note: For more information on text messaging, please refer to the CRTC's web page entitled "Frequently Asked Questions About Canada's Anti-Spam Legislation."

Voter databases, surveys and research

Voter databases

An expense that a candidate's campaign incurs for the use of voter database software during an election period is an election expense. The table below shows how to determine the election expense, based on the software arrangement.

The campaign must also report an "other" electoral campaign expense if it incurs expenses to use voter database software outside the election period.

Software arrangement Political entity Election expense
Political entity has an ongoing contract with a supplier for use of the database software Candidate with their own software Amount charged by the supplier for ongoing use, prorated for the election period
Candidate using the registered party's software Amount charged by the supplier for additional access per candidate, prorated for the election period
Candidate using a registered association's software Amount charged by the supplier to the association for ongoing use, prorated for the election period
Political entity owns the database software outright (customized or off-the-shelf solution) Candidate with their own software Commercial value of renting a similar asset for the election period* or actual purchase price, whichever is less
Candidate using the registered party's software Commercial value of the party renting additional access per candidate during the election period (building on the commercial value of the party renting software for itself)*
Candidate using a registered association's software Commercial value of renting a similar asset for the election period* or actual purchase price, whichever is less

*The commercial value is the lowest amount that a supplier would normally charge for the use of database software with equivalent functions (e.g. generates canvassing lists) and capacity (e.g. holds information on 100,000 electors) over the election period. A quote should be obtained from a subscription-based software supplier.

Examples
  1. A candidate is endorsed by a registered party that offers access to its central database. The party has an annual contract with a supplier for its voter database software, and the supplier charges the party an extra $100,000 for its 338 candidates to have access during the election period. The candidate receives an invoice for $296 ($100,000 / 338) from the party's chief agent to account for the access fee. This can be sent as a non-monetary transfer or as an invoice to be paid. The official agent reports $296 as an election expense for use of the database software during the election period.
  2. A candidate's campaign subscribes to a voter database service from June 1 to November 30 (183 days) in an election year at a cost of $500 per month. The election period runs for 40 days during that time. The official agent reports an election expense of $655.74 (6 months x $500 / 183 days x 40 days) for use of the database software during the election period. The remaining amount, $2,344.26, is reported as an other electoral campaign expense for days outside the election period.
  3. A candidate's campaign creates a voter database using off-the-shelf software at a cost of $100 before the election period. The official agent reports an election expense of $100 for use of the database software during the election period.

Surveys and research

Whether an expense for a survey or research is an election expense depends on when it was conducted. The date that a campaign conducts a survey or research is the date that it receives the data. If the candidate's campaign conducts a survey or research:

  • during an election period, it is an election expense
  • outside an election period, it is not an election expense but an other electoral campaign expense, even if the data is used during the election period

Expenses to add data to a database and clean the data during the election period, and for system support during the election period, are also election expenses.

In some cases, a registered party might incur data expenses centrally on behalf of its candidates. If a candidate's official agent agrees to buy the property or services from the party, a prorated amount for their electoral district is the candidate's election expense rather than the party's election expense.

Examples
  1. A candidate's campaign engages Election Polling Inc. to conduct a survey of electors for $1,500. The campaign receives the survey data during the election period. The official agent reports an election expense of $1,500.
  2. Before an election period, a candidate's campaign pays a data broker $10,000 for two sets of data. The campaign receives the first set immediately and the second set after the election period starts. The official agent reports an other electoral campaign expense of $5,000 and an election expense of $5,000.
  3. During an election period, a registered party buys phone numbers from a data broker on behalf of its candidates to support their get-out-the-vote activities. Each candidate's official agent agrees to buy the data from the party. The chief agent sends candidates an invoice for their share of the expense, and the official agents report the amount as an election expense.

Data from an external source

When a candidate's campaign receives data for free or at a discount from an external source, it is accepting a contribution.

An external source is a person or group other than:

  • the registered party, its candidates and its registered associations
  • a person providing volunteer labour to the above-mentioned political entities (see Volunteer labour is not a contribution in Chapter 3, Contributions)
  • Elections Canada, when it is providing data to candidates as required by law

If an external source is an ineligible contributor or an individual who would exceed their contribution limit, the campaign must be invoiced for the data at commercial value. The commercial value is the lowest amount charged by a business for a dataset with a similar number of entries and data fields and with a similar level of quality and currency.

If the external source is not in the business of selling data and collected data specifically for the candidate, the invoiced amount must be the actual expenses incurred.

Candidates coordinating activities with third parties should be aware of potential risks. See Activities conducted by others in coordination with the candidate's campaign may be contributions in Chapter 3, Contributions.

Example

During an election period, an advocacy group offers a candidate's campaign its members list. The list is a spreadsheet with names, addresses and phone numbers of 100 people who support an issue that the candidate is associated with. The advocacy group is an ineligible contributor, so the candidate's campaign cannot accept this list for free. However, the campaign determines that an equivalent dataset would be sold by a broker for $500 and asks the advocacy group to invoice that amount. The official agent pays and reports an election expense of $500 for the data.

OGI reference

For a detailed discussion of this topic, please refer to Elections Canada's interpretation note 2022-03, Voter Databases and Election Expenses, on the Elections Canada website.

Capital assets

Under the Canada Elections Act, a capital asset is any property with a commercial value of more than $200 that is normally used outside an election period other than for the purposes of an election (for example, computers, software, printing equipment and furniture).

If the candidate's campaign purchases a capital asset and uses it during the election period, the election expense is the lower of the commercial value of renting a similar asset for the same period or the purchase price.

For non-capital assets such as office supplies, the purchase price must be recorded as an election expense.

Capital assets might be received in the form of a contribution from an individual or a transfer from the registered party or a registered association of the party. In that case, the commercial value of the asset is a non-monetary contribution or transfer. If the asset was used during the election period, the election expense is the lower of the commercial value of renting a similar asset for the same period or the purchase price. The remaining amount, if any, is an other electoral campaign expense.

Note: Amortization may not be used as a method of calculating the commercial value of the use of the asset.

Note: Capital assets acquired during the campaign must be disposed of at the end of the campaign. They must be sold at fair market value, or else transferred to the party or to the registered association in the candidate's electoral district.

Examples
  1. The candidate's campaign rents two computers from a local office supplier for $500 on the day the election is called. The rental agreement is for two months (61 days), and the election period is 37 days. The cost of renting the computers during the election period is an election expense, and it is calculated as follows: $500 / 61 x 37 = $303.30. The remaining amount, $196.70, is recorded as an other electoral campaign expense.
  2. On the day the election is called, the official agent pays $100 at a garage sale for the purchase of a printer for the campaign. The commercial value of renting a similar printer during the election period would have been $150. The official agent records $100 as an election expense since the purchase price, $100, is lower than the rental rate.
  3. A volunteer uses his personal laptop to do work for the campaign during the election period. The commercial value of renting a similar laptop for the 37-day period would be $80. This is a non-monetary contribution from the volunteer. However, because the amount is $200 or less and the volunteer is not in the business of providing electronics, the non-monetary contribution is deemed to be nil and there is no expense to report.

Rental of a campaign office

The campaign may rent an office for the candidate's campaign. The portion of the rent incurred before and after the election period is an other electoral campaign expense. Only the portion of the rent used during the election period is an election expense.

Example

The campaign rents an office on March 1, a month before the election is called. The rental agreement is for three months and the rent is $300 a month. The election period is 37 days.

The election expense to be recorded is the rent for the month of April, plus the rent for 7 days in May: $300 + (7 / 31 x $300) = $367.74. The remaining amount, $532.26, has to be recorded as an other electoral campaign expense.

Note: If the registered association rents an office for the candidate in advance, the candidate's campaign must report all of the rent as its own expense either from the date agreed on for the campaign to start using the office or from the date it starts using the office (whichever is earlier).

Installation and other office expenses

The expense incurred to install items used during the election period is an election expense even if the installation takes place before the election is called, as long as the item itself is an election expense. Installation expenses cannot be prorated.

Other office expenses include the cost of buying office supplies, such as paper or toner cartridges, or supplying refreshments during meetings.

Example

The campaign pays $500 in labour for a worker to install telephones, computers and printers in the office before the election starts. The full $500 is an election expense because the installed equipment is used during the election period.

The campaign also pays a monthly rate of $200 for telephone usage. The prorated cost for days during the election period is an election expense, while the prorated cost for days outside the election period is an other electoral campaign expense.

Cell phones

A candidate's campaign might provide the candidate and workers with cell phones for use during the election period. If the campaign supplies the phones, the election expense is the cost of the cell phones and monthly usage plans, prorated for the length of the election period, plus any additional fees.

If personal cell phones are used during the election period, there are two ways that the expenses may be accounted for:

  • Candidates or workers may ask the campaign to reimburse expenses that they incurred because of the election. These costs are election expenses for days during the election period.
  • Candidates or workers may make a non-monetary contribution of the use of their phone. If the incremental expenses that they incurred because of the election are $200 or less (for example, additional fees per monthly phone bill) and the person is not in the business of providing cell phone service, then the contribution amount is deemed to be nil and no expense is reported.
Examples
  1. The candidate's campaign rents cell phones for its workers at a cost of $30 per day over a 40‑day election period. The rental company charges a usage fee per transaction. The election expense is $1,200 (40 x $30) plus any transaction fees incurred on days during the election period. Any costs for days outside the election period are other electoral campaign expenses.
  2. Ling, a candidate, uses her own cell phone for campaigning during a 40-day election period. On top of her usual monthly fee, she incurs an extra $100 for data overage while campaigning door to door. Because the incremental expense that she incurred for the election is $200 or less, Ling could make a non-monetary contribution of the data overage, and it would be deemed nil. However, the campaign agrees to reimburse the $100 and reports it as an election expense.

Campaign workers and related expenses

The candidate's campaign may have to report various election expenses related to their paid workers and volunteers: incidental expenses, travel and living expenses, and compensation.

Incidental expenses of campaign workers

Whether campaign workers are volunteering or being paid, some incidental expenses related to their work, such as for local transportation and refreshments, are election expenses.

If a worker pays for incidentals and is not reimbursed, the amount is a non-monetary contribution and an expense. However, if the amount is $200 or less and the individual is not in the business of providing that property or service, the non-monetary contribution is deemed to be nil and no expense has to be reported. Each incidental expense is measured individually against the $200 threshold to determine whether the contribution is deemed nil.

The campaign may provide gift cards to its workers specifically to cover incidental expenses, such as gas and food, during the election period. These gift cards are reported as election expenses, not as gifts to workers. To support the expenses, workers who make a purchase of $50 or more with a gift card should get an invoice (or other document evidencing the expense) showing the date, amount and items purchased, while workers who make a purchase of less than $50 with a gift card should record the date, amount and nature of the expense. Without these supporting documents, the expenses may not be eligible for reimbursement.

Examples
  1. Late one night during the election period, volunteers help in the campaign office to prepare hundreds of flyers for mailing. A volunteer orders pizza and pays the delivery person $85 with their personal credit card. The campaign reimburses the volunteer a few weeks later. The amount of $85 is an election expense.
  2. A volunteer is driving around in her own car to deliver flyers during the election period. She pays $30 to fill up her car. If the amount is not reimbursed by the campaign, the volunteer made a non-monetary contribution. However, because the amount is $200 or less, the non-monetary contribution is deemed to be nil and no expense has to be reported.
  3. The campaign gives 10 volunteers a $50 gift card each to buy meals while they help during the election period. The volunteers use their gift cards to make multiple purchases under $50. They record the date, amount and nature of each expense, and give these records to the official agent. The official agent submits the records, along with the invoice and proof of payment from the original purchase of the gift cards, as supporting documents with the financial return.

Travel and living expenses of campaign workers

Campaign workers, whether volunteering or being paid, might travel to help at campaign events during the election period.

No matter when travel happens, if the work performed at the destination is an election expense, the travel expense in both directions is an election expense. This includes return trips after the election period.

Temporary lodging and meals (or per diems) are also an election expense but only for days during the election period.

It is advisable to have a written agreement or other documentation about a campaign worker's travel and living expenses to support all amounts being reported. In the absence of evidence, the payments may be considered an inappropriate use of campaign funds that would need to be returned.

When a worker is sharing transportation with the candidate, some of the cost may be an election expense and some may be the candidate's travel and living expense. See Chapter 11, Candidate's Travel and Living Expenses.

Travel and living expense of campaign workers Timing Reported as
Travel to and from destination Days during or outside election period Election expense
Lodging and meals

Days during election period

Days outside election period

Election expense

Other electoral campaign expense

Note: If a worker pays for travel and living related to the campaign and is not reimbursed, the amount is a non-monetary contribution and a reportable expense. However, if the amount is $200 or less and the individual is not in the business of providing that property or service, the non-monetary contribution is deemed to be nil and no expense is reported.

Note: If workers have travelled to a particular destination for a purpose unrelated to the election and help with the campaign while there, only incremental expenses incurred to help are election expenses.

Examples
  1. The campaign rents a bus to transport volunteers to one of the candidate's speaking events during the election period. It spends $600 on the rental and another $100 on refreshments for the volunteers. The $700 is an election expense.
  2. The campaign is paying to relocate a worker, Gordon, from party headquarters to the candidate's riding for the election. The round-trip flight is $800. It is an election expense even if Gordon flies outside the election period. Gordon has free lodging with a relative and receives a per diem of $25. Since he travelled for 30 days during the election and 2 days outside it, the per diems result in an election expense of $750 ($25 x 30) and an other electoral campaign expense of $50 ($25 x 2). The expenses to record for Gordon's relocation are an election expense of $1,550 ($800 + $750) and an other electoral campaign expense of $50.

Compensation of workers

The campaign may choose to pay compensation to the official agent or other campaign workers, including paying volunteers for part of their work.

If a campaign worker is not receiving regular pay (i.e. a salary or hourly wage), please see information on paying volunteers for part of their work under Volunteer labour is not a contribution in Chapter 3, Contributions.

For work performed during the election period, compensation is almost always an election expense. Before the election period, it is occasionally an election expense. It is never an election expense after the election period. The table below provides examples.

An agreement must be in place before the work is performed. Once an agreement is in place, the campaign is liable for the related expenses.

An invoice is required for payments of $50 and over, setting out the nature of the expense. Because compensation expenses can vary widely, it is advisable to also have a written agreement or other documentation about a campaign worker's compensation to support all amounts being reported. Failure to adequately support the expenses may result in follow-up enquiries by Elections Canada auditors. In the absence of evidence, the payments may be considered an inappropriate use of campaign funds that would need to be returned.

Timing Compensated work: examples Reported as Why
Before election period Planning, budgeting, creating contact lists Other electoral campaign expense Research-style activities are election expenses only during the election period
Canvassing homes, distributing flyers one week before the election period Other electoral campaign expense The communication has been fully transmitted before the election period
Installing signs, designing flyers for use during the election period Election expense The communication will be used during the election period to promote/oppose a candidate
During election period General campaign work Election expense Most work during the election period is done to promote/
oppose a candidate
Converting a website to an accessible format Accessibility expense Accessibility-related work is excepted from election expenses (see Chapter 13)
Processing contributions Other electoral campaign expense Certain fundraising work is excepted from election expenses (see Chapter 7)
After election period Any work Other electoral campaign expense Work done after the election period does not promote/
oppose a candidate during an election period

Note: When paying candidates' representatives at the polls or office of the returning officer, compensation up to $5,000 total is reported as a personal expense of the candidate.

Examples
  1. Leslie, a candidate, is paying her official agent $1,000 for work done before the election period, including budgeting, signing contracts and preparing lists of volunteers. The $1,000 is an other electoral campaign expense. A portion of the $1,000 could be an election expense if the output of the work, such as a campaign website, voter contact script or launch party, is tied to a specific activity during the election period. Supporting documents would need to show why part of the compensation is in fact an election expense. Leslie is paying her official agent another $2,500 for general work during the election period. The $2,500 is an election expense.
  2. Leslie is paying $50 compensation to each of her six representatives at the polls on election day. The total amount paid, $300, is recorded as the candidate's personal expense rather than as an election expense.

High-profile campaigners and invited guests

Parliamentarians, other candidates or celebrities will sometimes campaign with a candidate at in-person events. The candidate might also invite a high-profile guest to play an official role in an event.

When it comes to expenses, high-profile campaigners and guests are treated in the same way as campaign workers. This means their travel and living expenses associated with the event are election expenses. Any compensation paid to them (or the commercial value of a service that they are not eligible to provide as a volunteer) is also an election expense.

If they have travelled to a particular destination for purposes unrelated to the election and help with the campaign while there, only incremental expenses incurred to help are election expenses.

Some celebrities charge appearance fees to take part in events, though as individuals they often make the personal choice to participate for free in other events. As with any individual, if a celebrity is self-employed as a speaker but chooses to express their personal political views at a candidate's event without being paid, they may do so without making a non-monetary contribution.

However, there is a difference when the celebrity is asked to provide a service other than speaking or appearing, such as participating as an emcee or a performer. In that case, the commercial value of the service is an election expense, whether paid by the candidate or contributed by the celebrity.

Note that a celebrity's participation in a candidate's event is not captured as a third party partisan activity, since the candidate organizes the event and reports the expenses.

Examples
  1. The candidate invites Faiza, a celebrity who sometimes charges for speaking engagements, to give a speech at a campaign rally. Faiza supports the candidate and can choose to speak for free. She does not have to charge for her participation or make a contribution of its commercial value. Faiza did not have to travel to attend the event, and the campaign incurred no additional expenses for her to participate. There is no contribution or election expense to report for her participation.
  2. Clydie G, a famous Canadian musician, is touring during the election and plays a show in Vancouver. The next day, he flies to Victoria to join a candidate on stage at a rally and performs a song. He then flies back to continue his tour. The cost of the round-trip flight is $400. It is an election expense that must be paid by the candidate or contributed by Clydie G. For the performance itself, because Clydie G is self-employed as a musician, he cannot volunteer the service. The commercial value of the performance is an election expense that the candidate must pay or Clydie G must contribute.

For examples involving parliamentarians and other candidates, see Chapter 15, Working with Other Entities.

Holiday greeting cards and receptions

Candidates might choose to distribute greeting cards during a holiday season. If the greeting cards are distributed during the election period, they are election advertising and have to be reported as election expenses. If these expenses are not paid by the campaign, then they could be either non-monetary contributions if paid by an individual, or non-monetary transfers if paid by the registered party or a registered association.

If the greeting cards are in transit on the day the election is called and the candidate does not have the ability to stop their delivery, they will not be considered an election expense even though the actual delivery will take place during the election period. However, any greeting cards distributed in the 36 days preceding a fixed-date election will be considered an election expense.

Holiday season receptions held during the election period are election expenses. If these expenses are not paid by the campaign, then they could be either non-monetary contributions if paid by an individual, or non-monetary transfers if paid by the registered party or a registered association.

Use of parliamentary resources and other existing resources

Candidates' campaigns commonly make use of existing resources such as signs and office staff. These resources often come from a registered association, and sometimes from a member of Parliament's office. Their use during the election period is an election expense.

If a member of Parliament uses parliamentary resources during their election campaign, and these resources are not paid by the campaign, their use is a non-monetary contribution from the member and is subject to the contribution limit.

Note: The House of Commons' Members By-law should be consulted as it may place limitations on certain uses of parliamentary resources (available on the Parliament of Canada website).

OGI reference

For a detailed discussion of a related topic, please refer to Elections Canada's interpretation note
2020-04, The Use of Member of Parliament Resources Outside of an Election Period, on the Elections Canada website.

For details on shared transactions, such as subletting the registered association's office space, see Chapter 15, Working with Other Entities.

Used signs

If a campaign uses signs in a subsequent election, the amount of the election expense to be recorded is the current commercial value of equivalent signs.

Reused signs also have to be recorded as a non-monetary transfer or contribution received from the entity or individual that had possession of the signs. Generally this is the registered association or the candidate. Keep in mind that contribution and transfer rules apply to these transactions.

Billboards

The commercial value, including design, production and installation, of any pre-existing billboards that remain in place during the election period are election expenses. Billboards include the sign and the supporting structure. Elections Canada will accept the commercial value of an equivalent sign (that is, the same size and design) that would be temporarily installed just for the election period.

Similarly, with respect to the supporting structure, Elections Canada will accept the commercial value of an equivalent structure that would typically be used for an election period rather than the commercial value of a structure designed to be more permanent in nature. Note that the commercial value of the structure is the lower of its purchase price or its rental cost for the length of the election period.

Website and social media accounts of a parliamentarian

Candidates may have websites and social media accounts that are designed and maintained using parliamentary resources.

If the candidate uses the website for the purpose of their campaign, its commercial value—including design, maintenance and hosting—is an election expense. Elections Canada will accept the current commercial value of an equivalent website as the commercial value of a pre-existing website.

Expenses to produce and distribute content on the website or social media accounts for the purpose of the campaign are also election expenses. Pre-existing content is only an expense if it was posted for the purpose of the campaign or promoted during the campaign.

Staff of a parliamentarian

If employees on the staff of a parliamentarian engage in political activities to support the parliamentarian as a candidate during the election period, the salaries of these persons are election expenses of the candidate and, if not paid by the campaign, are non-monetary contributions from the parliamentarian.

However, if the employees work on the candidate's campaign outside their normal working hours or are on unpaid leave (or paid, if the leave was earned under regular terms of employment that do not specify leave for the purpose of helping a political entity), their involvement is volunteer labour and is therefore neither an election expense nor a non-monetary contribution.

Parliamentary database of a member of Parliament

A member of Parliament who is running as a candidate might use information on electors from their parliamentary database to promote their re-election. The campaign has to report the commercial value of the data as a personal contribution from the member, subject to their contribution limit, unless it is paid by the campaign. It is also an election expense or an other electoral campaign expense, depending on when the data was shared with the campaign.

The commercial value is the lowest amount charged by a business for a dataset with a similar number of entries and data fields and with a similar level of quality and currency. Any compensation paid to staff from the parliamentary budget to do election database work must also be reported.

Example

A candidate, who is a member of Parliament, arranges for data to be transferred from their parliamentary database to their election database before the election period starts. This is a personal non-monetary contribution from the member to their campaign. The official agent reports the commercial value of an equivalent list sold by a broker as the amount of the contribution and as an other electoral campaign expense. Note: The House of Commons Members By-law should be consulted as it may place limitations on this type of activity.

Householders issued by members of Parliament

A member of Parliament who is running as a candidate in an election might issue a householder during the election period. This is an election expense and, if not paid by the campaign, a non-monetary contribution from the member.

If a householder is in transit on the day the election is called and the candidate does not have the ability to stop the delivery, it will not be considered an election expense even though the actual delivery will take place during the election period. However, any householder distributed in the 36 days preceding a fixed date election will be considered an election expense.