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Political Financing Handbook for Third Parties, Financial Agents and Auditors (EC 20227) – August 2019

1. Reference Tables and Timelines

The reference tables and timelines in this chapter are quick reference tools for the use of third parties, financial agents and auditors.

The chapter contains the following:

Registration requirements

Pre–election period registration requirements

Registration requirements
Text description "Registration requirements"

1 The pre–election period starts on June 30 in the year of a fixed–date general election. It ends on the day before the general election is called.

2 A foreign corporation cannot register as a third party if, during the pre–election period, its only activity in Canada is to influence electors to vote or refrain from voting, either in general or for a particular candidate or registered party.

3 In defining who is not a third party, a potential candidate means someone who is selected in a nomination contest, is deemed to be a candidate because they have conducted political financing transactions, or has the support of a political party to be a candidate of that party.

Note: A third party may register if it intends to incur pre–election period expenses totalling $500 or more, even if it has not yet incurred the expenses.

Election period registration requirements

Election period registration requirements
Text description "Election period registration requirements"

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

2 A foreign corporation cannot register as a third party if, during the election period, its primary purpose in Canada is to influence electors to vote or refrain from voting, either in general or for a particular candidate or registered party.

Note: A third party may register if it intends to incur pre–election period expenses totalling $500 or more, even if it has not yet incurred the expenses.

Note: A third party that registered during the pre-election period and is also required to register during the election period is deemed to be registered for the election period.

Role and appointment process—financial agent

Third party's financial agent

Role summary
  • The financial agent is responsible for administering the third party's financial transactions related to regulated activities during the pre-election period and election period, and for reporting those transactions to Elections Canada as required by the Canada Elections Act.
  • The financial agent may authorize another person to accept contributions or incur expenses for regulated activities, but that does not limit the responsibility of the financial agent.
  • The financial agent's role continues until the third party fulfills all financial reporting requirements.
Who is eligible? Yes / No
Canadian citizen Yes
Permanent resident of Canada Yes
Potential candidate, candidate or their official agent No
Leadership contestant or their leadership campaign agent No
Nomination contestant or their financial agent No
Chief agent or registered agent of a registered party or eligible party No
Election officer or member of the staff of a returning officer No
Any other person or group not mentioned above No
Appointment process
  • When the third party applies to register, it must submit the General Form—Third Party. This form must include the financial agent's name, address and telephone number.
  • The financial agent has to sign a statement consenting to act in that capacity.
  • If for any reason the financial agent is no longer able to continue in that role, the third party must appoint a new financial agent and notify Elections Canada without delay. The notice has to include a signed consent from the new financial agent.
  • Although it is not a legal requirement, a financial agent should be experienced in managing finances. The role requires a strong ability to control, record and administer financial transactions as well as to create financial reports.

Role and appointment process—auditor

Third party's auditor

Role summary
  • The auditor, if one is required, has to examine the third party's financial records and give an opinion in a report as to whether the third party's financial return presents fairly the information contained in the financial records on which it is based.
  • The auditor has a right to access all documents of the third party, and may require the third party or the financial agent of the third party to provide any information or explanation that is necessary to enable the auditor to prepare the report.
Who is eligible? Yes / No
Person who is a member in good standing of a corporation, an association or an institute of provincially incorporated professional accountants (CPA designation)* Yes
Partnership of which every partner is a member in good standing of a corporation, an association or an institute of provincially incorporated professional accountants (CPA designation)* Yes
Third party's financial agent No
Person who signed the third party's application for registration No
Election officer No
Potential candidate, candidate or their official agent No
Leadership contestant or their financial agent No
Nomination contestant or their financial age No
Chief agent or registered agent of a registered party or eligible party No
Any other person or group not mentioned above No
Appointment process
  • If the third party incurs expenses totalling $10,000 or more for regulated activities, an auditor must be appointed.
  • The auditor has to sign a statement consenting to act in that capacity.
  • The third party must notify Elections Canada about the appointment without delay. If for any reason the auditor is no longer able to continue in that role, the third party must appoint a new auditor and notify Elections Canada without delay. The notice has to include a signed consent from the new auditor.
  • The third party may have only one auditor at a time.

* Provincial and territorial auditing bodies may require auditors to meet other professional criteria in order to perform this role.

Note: For a guide to preparing the auditor's report, please refer to guidance produced by the Chartered Professional Accountants of Canada. A link to the guide is posted on the Elections Canada website.

Note: The Canada Elections Act does not provide for a subsidy in relation to audit services for registered third parties.

Interim reporting requirements for a fixed–date general election

Interim reporting requirements for a fixed-date general election
Text description "Interim reporting requirements for a fixed-date general election"

* A third party is required to register immediately if it incurs expenses totalling $500 or more for regulated activities that take place during the pre–election period, or $500 or more for regulated activities that take place during the election period

Note: Once a third party starts filing interim reports, it must file all remaining interim reports.

Interim reporting requirements for a general election held other than on a fixed date

Interim reporting requirements for a general election held other than on a fixed date
Text description "Interim reporting requirements for a general election held other than on a fixed date"

Note: Once a third party starts filing interim reports, it must file all remaining interim reports.

Note: There are no interim reporting requirements for by-elections.

Third party interim reporting scenarios

Fixed-date general election
(in these scenarios, the election period starts on Sept. 15, 2019, and election day is Oct. 21, 2019)
Register Interim reporting deadlines
On May 10, the third party receives a $50,000 contribution for regulated activities.

On May 15, the third party purchases advertising on national radio for $8,000. The broadcast will start on June 30.
June 30
  1. July 5 (for period between Oct. 20, 2015, and June 30, 2019)
  2. Sept. 15 (for period between July 1 and Sept. 14)
  3. Sept. 30 (for period between Sept. 15 and Sept. 28)
  4. Oct. 14 (for period between Sept. 29 and Oct. 12)
On July 20, a third party purchases flyers for $750 to promote a potential candidate during the pre–election period.

The third party receives a $10,000 contribution for regulated activities on August 15.
July 20
  1. Sept. 15 (for period between Oct. 20, 2015, and Sept. 14, 2019)
  2. Sept. 30 (for period between Sept. 15 and Sept. 28)
  3. Oct. 14 (for period between Sept. 29 and Oct. 12)
On Aug. 30, a third party hires a media firm to design election advertising for $1,500 that will be distributed during the election period.

The third party incurs another $8,000 in expenses and receives $9,000 in contributions for regulated activities during the election period.
Sept. 15 Interim reporting is not required.
(The third party has not incurred expenses of $10,000 or more, or received contributions of $10,000 or more, for regulated activities.)
In 2018, a third party received contributions totalling $15,000 to conduct election surveys.

On Sept. 17, it incurs an expense of $5,000 to conduct an election survey during the election period.
Sept. 17
  1. Sept. 30 (for period between Oct. 20, 2015, and Sept. 28)
  2. Oct. 14 (for period between Sept. 29 and Oct. 12)
A third party hires an event organizer on Oct. 1 at a cost of $12,000 to hold a national event on Oct. 10, promoting a registered party. Oct. 1
  1. Oct. 14 (for period between Oct. 20, 2015 and Oct. 12, 2019)
General election held other than on a fixed date Register Interim reporting deadlines
A snap general election is called on Jan. 20. Election day is Feb. 25.

On Jan. 31, a third party purchases ads on national TV for $60,000, promoting a registered party.
Jan. 31
  1. Feb. 4 (for period between Oct. 20, 2015, and Feb. 2, 2019)
  2. Feb. 18 (for period between Feb. 3 and Feb. 16)