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Political Financing Handbook for Electoral District Associations and Financial Agents (EC 20089) – June 2019 – Archived Content

This document is Elections Canada's archived guideline OGI 2019-04 and is no longer in effect.

Click on the link for the latest Political Financing Handbook for Electoral District Associations and Financial Agents.

8. Working with Other Entities During the Election Period

This chapter discusses how transactions are regulated when the association engages in shared activities, shares its resources or acts on behalf of another political entity during the election period. It covers the following topics:

  • Incurring election expenses on behalf of the candidate or the party
  • Typical election expenses incurred on behalf of the candidate or the party

Incurring election expenses on behalf of the candidate or the party

An electoral district association of a registered party, whether the association is registered or not, cannot incur election expenses unless it is done on behalf of the candidate or the party. The association must receive prior written authorization, and the expenses are election expenses of the candidate or the party, as the case may be.

The property or services must be:

  • sold to the party or a candidate endorsed by the party, or
  • transferred to the party, a registered association of the party (which must then also sell or transfer the property or services), or a candidate endorsed by the party

Note: Only registered electoral district associations can send transfers.

Typical election expenses incurred on behalf of the candidate or the party

The following are examples of typical activities where the registered association shares its resources or incurs election expenses on behalf of the candidate or the party.

Election advertising on behalf of the candidate or the party

Election advertising done on behalf of the candidate or the party must receive prior written authorization from the official agent of the candidate or from a registered agent of the party, as the case may be. This authorization has to be mentioned in or on the message—for example: "Authorized by the registered agent of the XYZ Party of Canada."

The registered association must send a copy of the original supplier invoice to the candidate or party. The expenses incurred for advertising conducted during the election period, including the cost of production and distribution, are election expenses of the candidate or the party.

Examples
  1. After an election is called, the financial agent of the registered association obtains the official agent's written authorization to purchase and distribute signs promoting the candidate. The financial agent sends a copy of the original supplier invoice to the candidate's campaign. These expenses are election expenses of the candidate. The official agent's authorization must be mentioned on the signs.
  2. During the election period, the registered association would like to post a video promoting the candidate on YouTube. There is no placement cost to post the video, so it is not election advertising. However, because the production cost for the video would be an election expense of the candidate, the association has to obtain prior written authorization from the candidate's official agent to post the video.
  3. The association would like to hire a media firm to place banners promoting the candidate on social media platforms during the election period, directing users to a video on YouTube. Because the banners have a placement cost and promote the candidate, they are election advertising. The association has to obtain prior written authorization from the candidate's official agent, and this authorization must be mentioned on the banners. The financial agent has to send a copy of the original supplier invoice to the candidate's campaign. These expenses are election expenses of the candidate.
OGI reference

For a detailed discussion of a related topic, please refer to Elections Canada's interpretation note 2015-04, Election Advertising on the Internet, on the Elections Canada website.

Pamphlets and flyers

An electoral district association of a registered party, whether the association is registered or not, might choose to distribute pamphlets and flyers at any time during the year.

If the pamphlets and flyers are distributed during an election period, they are election expenses and can be sent only on behalf of the candidate or the party. Prior written authorization from the official agent, chief agent or a registered agent must be obtained and mentioned in or on the advertisement.

If the pamphlets and flyers are in transit on the day the election is called and the association does not have the ability to stop their delivery, they will not be considered election advertising or election expenses even though the actual delivery will take place during the election period. However, any pamphlets and flyers distributed in the 36 days preceding a fixed-date election will be considered election advertising and election expenses.

Note: Pamphlets and flyers distributed during the pre-election period in the year of a fixed-date general election are partisan advertising. See rules and restrictions in Chapter 7, Partisan Advertising During the Pre-election Period.

Used signs

The registered association may have in its possession signs used in a previous election. If the candidate or party reuses these signs in a subsequent election, the current commercial value of equivalent signs has to be recorded as a non-monetary transfer to the political entity receiving the signs. Transfer rules apply to these transactions.

Example

After an election is called, the financial agent of the registered association obtains the official agent's written authorization to reuse signs from the previous election, promoting the candidate. The current commercial value of the signs is the election expense of the candidate. In addition, the official agent's authorization must be mentioned on the signs.

Billboards

The commercial value, including design, production and installation, of any pre-existing billboards promoting the candidate 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.

Example

The registered association is renting a billboard that promotes the member of Parliament in the riding. The expenses are reported in the association's annual financial return. When a federal election is called and the member of Parliament runs for re-election, the association plans to keep the billboard up to promote the incumbent candidate. The candidate's official agent has to authorize the expenses of the billboard in writing, and the authorization must be mentioned on the billboard. The expenses are election expenses of the candidate.

Registered association's office and assets

The candidate's campaign may use the registered association's office and assets during the election period. Their use is an election expense of the candidate.

For the use of its office, the registered association must send an invoice to the candidate's campaign together with the association's original rental agreement.

If the registered association charges:

  • less than its own rental cost for the period, the difference is a non-monetary transfer from the association
  • more than its own rental cost for the period, the difference is a monetary transfer from the candidate

For the use of its capital assets (computers, printing equipment, etc.), the association must send an invoice equivalent to the commercial value of renting similar assets for the same period.

If the registered association does not charge for the use of its capital assets, the commercial value of renting similar assets for the same period is a non-monetary transfer from the association.

For the use of office supplies (paper, pens, printer toner, etc.), the association must send an invoice equivalent to the commercial value of the items. If the association does not charge the campaign for office supplies, the commercial value of the items is a non-monetary transfer from the association.

Example

The registered association rents office space all year. During the election period, the candidate sublets the office and uses it as a campaign office. The registered association sends the original rental agreement and an invoice to the candidate's campaign for the rent calculated for the election period. The rent paid by the candidate is an election expense of the candidate. The registered association has to report the income in its financial statement at the end of the fiscal year.

Registered association's existing website or web content

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.

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.

Fundraising for a candidate during an election period

If a registered association organizes a fundraising activity during an election period to raise funds for a candidate's campaign, the promotion of the event is election advertising and an election expense of the candidate.

Prior to incurring election expenses on behalf of the candidate, the financial agent of the registered association must receive written authorization from the candidate's official agent. In addition, since this is an election advertising expense, the official agent's authorization also has to be mentioned in or on the promotion—for example, "Authorized by the official agent of John Smith."

The registered association must send a copy of the original supplier invoice for the advertising expense to the candidate's campaign. The candidate's campaign must report the amount as an election expense.

Example

During an election period, the registered association is planning a fundraising event to collect contributions for the candidate's campaign. The financial agent obtains the official agent's written authorization to incur expenses for advertising the event, and the association creates flyers and distributes them in the riding. After the event, the financial agent sends a copy of the original supplier invoice to the candidate's campaign for the expenses incurred for designing, printing and distributing the flyers. The official agent reports the invoiced amount as an election expense.

Voter contact calling services

Voter contact calling services are services involving the making of calls during an election period (but not during a pre-election period) for any purpose related to an election, including:

  • promoting or opposing a registered party, its leader, a candidate, a nomination contestant or any position on an issue with which a party or 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 registered party, a candidate or a nomination contestant

Before incurring expenses for voter contact calling services, the registered association must obtain written authorization from the chief agent, the official agent or the financial agent of the political entity the services are to be acquired for. The association cannot incur expenses for voter calls during the election period on its own behalf.

The registered association must send an invoice, including a copy of the original supplier invoice, to the registered party, the candidate or the nomination contestant. Expenses incurred for voter calls conducted during the election period, including their production and distribution, have to be reported as election expenses (or nomination campaign expenses) by the entity the services were acquired for.

Although voter calls are election expenses, they are not election advertising.

Note: If a registered association provides voter contact calling services to a nomination contestant, the service must be offered equally to all nomination contestants.

Note: A registered association 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 2015-11, Application of Election Advertising Rules to Telephone Calls, on the Elections Canada website.