Foreign Influence Transparency and Accountability Act (FITAA)

Overview

The Foreign Influence Transparency and Accountability Act (FITAA) came into effect on August 4th, 2026. This federal legislation is intended to increase transparency and visibility of foreign influence in Canadian political and governmental processes, and applies to a range of activities undertaken at the University of Waterloo. 

  • FITAA generates legal obligations: FITAA requires individuals and organizations to register arrangements with foreign principals where the aim of the arrangement is to influence a Canadian political or governmental process. These obligations apply to the University and its employees. Failure to register risks administrative monetary penalties or criminal prosecution. 
  • Any potential registration must be discussed with the institution prior to registration. Contact: uw-fitaa@uwaterloo.ca for guidance. 

The information on this webpage is intended to raise awareness of registration requirements and processes at the University of Waterloo. For more information, the website of the Office of the Foreign Influence Commissioner includes an overview of the registration process, a list of frequently asked questions, guidance on how to register, and a questionnaire to help you determine whether you need to register.


About FITAA

FITAA does not prohibit any activities. It requires disclosing information about some arrangements with foreign principals on a public registry. Failure to register risks administrative monetary penalties or criminal prosecution.  

FITAA established the Office of the Foreign Influence Commissioner and a public registry of foreign influence activities. FITAA requires individuals or organizations in Canada, including universities and members of the university community, to register if they have entered into an arrangement with a foreign principal to engage in influence activities aimed at a Canadian political or governmental processes.

Diagram showing that Foreign Influence Arrangement is composed of Foreign pricipal, influence activity and political/government process, which together equals registration obligation

Not every relationship or agreement with a foreign principal must be registered under FITAA.
A registration obligation arises when an arrangement satisfies all three of the following elements:

1. There is an arrangement with a foreign principal.

Arrangements can be written or unwritten, formal or informal, and may or may not require employment, contractual, or membership relationships or obligations. Examples of arrangements can include research agreements, funding agreements, donations, in-kind contributions, partnerships, and other activities or forms of support that are common in academic collaborations.

‘Foreign principals’ does not mean all foreign entities. For instance, it does not include most foreign universities or most privately owned foreign businesses. It does include state granting agencies, state-owned or state-controlled universities, and state-owned or state-controlled businesses.

Foreign principals can include:

  • Foreign states – country, province, territory, state, or city outside of Canada.
  • A foreign government department or ministry.
  • A foreign government research agency or funding body.
  • A state-owned or state-controlled university, academic institution, or research institute.
  • A foreign economic entity: a business or organization owned or controlled by one or more foreign states.
  • A cultural group, non-governmental organization, media outlet, charity, etc., owned or controlled by one or more foreign states.

2. The arrangement involves an influence activity.

‘Influence activities’ can include many activities undertaken at the University. Most significantly, it can include:

  • Disseminating information through academic publications, conference presentations, public lectures, media interviews, and social media. 
  • Communicating with a public office holder by responding to government consultations, contributing expertise to advisory bodies, sharing research with government, or providing advice or recommendations to government.
  • Providing money, services, use of facilities, or other things of value. 

3. The activities are in relation to a Canadian political or governmental process.

The occurrence of an influence activity, with or without the involvement of a foreign principal, does not alone trigger a registration obligation where the activity does not relate to a Canadian governmental or political process. Similarly, engagement with a foreign partner or receipt of foreign funding does not automatically trigger a registration obligation. 

In order to qualify, the arrangement must be to undertake influence activity that aims to influence a Canadian political or governmental process at the federal, provincial/territorial, or municipal level. 

‘Political or governmental process’ includes the following:

  • Any proceeding of a legislative body.
  • Development or amendment of legislation, policies, or programs.
  • Funding decisions on government grants or contracts.
  • Regulatory or licensing decisions.
  • Immigration, health, education, or economic programs.
  • Decisions by ministers, departments, agencies, or government bodies.
  • Political processes, such as elections, referendums, party leadership contests, or political party activities.

Depending on the specifics of a given arrangement, FITAA may apply to a range of University of Waterloo activities, such as:

  • International institutional partnerships/agreements.
  • Corporate or other forms of sponsored research partnerships.
  • Funding from foreign government entities.
  • Donations/advancement activities.
  • Policy research.
  • Conferences, events, social media communications, and other forms of public engagement.
  • Other activities involving foreign principals.

The University must ensure all applicable arrangements are registered. Registerable arrangements can be between a foreign principal and the University as an institution (including Faculties, Departments/Schools, Centres and Institutes, and other administrative units), or they can be between a foreign principal and an individual faculty member acting in their capacity as an employee of the University. 


Registration Process

The formal registration process is extensive and requires detailed information about both parties of the arrangement. Refer to the Commissioner’s document here on what you’ll need to register.

Prior to beginning the registration process for any arrangement, first contact uw-fitaa@uwaterloo.ca for guidance.

Some registerable arrangements are between a foreign principal and the University of Waterloo as an institution (including Faculties, Departments/Schools, Centres and Institutes, and other administrative units). Others are between a foreign principal and an individual faculty member. In both cases, the University must ensure all applicable arrangements are registered.

Institutional arrangements will be processed by the Office of Research, with significant contributions from employees in the relevant unit. If you are aware of any potential institutional arrangements in your unit, please contact uw-fitaa@uwaterloo.ca for guidance.  

Individually-initiated arrangements include research collaborations/partnerships between individual faculty members and foreign principals, along with funding from foreign principals, including state granting agencies. Faculty members who enter into individual registerable arrangements are required to register such arrangements themselves through the Office of the Foreign Influence Commissioner’s website. Prior to registering on federal government’s website, individual faculty members must contact the Office of Research for guidance, via uw-fitaa@uwaterloo.ca.

Note: In some cases, faculty members may enter arrangements independently of their employment with the University e.g. in their personal capacities or when acting on behalf of a third-party. In such cases, the University is not responsible for registration. However, if it is unclear to a faculty member whether they are acting in their capacity as an employee of the University or not, they must consult the Office of Research for guidance.


Key dates

New registerable arrangements must be registered within 14 days of the arrangement becoming active.


Obligations for University of Waterloo units and researchers

Individual researchers must:

  1. Be aware of their obligations under FITAA.
  2. Contact uw-fitaa@uwaterloo.ca for guidance about any potentially registerable arrangement, including research partnerships, collaborations, or external funding.
  3. Register applicable arrangements with the Office of the Foreign Influence Commissioner only after consulting with the Office of Research  FITAA team. 
  4. Be mindful that FITAA may also apply to arrangements faculty members enter into independently of their employment with the University e.g. in their personal capacities or when acting on behalf of a third-party. (For instance: individual consulting work outside of their role as a University of Waterloo faculty member.)

Administrators in Faculties, Departments/Schols, Centres and Institutes, and other administrative units must: 

  1. Be aware of their obligations under FITAA.
  2. Review active and pending arrangements (e.g., contracts, sponsored research agreements, international partnership agreements, funding arrangements, donations/advancement activities) against the three-part FITAA test above.
  3. Contact uw-fitaa@uwaterloo.ca for as early as possible for guidance about any potentially registerable arrangement and for clarity on which active and pending arrangements they are responsible for reviewing.
  4. Compile an inventory of potentially registrable arrangements within their unit and seek internal guidance from the Office of Research FITAA team on potentially registerable arrangements involving foreign principals. Information related to each arrangement should be communicated to the Office of Research FITAA team using the submission criteria for formal registration using the internal FITAA disclosure document.
  5. Maintain an up-to-date inventory of potentially registrable arrangements and be mindful of the 14-day registration obligation for any new arrangements.

Compliance and Enforcement

Information in the Registry will be publicly available and visible. Although the FITAA regime intends to focus on compliance rather than punitive measures, non-compliance with FITAA may result in administrative monetary penalties ranging from $250 up to $1,000,000, and could result in criminal prosecution. FITAA violations will also be publicly reported, including the name of the person involved, the violation, and the penalty issued.


FAQ

Does every international collaboration need to be registered?

No; collaborations do not need to be registered unless the collaboration involves:

  1. a foreign principal;
  2. an influence activity; AND
  3. a Canadian political or governmental process

Examples of a Canadian political or government process may pertain to a Canadian law, policy, regulatory proposal, government decision, etc.; these examples are non-exhaustive.

Does receiving foreign funding automatically require registration?

No; foreign funding alone does not automatically require registration. The funding must involve a foreign principal, an influence activity, and a Canadian political or governmental process. Examples of a Canadian political or government process may pertain to a Canadian law, policy, regulatory proposal, government decision, etc.; these examples are non-exhaustive.

Does communicating with government agencies as part of academic researcher require registration?

Communicating with government agencies does not automatically trigger registration obligations under FITAA. Registration depends on the involvement of a foreign principal, an influence activity, and a Canadian governmental or political process. Examples of a Canadian political or government process may pertain to a Canadian law, policy, regulatory proposal, government decision, etc.; these examples are non-exhaustive.

Does FITAA prohibit work with foreign governments or state-linked universities and research organizations?

No; requirement for registration under FITAA does not necessarily indicate that the arrangement is prohibited or inappropriate. FITAA intends to make registerable arrangements transparent. Be mindful that other legislation, policy, and guidelines – such as sanctions prohibitions, export controls, the Policy on Sensitive Technology Research and Affiliations of Concern (STRAC), the National Security Guidelines for Research Partnerships (NSGRP), and the Ontario research-security framework – may separately apply to the arrangement.

Can an informal relationship constitute an “arrangement” under FITAA?

Informal and unwritten arrangements may still require disclosure. Arrangements do not need to be in the form of a formal, written contract.

Will the University of Waterloo register arrangements on behalf of researchers?

The University of Waterloo will coordinate registration of arrangements that directly involve the University as a party to the arrangement. Individuals are responsible for registering their own arrangements; prior to registering, individual faculty members are required to contact the University of Waterloo FITAA Team at uw-fitaa@uwaterloo.ca.

What if I already have an arrangement that may meet the requirements?

Please contact the University of Waterloo FITAA Team (uw-fitaa@uwaterloo.ca) as soon as possible. New arrangements entered into after August 4, 2026 must be registered within 14 days. Existing arrangements that were in place prior to August 4, 2026 were due for registration by October 3, 2026.

Do I need to re-submit the internal University of Waterloo disclosure form or federal registry, if my arrangement status changes after I have already submitted a disclosure?

The University of Waterloo registration form allows you to edit the form; responses can be saved and resubmitted.

The Federal registration form allows you to update the status of an arrangement by logging back into the portal and selecting the most applicable option.

What information do I need to provide when I register?

The FITTA registry requires detailed information about the parties involved and about the arrangement and activities. This includes:

  • Personal information for all Waterloo participants (names, address, phone and email, date and place of birth),
  • Organizational information (registration/incorporation number, websites, parent companies),
  • Information about the foreign principal (names and addresses for foreign representatives, addresses, organizational identity details),
  • Information about any contact with public office holders (identity, jurisdiction, and position of office holder),
  • Information about the arrangement (start and end dates, compensation, financial benefits, in-kind support),
  • Details about the influence activities (government process being influenced, target audience, intended outcome, foreign principal objectives, forms of public communication carried out) and
  • Information about financial compensation, services provided,  and facilities and infrastructure support.