Representations to government as a charitable activity

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Given their unique perspectives and expertise, it is recognized that charities make a valuable contribution to the development of public policy in Canada.
The provisions of the Income Tax Act related to political activities are not meant to restrict the contribution of charities to public policy. Therefore, if a charity makes a representation to an elected representative or public official, with or without an invitation, this will generally be considered as a charitable activity. For more information, see section 7.3 of Policy statement CPS-022, Political activities.
Representations to elected representatives or public officials must:
- only be undertaken as an activity that is subordinate to a charity’s charitable purposes
- relate to an issue that is connected to the charity's purposes
- be well-reasoned
- not contain information that the charity knows or ought to know is false, inaccurate, or misleading

If making representations becomes a charity’s sole or primary activity, the Canada Revenue Agency (CRA) would likely conclude that the charity had adopted either a collateral, non-charitable purpose or a political purpose. The charity could then be subject to compliance measures, including suspension of its tax-receipting privileges, or revocation of its charitable status.
If a charity made a representation that was not connected to its charitable purposes, the CRA would also likely conclude that this was not an acceptable use of resources. For example, if a charity were registered with the sole charitable purpose of advancing education by providing scholarships, yet made representation to a government calling for a reduction in general sales taxes, the CRA would not consider this representation to be connected to its charitable purposes.
Finally, a representation must always be non-partisan. It must never include any direct or indirect support or opposition to a candidate or political party.

Whether a representation meets all the criteria described in section 7.3 of Policy statement CPS-022, Political activities, will always depend on the specific facts of the individual case. Examples of representations that, depending on the circumstances, might meet all the criteria include:
- a meeting at a member of Parliament’s office where a charity delivers an oral argument urging the member to support legislation that is related to the charity’s charitable purpose
- a presentation delivered to a public official at a charity’s headquarters to explain the charity’s findings on a public policy issue that relates to the charity’s purposes and call for a government policy to be changed
- an appearance before a parliamentary committee to speak about a charity’s experiences in its field of operations and to urge the committee to support/amend proposed legislation
- a presentation at a municipal government town hall meeting to provide a charity’s views on the benefits to its programs of proposed changes to a municipal bylaw and call for the changes to be implemented

Releasing the text of a representation before or after delivering it to the elected representative or public official will be considered a charitable activity provided that the entire text is released and there is no explicit call to political action either in the text or in any reference to the text.
The charity may issue the entire representation to the public by press release; its website; or explaining in a newsletter that it intends to make, or has made, the representation and is willing to distribute the information to anyone who wants a copy.
In all cases, the entire representation should be made available.
Should a charity make an explicit call to political action in any part of this representation or in reference to it, the activities could be regarded as political activities and, as a result, all resources and expenditures associated with these activities could be considered to have been devoted to a political activity.