On August 27, 2026, the Government of Quebec officially called the general election, which will lead voters to the polls on October 5. As with every election campaign, companies, associations, and organizations ask whether their government relations activities can continue and if the rules applicable to lobbying change during this period.
The short answer is that the calling of an election does not suspend the application of the Lobbying Transparency and Ethics Act. Lobbying activities can generally continue, and several public office holders continue to perform their duties during the election campaign.
However, the dissolution of the National Assembly and the electoral context change certain important parameters that organizations active in public affairs should keep in mind.
The Calling of an Election Does Not Suspend the Application of the Lobbying Act
The Lobbying Transparency and Ethics Act continues to apply throughout the entire election period. Registration, transparency, and ethics obligations remain in effect, and activities aimed at influencing certain government decisions continue to constitute lobbying activities within the meaning of the law. Companies, industry associations and other organizations active in public affairs therefore do not benefit from any particular suspension or exemption solely because an election campaign is underway.
MNAs During an Election Period: A Special Status
The dissolution of the National Assembly brings Members of the National Assembly’s parliamentary mandates to an end. Subject to the exceptions described below, Members of the National Assembly therefore generally cease to be public office holders for the purposes of the Lobbying Transparency and Ethics Act. They then become candidates or prospective candidates rather than sitting parliamentarians.
This distinction is important for organizations that regularly interact with provincial elected officials.
Communications with a candidate for election do not necessarily raise the same issues as communications with a public office holder acting in the exercise of official duties. As discussed further below, communications with ministers and other public office holders whose functions continue during the election period remain subject to the lobbying regime, whereas communications with individuals acting solely as election candidates are generally not covered by the Lobbying Transparency and Ethics Act.
Who Remains a Public Office Holder During the Campaign?
This is often the most important practical question for lobbyists during an election period.
The dissolution of the National Assembly does not mean that all public office holders immediately cease to hold office for the purposes of the law. Several categories of public office holders continue to perform their duties throughout the election period.
Accordingly, in general:
- the President of the National Assembly and the Vice-Presidents of the National Assembly remain public office holders;
- ministers remain in office until a new government is sworn in;
- deputy ministers remain in office;
- public servants continue to perform their duties;
- government agencies generally continue their administrative activities; and
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public bodies and government institutions generally continue their operations.
As a result, many communications that constitute lobbying activities may continue during the election campaign.
Can We Continue To Meet with Ministers And Public Officials?
In many cases, yes.
Organizations can generally continue to engage with ministers, government departments and public bodies regarding administrative or regulatory matters that remain active during the election period. Importantly, where such communications seek to influence decisions covered by the Lobbying Transparency and Ethics Act, the lobbying rules continue to apply notwithstanding the election campaign.
In addition, while this is not a lobbying-law prohibition, the election period is generally associated with caretaker-type restraint by an outgoing government. Ministers and their offices may therefore be more cautious about new announcements, significant discretionary decisions, appointments or commitments that could bind a future government, while routine administrative business continues. For a more detailed discussion of this convention in the federal context, see our prior bulletin on the caretaker convention.
As such, in practice, however, organizations often find:
- a slowdown in certain decision-making processes;
- the postponement of certain government announcements;
- greater caution on the part of ministerial offices;
- the postponement of certain decisions with a significant political dimension.
However, these are more administrative and policy considerations than prohibitions arising from lobbying rules.
Accordingly, organizations should not assume that the election period suspends their lobbying obligations. Communications with ministers, deputy ministers, public servants and other public office holders may continue to constitute lobbying activities and remain subject to the applicable registration, transparency and ethics requirements.
Are Candidates In Elections Public Office Holders?
Not necessarily. As noted above, the dissolution of the National Assembly generally brings Members of the National Assembly’s parliamentary mandates to an end. As a result, they cease to be public office holders for the purposes of the Lobbying Transparency and Ethics Act. Simply being a candidate in an election does not, in itself, confer public office holder status.
Communications with a person acting solely as an election candidate are therefore generally not subject to Québec’s lobbying regime. Such communications may nevertheless raise other legal, political or reputational considerations, including under election financing, contribution, gift, benefit or conflict-of-interest rules.
Organizations engaged in government relations should nevertheless distinguish between communications with a candidate who does not hold a public office and communications with ministers or other public office holders whose functions continue during the election period, including the President of the National Assembly and the Vice-Presidents, since only the latter may continue to be subject to the lobbying regime.
Post-Employment Rules Remain Important
The election campaign is also an appropriate time to revisit the restrictions that apply to certain former public office holders.
Indeed, individuals who have held governmental or parliamentary positions may remain subject to post-employment restrictions that limit, for a specified period, their ability to engage in lobbying activities.
For example, former ministers, the Government Chief Whip, the Government House Leader and the Government Caucus Chair may, for a period of two years following their departure from office, be prohibited from engaging in lobbying activities before their former public institutions or before institutions with which they maintained official, direct and significant dealings. In certain circumstances, they may also be prohibited from acting as consultant lobbyists during that same two-year period.
Former deputy ministers, associate and assistant deputy ministers, ministerial staff members and certain other senior public office holders may be subject to similar restrictions for a period of one year following their departure from office.
Organizations considering the recruitment of former ministers, political staff members, senior public servants or other former public office holders should therefore ensure that any applicable restrictions are respected and that the contemplated duties are consistent with the applicable post-employment rules.
To assist organizations in navigating these requirements, Lobbyisme Québec provides a practical tool that outlines the restrictions applicable to different categories of former public office holders: Post-Employment Rules – Lobbyisme Québec.
Conclusion
The calling of a general election changes the political landscape, but it does not suspend lobbying activities or the application of the Lobbying Transparency and Ethics Act. Several public office holders continue to perform their duties, ministries continue their administrative activities, and organizations can generally continue to carry out their usual government relations activities.
However, the election campaign remains a unique period where the distinction between ministers, public servants, outgoing members of the National Assembly, and candidates becomes increasingly important. Organizations active in public affairs would therefore benefit from reassessing their engagement strategies to take into account the specificities of the electoral context and the guidelines published by Lobbyisme Québec.
