Time to Act on Foreign Interference: Implementing Hogue Commission's Blueprint
Implement Hogue Commission's Blueprint on Foreign Interference

The public inquiry into foreign interference has replaced rumour with a record. Across six volumes, Commissioner Marie-Josee Hogue described a threat that is methodical and layered. Foreign interference in Canada is aimed less at ballot boxes than at the conditions that make elections meaningful: confidence, participation, and the integrity of the information citizens use to make political choices.

The Question Is No Longer Whether Canada Has a Problem

It is whether governments and institutions will enforce what is already on the books, follow through on the low-friction fixes the commission set out, and tackle the harder structural gaps that still leave Canada exposed. Volume 5 is blunt: Many measures can and should be implemented quickly, with progress reported to Parliament within a year. Others require deeper redesign but build on structures the commission calls “well thought-out, sound and efficient.”

What to Know About Bill C-70

Parliament passed the Countering Foreign Interference Act (Bill C-70) in 2024, creating the Foreign Influence Transparency and Accountability Act and a public foreign influence registry run by an independent commissioner. The premise is straightforward: Those who undertake political or governmental activities in Canada under the direction, control or influence of a foreign state or related entity must disclose that relationship through registration. The law creates narrow exemptions and a mix of administrative penalties and criminal offences to deal with false declarations and serious violations. On paper, this is the centrepiece of a modern transparency regime.

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In January 2026, draft regulations finally appeared in the Canada Gazette and a 30-day consultation opened. Those regulations spell out basic definitions, what information must be filed, how the registry will function, and how penalties will work. They are about mechanics: Who has to register, what they must disclose, and how non-compliance will be sanctioned. They say much less about how Canadians can complain or seek redress if they suspect covert foreign influence. A first commissioner has now been proposed. Even so, as of early 2026, the regime is still not fully operational.

The Registry Is Necessary but Not Sufficient

The inquiry makes clear that the registry is necessary but not sufficient. Volume 2 recounts how the “Plan to Protect Canada’s Democracy” created the Security and Intelligence Threats to Elections Task Force. It also created the Critical Election Incident Public Protocol, the five-person panel that can speak publicly during a campaign. Commissioner Hogue largely agreed that these mechanisms were tuned to broad, system-wide interference and were not designed to capture the kind of human, riding-by-riding pressure that has emerged as the greatest risk. She called for clearer priorities for the task force, more flexible tools for the panel, and stronger involvement by Global Affairs on offline as well as online activity.

The Information Environment

Volume 3 turns to the wider information environment. It describes how research networks were set up to monitor political information flows and flag serious “information incidents” during elections. This capacity matters because responsibility is often difficult to establish in real time, even though the harm can be immediate. The Commission also notes how fragile this ecosystem remains. Funding is uncertain, and researchers often lack access to basic platform data, including data on reach, engagement, coordinated activity, and content circulation. Stable support and lawful data access are not luxuries. They are preconditions for credible public analysis of foreign interference.

Taken together, the volumes argue that defending democracy now means defending the information conditions under which citizens reason together. Volume 5 translates that theme into a plan. It calls for a clear national strategy on foreign interference and, just as importantly, a government-wide communications strategy that is in place before the writ drops. Canadians should know who will speak, when, and on what evidentiary basis. They should know how rumour control will work, and how governments will share more, earlier, without burning sensitive sources. Opacity breeds mistrust and leaks. Clarity breeds resilience.

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What Is Now Required

A serious response has two tracks. The first is immediate and mostly administrative. As the foreign influence law and its regulations are in force, now is the time to confirm the commissioner and give the new office the tools it needs. Publish simple, plain-language guidance for people and organizations who may need to register. The design has been debated for years. Every month that the law sits dormant creates space for malign actors to test the system.

The second track is precision rewiring. The panel of five senior public servants (who have to be independent) needs options between silence and a single, dramatic public announcement. The inquiry recommends pre-writ transparency about how the panel works, and a set of intermediate communication tools for use during a campaign. It also urges governments to align the election task force with the threat profile Canada actually faces. It includes riding-level activity, and improvement the timing and detail of security briefings to parties and parliamentarians. This narrows the gap between ambiguous intelligence and live politics, so that decisions are not left to leaks and late-night speculation. It is important to keep in mind that foreign interference does not happen simply after the writ is dropped. It is an ongoing process.

Nominations and Leadership Races

The inquiry is equally frank about the “front door” to Parliament: Nominations and leadership races. The record shows inconsistent rules and opaque practices that are easy to exploit. The commission points toward some pragmatic solutions, including basic identity checks. It also includes the requirement for transparent procedures when thousands of memberships are sold at once. It calls for audit trails for bulk purchases. It requires the duty to receive security briefings when credible risks are flagged.

The same logic applies to domestic open-source monitoring. The commission recommends a lawful, privacy-respecting capacity within government to track public information relevant to election integrity, the ability to work with research networks and platforms, and the ability to speak quickly and credibly when major information incidents arise. Coupled with Elections Canada’s work on tools to verify and label altered political content, this would give voters a baseline: A place to check whether they are dealing with truth, spin, or fabrication, without policing opinion or debate.

Transnational Repression

Transnational repression runs through the volumes as a constant concern. The inquiry documents how intimidation of Canadians, often through pressure on relatives abroad or attempts to capture community leadership, deters participation. Prosecutions will always be difficult. But existing sanctions and domestic powers can impose real costs on foreign officials and proxies who try to export repression onto Canadian soil. That requires a willingness to use those tools and to call this conduct what it is.

Finally, during the hearing it became apparent that there was no robust complaints intake process. Complaints were raised but they went nowhere. The current Act does not address this. It is simply a registry process, seemingly based on the lobbyist registration process. This does not take into consideration that the issues involved in transnational repression are far more complex and insidious.

What Canadians Should Watch For

Moving forward, what should Canadians watch for as a reality check? Three signals stand out. First, a foreign influence commissioner who is actually in office and a registry that is live, searchable, and backed by clear rules and service standards well before the next federal election.

Second, a concise public strategy on foreign interference, paired with an election communications protocol that explains in plain language how early warnings, rumour control, and any possible panel statements will work.

Third, visible, funded observatories and research networks issuing regular public briefs during campaigns, based on timely and lawful access to data. If those pieces are in place, hostile states and their proxies will have less ambiguity to exploit, and Canadians will have more evidence to rely on.

Foreign interference is adaptive and opportunistic. It is often designed to force the very dilemmas Canadians fear most: Speak on incomplete information and risk being seen as partisan, or say nothing and watch corrosive stories harden into “truth.” The Hogue Commission cannot solve those dilemmas, but it shows how to narrow them: Publish the rules, share more and earlier, put independent analysis in the open, and enforce the laws Parliament has already passed.

The Hogue Commission has provided much of the blueprint — it is now time to fully implement.

Malliha Wilson was counsel for the Churchill Society for the Advancement of Parliamentary Democracy at the Hogue Inquiry into Foreign Interference. Janakan Muthukumar is a PhD student at Carleton University.