By Brett McKay, Local Journalism Initiative Reporter, Investigative Journalism
February 20, 2026
Months after Canada’s federal election, the funding sources for some prominent third-party advertisers remain a mystery. Experts say the political influencers are increasingly finding ways to sidestep election advertising regulations, and in some cases strategically choosing non-compliance.
“Between the comparatively low penalties, the lengthiness of the process, it doesn’t necessarily encourage compliance, especially if you’re a third party that is already antagonistic to this approach that we have to regulating third party finance,” said Andrea Lawlor, an associate professor in the political science department at McMaster University.
In the week before the 2025 federal election was called, third-party advertiser Canada Strong and Proud, also known as Proud to be Canadian, spent between $185,000 and $267,000 on 584 Facebook and Instagram ads promoting Conservative Party Leader Pierre Poilievre and opposing Prime Minister Mark Carney, according to data from the Meta Ad Library. When Parliament was dissolved on March 23, officially kicking off the campaign period during which partisan ads are regulated as political activities, Canada Strong and Proud suspended its campaign.
Elections Canada requires registered third-party advertisers to report information on expenses and contributions for three periods during an election: 21 days before the election, a week before the election and a final return due within four months after election day.
Canada Strong and Proud filed only the second interim financial return, which reports a total of $750 received from two named contributors and just over $2,000 in expenses, primarily for unspecified partisan activities carried out by its network of regional groups, including Alberta Proud, Quebec Fier and Ontario Strong. The group also received $3,175 from anonymous contributors who gave $200 or less.
Heading into the final two weeks of the election campaign, Canada Strong and Proud restarted its online ad blitz, spending between $212,600 and $290,782 on hundreds of Facebook and Instagram ads. Meta logs information about ads related to social issues, elections and politics, providing a record of Canada Strong and Proud’s activity on Meta platforms. It is not known whether the group engaged in other types of advertising or spending on other platforms.
Duff Conacher, co-founder of Democracy Watch, said the example of Canada Strong and Proud highlights several loopholes third parties can use to maximize their influence and minimize transparency.
“One of the problems is not having to report donors under $200. You could say it’s a small problem, but if you have a corporation wanting to funnel money to a third party and not ever have it disclosed, you funnel it through your employees, each giving $199,” he said.
There is also no legislative requirement for third parties to identify the sources of funds for their contributors, he said. During the 2019 federal election, the Manning Centre, now known as the Canada Strong and Free Network, raised and donated more than $300,000 to Canada Strong and Proud and its affiliates, which in turn “only disclosed the Manning Centre as the sole source of the funds.”
Disclosures from the 2021 federal election show that Canada Strong and Proud received more than $78,000 from the oil and gas industry advocacy group the Modern Miracle Network. Along with getting financial support from the Canada Strong and Free Network and the Modern Miracle Network, previousreporting from the IJF found overlap between the members of all three organizations.
‘Dark money problem in Canada’
Though many third parties are active year-round, Elections Canada’s financial disclosure requirements only apply during an election period, which lasts between 37 days and 51 days, when an election doesn’t take place on a fixed date.
“There’s no pre-election disclosure or registration,” Conacher said. “So, we actually have a worse dark money problem in Canada than they do in the U.S.”
“We don’t regulate spending in between elections and have any disclosures. Whereas in the U.S. during election year, they do actually have that disclosure,” he said.
Canada Strong and Proud spent up to $581,044 on political ads placed on Meta platforms in 2025. Only about $290,000 was spent during the official federal campaign period and is subject to reporting requirements. To date, the sources of just $750 in contributions have been disclosed to Elections Canada.
Elections Canada told the IJF that Canada Strong and Proud was granted an extension for its final campaign return, but the return was not received by the Sept. 29 due date.
“When a third party or other political entity isn’t compliant with their reporting obligations under the Canada Elections Act, Elections Canada can refer the case to the Commissioner of Canada Elections, who is responsible for ensuring that the Act is complied with and enforced,” a spokesperson for Elections Canada said.
The Commissioner has the power to investigate whether the Act was contravened and use enforcement measures like administrative monetary penalties or compliance agreements.
Elections Canada said it does not comment on specific referrals, but added that where an entity’s non-compliance is clear, such as reporting obligations not being met, it is “very likely that the case would be referred.”
Canada Strong and Proud did not respond to requests for comment.
Alberta Proud’s Gondek campaign
In the Calgary municipal election campaign in October, Alberta Proud registered with Elections Calgary as a third-party advertiser and spent up to $21,410 on 90 Facebook and Instagram ads opposing former mayor Jyoti Gondek. The group has yet to file any contribution or spending disclosures for its activities during the local election. The first disclosure covering the period between May 1 and July 31 was due Oct. 1.
Third parties that fail to file a required report by the deadline must pay a $500 fine, according to Alberta’s laws governing local elections. Additional penalties may apply if the Election Commissioner finds they are guilty of an offence.
Records from Calgary’s 2021 election show the group received $40,000 from just six corporate donors, all development or construction companies.
‘A pretty low cost to pay for influencing an election’
Most non-criminal violations of federal elections rules are enforced through compliance agreements and administrative monetary penalties. On the low end, this might mean agreeing to turn over missing financial documents and pledging to not repeat the offence. Other violations, including those related to third parties and political financing, may come with baseline administrative monetary penalties ranging from $50 to a maximum of $1,500 for individuals and $5,000 for a corporation or an entity.
Lawlor said that for someone opposed to the limits on political activity imposed by Elections Canada, the perceived benefit of non-compliance may outweigh the repercussions.
“The respective penalties are not very onerous. And perhaps even more to the point, the process of having Elections Canada or an elections management body review these files and give the party a chance to respond and a chance to comply, these are actually quite lengthy processes, so you can really draw it out,” she said.
The Commissioner of Canada Elections has published 16 administrative monetary penalties in 2026, all for violations committed in 2023 or earlier. Several were for violations that occurred during the 2021 federal election.
Conacher suggested that introducing a sliding scale of penalties based on income would be one way to deter abuses of political financing and influence regulations.
“You’re not going to discourage the multi-billion-dollar corporation with a $5,000 fine,” or an individual billionaire with a maximum fine of $1,500, he said.
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“That’s a pretty low cost to pay for influencing an election. Because the upside is getting the party in power that you want in power, which is a huge benefit.”
