If you hear people referring to P2D2A, it’s not the latest Star Wars droid, but shorthand for your public policy activities.
The federal government recently changed the Income Tax Act to get rid of the concept of “political activities” by registered charities. All of the public policy work that you do as a charity is now covered by the somewhat unwieldy category of Public Policy Dialogue and Development Activities. Government being what it is, the acronym P2D2A didn’t take long to start floating around.
What exactly does P2D2A refer to?
P2D2A refers to everything a charity might do to influence laws, regulations, or government policies at any level, either in Canada or abroad. This would include: developing proposals for government to change, get rid of, or develop new laws and policies; reacting to government proposals and actions; participating in the process through written submissions, committee appearances, and the like; meeting with elected officials and public servants to advocate for change; and urging the public to get involved in an issue through things like petitions, rallies, or letter-writing campaigns.
Are there any limits on what charities can do politically?
As long as the public policy work you do is in furtherance of your charitable purpose as accepted by the Canada Revenue Agency, there are no longer government-imposed limits on how much of this work you do. As long as your board, donors, and other funders are with you, public policy work is one of the tools you can use to achieve your purpose.
Do we have to track or report our political activities?
Under the old rules, charities had to track and report on their “political activities” in great detail, but it was not always clear on what should be counted, or how their expenses should be calculated to demonstrate their adherence to the 10% limit.
You may have already received the T3010 that you need to fill out for 2018, which has the old political activities questions still on it. The rule changes came too late in 2018 for new forms to be developed, so this may create some confusion.
The Charities Directorate has just issued further clarification and instructions related to filing your T3010 this year. Charities will be asked if they carried out any public policy dialogue and development activities in 2018; those that answer “yes” will be asked to provide a brief narrative summary of what those activities were and how they relate to the organization’s charitable purpose. Questions about the amounts spent, the types of resources used, and other detailed financial information should not be answered and they are no longer relevant.