Bulletin #1

Determining who is a Public Office Holder

The Integrity Commissioner as the Lobbyists Registrar maintains an online public record of lobbyists and conducts investigations into non-compliance with the Lobbyists Registration Act, 1998.


Under the LRA anyone who lobbies a “public office holder” must register with the Integrity Commissioner. This Bulletin assists registrants to determine whether they are lobbying a public office holder.



The term “public office holder” has a special meaning in the LRA. The following individuals are public office holders under the LRA:

-          an employee of a ministry of the Government of Ontario,

-          a minister,

-          an employee in a minister’s office,

-          a Member of Provincial Parliament (“MPP”),

-          an employee in an MPP’s office,

-          a member of the Ontario Provincial Police Force,

-          an officer, director or employee of Ontario Power Generation Inc. or its subsidiaries,

-          an officer, director or employee of Independent Electricity System Operator,

-          an officer, director or employee of a public body listed in O.Reg. 146/10 under the Public Service of Ontario Act, 2006

An officer, director or employee of other entities MAY be public office holders if the entity has a governing body with Government of Ontario appointees. Entities that have governing bodies with Government of Ontario appointees may be identified by reviewing the enabling statute of an entity (if applicable), reviewing the “agencies list” on the website of the Public Appointments Secretariat* or requesting an Advisory Opinion from the Commissioner. 



This Bulletin applies to the following types of lobbyists:

-consultant lobbyists
-in-house lobbyists (organizations) and (persons and partnerships)

Relevant Legislation

This Bulletin considers the following sections of the LRA:  s.1(1) “lobby”, “public office holder”; s.1(3); 4(4) paragraphs 12 and 13; s5(3) paragraphs 13 and 14; and, s. 6(3) paragraphs 12 and 13. 


-First issued: March 1, 2011.

-Amended on: June 4, 2015; July 1, 2016.


The Registrar may issue an interpretation bulletin with respect to the enforcement, interpretation or application of the LRA as set out in section 15 of the LRA. It is intended solely to provide information and is not a substitute for independent legal advice. This Bulletin is not a binding statement of how the legislation will be interpreted or applied in a particular circumstance. Final interpretation of the law is the responsibility of the courts.

Copyright © 2019 Office of the Integrity Commissioner.
All Rights Reserved.