Interpretation Bulletin #3A

Does my business have to register?



Summary

If you are the senior officer of a for-profit organization (a business), you may need to register your business’s lobbying activity. This Bulletin explains when.



Interpretation

You, or your staff, are lobbying when you communicate with anyone in government to try to influence:
- a law or regulation
- a government policy or program(s)
- the transfer of a government asset, good or service to the private sector
- a government grant, contribution or other financial benefit.

For more information about what is lobbying, see Interpretation Bulletin #1 "Am I lobbying?".

For information about not-for-profit organizations, see Interpretation Bulletin #3B "Does my not-for-profit organization have to register?".

You are responsible for registering if you are the senior officer
You are the senior officer if you are the most senior paid officer or employee, e.g. the CEO. 

If you are the senior officer, you must register when:
- One or more paid employees, officers or directors (i.e. a Board member) lobby the government of Ontario, and

- The paid employees, officers or directors collectively spend 50 hours or more lobbying in the year.

Note: If your employees, officers or directors lobby for a subsidiary or parent company of your business, count their lobbying as part of your business’s 50-hour lobbying threshold.

The steps you must take as senior officer
As senior officer, you need to:
- Keep track of how much time all paid staff, officers and/or directors are lobbying

- Make sure to count your own time spent lobbying 

- Once your paid staff, officers and directors have lobbied for 50 hours in a calendar year, register online within two months. Your paid staff, officers and directors who lobby are called “in-house lobbyists” on the registration. 


Application

This Bulletin applies to the following types of lobbyists:
- in-house lobbyists (persons and partnerships)



Relevant Legislation

Lobbyists Registration Act, 1998
- s. 1(1) “lobby”
- s. 5(1) and (7) 



History

First issued: March 1, 2011
Amended: July 1, 2016; March 30, 2020

This Bulletin was previously published as Interpretation Bulletin #3, "Registration Threshold for In-house Lobbyists".


Authority

The Lobbyists Registration Act, 1998, makes sure that lobbying in Ontario is transparent and ethical. The Integrity Commissioner, as the Lobbyists Registrar, maintains an online public record of lobbyists and conducts investigations into non-compliance with the Act. The Registrar may issue a bulletin about the interpretation or application of the Lobbyists Registration Act, 1998

This Bulletin provides general information. It is not legal advice. It is not a binding statement of how the Integrity Commissioner will interpret the law.

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