Registration Threshold for In house Lobbyists
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 (LRA).
Under the LRA, employees and paid directors of an entity may be an in-house lobbyist if the combined number of hours spent lobbying exceeds 50 hours a year. This Bulletin assists registrants to determine if they are an in-house lobbyist by explaining the 50 hours a year lobbying threshold.
The term “in house lobbyist” has a special meaning in the LRA.
An in-house lobbyist is an employee of any entity or paid director of a for-profit entity who either individually or collectively spends at least 50 hours in a calendar year lobbying on behalf of the entity.
The 50-hour threshold applies to time spent lobbying, that is communicating with public office holders in an attempt to influence certain government activities. This can include time spent managing grass-roots communication campaigns. (See Interpretation Bulletin #8 for more information on grass-roots communication campaigns)
The 50-hour threshold does not include:
- time spent preparing for such communications such as developing research papers or other resources or
- communications with public office holders that do not trigger a requirement to register under the LRA such as making submissions to a committee of the Legislative Assembly that are a matter of public record or, responding directly to written requests for advice or comments from public office holders.
The 50-hour calculation is not per individual or per subject matter. The 50-hour threshold relates to the combined number of hours spent lobbying by employees or paid directors. It is the responsibility of each entity to keep track of the lobbying activities relevant to determining if the entity has reached the 50-hour threshold.
When an entity determines that it has reached 50 hours, a single registration must be made on the Ontario Lobbyist Registry for the entity under the name of a senior officer, usually the CEO. The Registration must include a description of the lobbying activities that led to the 50-hour threshold as well as subsequent, ongoing lobbying activities within the calendar year. All in-house lobbyists contributing to the 50-hour threshold must be listed on the registration, including the senior officer, if applicable.
This Bulletin applies to the following types of lobbyists:
-in-house lobbyists (organizations) and (persons and partnerships)
-This Bulletin considers the following sections of the LRA: s. 1(1) “lobby”; s.3(2); s. 5(7) and s.6(5) “in-house lobbyist”;
- First issued: March 1, 2011
- Amended: 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.