Guidance for Lobbyists During and After an Election

The Office often receives questions from lobbyists on whether they need to update their lobbyist registrations during the writ period. The answers below provide general guidance for managing registrations during and after an election.

If you have a question about your specific registration circumstances, contact the Office of the Integrity Commissioner to request an Advisory Opinion.

Am I required to amend my registration(s) during the writ period if my lobbying activities target MPPs?

You do not need to amend your registration simply because the writ period is occurring.

The writ period begins on the day that the election is called and runs until the election is held, usually lasting 28 days. During the writ period, the Legislative Assembly is dissolved and individuals who were MPPs no longer meet the definition of “public office holder.” For that reason, it is not required to list MPPs as lobbying targets on the Members of Provincial Parliament list in your registration(s) during the writ period.

However, to promote transparency and minimize administrative burdens on lobbyists, the Integrity Commissioner, as Lobbyist Registrar, encourages all lobbyists to continue to register their lobbying activities as they normally do. This means that MPPs who were previously identified as lobbying targets on a registration do not need to be removed during the writ period.

What about cabinet ministers and other public office holders listed on my registration(s)?

You must include these public office holders in your registration(s) if you are lobbying them during the writ period.

Cabinet ministers continue in office, throughout the writ period and after, until a new minister is appointed. Ministers are identified by their ministerial office in the Registry (e.g., Office of the Minister Health), which means that the staff of ministers, who are also public office holders, are included in this lobbying target category.

Will I be required to make changes to my registration after the election?

Maybe. This will depend on your lobbying targets.

Members of Provincial Parliament

If one or more of the MPPs you have listed on your registration(s) is not re-elected, then you must review and update your registration.

MPPs are listed by their riding names, but they are often lobbied because of their parliamentary committee activities, Opposition critic role, or their specific interests in an issue. If you are lobbying an MPP for a specific reason that is unrelated to their riding and that MPP is not re-elected, you must remove the MPP from the target lists in your registration(s).

Ministries and Ministers’ Offices

Cabinet minister responsibilities are often changed after an election. You will need to review your registrations after the new cabinet is named to ensure they accurately reflect the ministers’ offices you are lobbying.

Additionally, the structure and names of ministries are sometimes changed shortly after an election. If ministry names change, you will need to review your registration(s) to determine whether the targeted ministries and/or ministers’ offices are listed accurately. 

If a ministry name is changed, your previous selection may be deleted from your registration(s), and it is your responsibility to amend your registration by selecting the new ministry.

Lobbyists must update their registrations within 30 days from the date the ministry name is changed to remain compliant with the Act.

Should I be aware of other compliance issues related to elections?

As noted, MPPs are not considered “public office holders” when it comes to being listed on your registration(s) during the writ period. However, certain provisions of the Members’ Integrity Act, 1994 continue to apply to MPPs who are running for re-election. This includes the prohibition on accepting gifts. Please see our Guidance for Lobbyists on Gifts and Benefits for more information.

If lobbyists take part in political activity, it may affect their ability to lobby in the future. Please see our Interpretation Bulletin #11 “What is a conflict of interest and how does it affect my lobbying?” for further information. 

Lobbyists may contact the Office of the Integrity Commissioner to request an Advisory Opinion with respect to their specific obligations under the Act.