Does my not-for-profit organization have to register?
Interpretation Bulletin #3B
If you are the senior officer of a not-for-profit organization, you may need to register your organization’s lobbying activity. This Bulletin explains when.
You, or your staff, are lobbying when you communicate with anyone in government to try to influence:
- law or regulation
- government policy or program
- transfer of a government asset, good or service to the private sector
- government grant, contribution or other financial benefit.
For more information about what is lobbying, see Interpretation Bulletin #1 "Am I lobbying?".
For information about for-profit organizations, see Interpretation Bulletin #3A "Does my business 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 Executive Director.
If you are the senior officer, you must register when:
- One or more paid employees (employees include officers, e.g. the Executive Director) lobby the government of Ontario, and
- All paid employees collectively spend 50 hours or more lobbying in the year
All types of not-for-profit organizations must register, including charities, professional associations and unions, if you meet the above requirements.
The steps you must take as senior officer
As senior officer, you need to:
- Keep track of how much time all paid employees are lobbying
- Make sure to count your own lobbying
- Once all paid employees have lobbied for 50 hours in a calendar year, register online within two months. Your paid employees who lobby are called “in-house lobbyists” on the registration.
This Bulletin applies to the following types of lobbyists:
- in-house lobbyists (organizations)
Lobbyists Registration Act, 1998
- s. 1(1) (“lobby”) (“organization”)
- s. 6(1), (5)
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".
The Lobbyists Registrations 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.