A compliance plan is your best bet for lobbyist registry success.
In Ontario, the responsibility for lobbyist registration falls to the consultant lobbyist or the senior officer of the organization or for-profit business. Many people may delegate these duties to someone else in their office, and it is essential that those individuals understand what is required. This is where putting a compliance plan in place can help ensure you are meeting the requirements of the Lobbyists Registration Act, 1998.
Lobbyists, senior officers and support staff need to be familiar with the Act, but also how to navigate the registration process. This includes how to search the public registry, how to log into the registration system, how to create a registration and update one. Pro tip: Our videos tutorials can help with those last two items.
What type of information should be included in a compliance plan?
Here are some general best practices to consider:
- Ensure your plan includes information on how to access the registration(s). We are regularly contacted by entities that cannot log in because that information, including passwords and security questions were known only by a former employee.
- Assign clear roles and make sure everyone is aware of their responsibilities. Does the consultant file the initial registration and the support staff file any changes and renew the registration? Will it be the senior officer’s role to review the registration before it is filed?
- Keep track of dates. What day did the lobbying activity start? When did your colleague join your lobbying efforts? You are required to provide this information in the registration form to demonstrate that you are complying with the timelines of the Act.
- Adopt an internal tracking system for your communications with Ontario public office holders and establish a reporting and follow-up system to ensure the information is added to the registration within required timelines. The tracking system should include:
- Changes in lobbying activity. Has the lobbying activity changed? Is there a new goal to the lobbying?
- Changes to who you are lobbying. Are you communicating with a different minister’s office? Are you no longer lobbying that agency?
- Updates to government funding. Has your client/entity received government funding that should be identified in the registration?
- Track the hiring and departures of employees with lobbying responsibilities. This will help to ensure that staff managing a registration can terminate a registration if a consultant has left a firm, for example. Or, if an employee has left an organization, their name must be removed as a current in-house lobbyist and listed as a former in-house lobbyist within 30 days as required by the Act.
- Train new employees so they understand their compliance requirements. Build training about lobbyist registration into your employee onboarding.
Developing a compliance plan with these components will set your firm or organization up for success in complying with the requirements of the Act.
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