In this issue...

• Compliance Check: Providing additional information
• Understanding the lobbying restriction under BPSAA
• The More You Know: Parent companies and subsidiaries

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Providing additional information

As part of our review process, you may have received an email asking for additional information regarding your registration. While the onus is on lobbyists and senior officers to meet the requirements of the Lobbyists Registration Act, 1998 our Office assesses new and existing registrations to make sure they are clear and accurate before they are published.

If a registration is incomplete or if the information is vague or out-of-date, Office staff will contact the lobbyist or senior officer and their “primary contacts” (individuals delegated by the lobbyist or senior officer to manage the registration) to make the necessary changes within a specified time frame. Please note that Office staff can only provide general guidance and are not able to advise you on what specifically to include in your registration. It is your responsibility to provide an accurate description of your lobbying goals.

We also routinely perform compliance checks on timelines to ensure that registrations were filed and renewed within the required timeframes of the Act and may ask about the date the lobbying activity started.

The main objective of our review process is to not only encourage compliance with the Act but to ensure that anyone who views a published registration can clearly understand what a business or organization is trying to accomplish through lobbying.

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Understanding the lobbying restriction under the Broader Public Sector Accountability Act, 2010

Who: Consultant lobbyists are prohibited from lobbying for a client if that client is a designated broader public sector organization and pays the consultant lobbyist for their lobbying services with public funds. If one of these entities hires a consultant lobbyist who is paid using public funds, the consultant lobbyist would be in breach of section 3.1 of the Lobbyists Registration Act, 1998. This is explained in more detail in Interpretation Bulletin #4: “Can my client pay me with public money?”

Consultant lobbyists can lobby on behalf of a broader public sector client only if the client pays them with other funds. This must be attested to by the client.

When: When filing an initial registration for a client that meets the criteria in section 4 of the Broader Public Sector Accountability Act, 2010, the consultant lobbyist must also provide an attestation signed by the head of the client organization at the same time. A new attestation is required at each annual renewal of the registration.

If the attestation is not provided when the registration is submitted, the registration may not be published on the Lobbyists Registry.

How: The attestation form can be downloaded during the registration process when a consultant lobbyist answers ‘yes’ to the Broader Public Sector Accountability Act question. The signed attestation form can be sent by email (the client’s electronic signature is acceptable). The attestation form is also available on our Resources page.

If you have any questions about the Broader Public Sector Accountability Act or the attestation, please contact us.

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Check the family tree: parents and subsidiaries

Consultant lobbyists should always check with their for-profit client to ensure they have the correct information about the client’s corporate structure. This information should be included under the “Additional Client Information” section of the registration.

For companies that have an In-house Persons and Partnerships registration, required information about parent companies and subsidiaries must be included in the “Additional Company Information” section of the registration.

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