ON Lobbying - a newsletter

Information & Resources for Lobbyist Registration in Ontario

Issue 30

August 2023

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When Your Client is an Association or a Coalition

Consultant lobbyist registrations are required to provide certain information about the clients. For example, Issue 29 of this newsletter covered what should be included when for-profit entities have, or are subsidiaries of other corporations. But what about not-for-profit organizations that are made up of other entities?

If your client is not a business or for-profit entity, you should check to see if, and how, it meets the definition of “organization” in the Lobbyists Registration Act, 1998. If it is an association or a coalition, you will need to provide information about the businesses or other types of entities that form the membership of the client. Pay close attention to the following prompts in the registration form under “Additional Client Information”:

If your client is an organization, provide the business name and address of each partnership, corporation or entity that is part of the organization.

If your client’s activities are controlled or directed by a third party with a direct interest in the outcome of your lobbying activity provide the name(s) and address(es).

When your client’s membership is made up of individuals, it is not necessary to list their names and addresses, however, you should explain the membership structure of the entity in the “Describe your client’s business” section of the registration.

You can always contact the Office if you have questions about what information to provide about a specific client.

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Who is the Senior Officer?

Under the Act, a senior officer is the most senior employee of an entity who is paid for the performance of his or her duties. Note: The senior officer does not have to receive the highest salary or payment within the entity.

Graphic of three people sitting at a table.

Senior officers are required to file a registration in their name when their organization or business employs in-house lobbyists, and the entity meets the 50-hour threshold of time spent lobbying within a 12-month period. The registration must be in the senior officer’s name, regardless of whether they are doing any lobbying activity.

The registration must list the names of all employees engaged in lobbying activities including the senior officer if applicable, and should be filed within two months of them meeting the definition of in-house lobbyist.

After the registration has been published, remember that any changes to the information in the registration or new information must be provided within 30 days. This includes a change to the name of the senior officer and amending the current and former in-house lobbyist lists on the registration.

Learn more about senior officers in Interpretation Bulletin #3A: Does my business have to register? and #3B: Does my not-for-profit organization have to register?

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Annual Report Stats

The Integrity Commissioner’s Annual Report for 2022-2023 was released in June, featuring registry statistics and details about compliance activities. The report also provided descriptions of Office processes and summaries of investigations.

This past year, the Office initiated 172 compliance reviews. A review is initiated when staff identify potential non-compliance with the Act.

Compliance reviews pie chart: of a total 172 reviews, 48 were closed at initial review, 96 were resolved through an informal process, and 28 were referred for an investigation assessment.

Of these compliance reviews, 28 were referred for investigation assessment.

This pie chart breaks down how the compliance reviews were handled.

 
Coming soon! Watch for our new Primary Contact Training coming in the fall! Email the Office at lobbyist.mail@oico.on.ca if you are interested in attending!
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