How do I know if I am a consultant or an in-house lobbyist?
Consultant lobbyists receive payment and have an agreement to communicate with a public office holder on behalf of a client. In-house lobbyists are employees, officers, or directors of an organization who are paid for the performance of their functions and whose collective lobbying efforts on behalf of the organization amount to at least 100 hours annually.
I am not sure if my activities count as lobbying. Should I register anyway?
No. Registering an undertaking that has not occurred frustrates the intended transparency and openness of the Lobbyists Registration Act (LRA) just as much as a lobbyist who registers late. If a lobbyist registers out of an abundance of caution, they give the impression that lobbying is occurring, which is misleading to the public. This could also result in a contravention of s. 4(1) for filing information that is not true. The best way to make sure you are in compliance with the LRA is to register an undertaking as soon as it has been established. Contact us for more information if you are unsure.
When the Lobbyists Registry asks if I am a former public office holder, does that include positions I held with the federal government?
No, you only need to list positions you have held in BC.
What is a former public office holder?
Under the LRA, a former public office holder is:
- a Minister;
- Ministers' staff (chief of staff, ministerial assistant, executive assistance);
- Parliamentary Secretary;
- Senior public servant (Deputy Minister, Associate/Assistant Deputy Minister, Chief Executive Officer); and
- Senior or next most senior ranking executive position in a "provincial entity" such as a Crown corporation, agency, or association.
- Chair or Vice Chair of the governing body of a Provincial Entity.
I updated my registration, but the changes I made don’t show in the Lobbyists Registry. Why can’t I see my changes?
Make sure the changes were submitted to the registry. In the “Review Screen,” check the “I certify…” box and click “Submit.” Registrations that have been saved but not submitted to the Registry Manager will be erased by the system after 10 days.
Why is the Registry Manager asking me to provide more details about my lobbying activities in my registration?
The Registry Manager is responsible for reviewing and verifying information contained in any return and may refuse to accept any return that does not comply with the LRA. The purpose of the LRA is transparency, which means that the public should be able to easily discern exactly what is occurring with respect to lobbying. If the information is too generic or vague, the Registry Manager will ask you to provide further details.
The registration form asked me to list the public office holders that I “expect to lobby.” Should I list as many as I can think of, to be on the safe side?
“Expect” means to confidently believe in something. Do not list every public office holder that you may possibly lobby; list only those that you believe, with confidence, you will target in the future. If you cannot provide details about your planned lobbying, it is likely premature for you to add this information to your registration.
I reported a Deputy Minister as a lobbying target, selected “Minister Staff Contact,” and listed their name. The Registry Manager told me to amend this information. Why?
When naming target contacts, there is an important difference between political staff of a ministry and civil servants.
- Minister Staff Contacts are those who work directly for Ministers in the Ministers’ offices, such as Ministerial Assistants and Executive Assistants to a Minister.
- Civil servants work in a ministry below the level of the Minister’s office and include positions such as Deputy Minister, Assistant Deputy Minister or Executive Director. These employees are civil servants, not ministerial staff. Instead of naming civil servants, select the name of the ministry within which the civil servant is employed (e.g., Ministry of Health, etc.) from the “Public Agency” drop-down menu.
When I registered, I planned to meet with a minister and listed that person as a lobbying target. I actually met with their chief of staff. Do I need to change my registration?
Yes, the law requires that you update your target list to reflect the fact that you met with a different person. There are two things to note in this situation. First, whenever there is a change to your existing registration – a different focus for your lobbying, a new target contact, etc. – you are required to update your existing registration. Lobbyist registrations are meant to be living documents that accurately reflect your ongoing lobbying efforts and any changes as they occur.
Secondly, there are five categories of lobbying targets to choose from:
- Person on the MLA’s staff;
- Person on the Minister’s staff; or
- Public Agency.
Your updated registration must reflect any change in category based on the new lobbying target.
If I lobby the City of Vancouver, do I have to register with the Office of the Registrar of Lobbyists for British Columbia?
No. Municipal governments, such as the City of Vancouver, do not fall within the definition of “public office holder” in the LRA.
I just signed a contract to lobby on behalf of an environmental organization. At what point do I need to register with the ORL?
Anyone who enters into an undertaking to lobby on behalf of a client must register within 10 days of entering into the agreement.
The end date for my undertaking has changed. What should I do?
You have 30 days to update your registration with any changes. You can update the details of your registration at any time on the Lobbyists Registry. If your agreement with your client terminates or completes before the date you had originally entered in your registration, you are required to amend the end date. If your agreement with your client has been extended, you have 30 days to extend the end date on your registration.
I have finished lobbying for my client, but my registration is still active. Do I need to de-register? And if so, how do I do that?
You need to adjust the end date of your registration to the date the lobbying activity for your client ended. The status of your registration will automatically change from “Active” to “Termination Pending” for 30 days, and ultimately to “Terminated.”
I'm preparing to re-register my organization. Should the registration reflect current and future lobbying over the next six months, or historical lobbying for the past six months?
Your registration must include who and what you expect to lobby in the upcoming six month period.
I worked as a former public office holder within the last two years. I am now an in-house lobbyist for an organization that does not meet the 100 hour threshold. Will I still be "caught" by the two-year lobbying prohibition?
Yes. You would not be able to lobby for two years after leaving your former public office holder position unless you receive an exemption. Information on the exemption process can be found here.