A significant part of duties.

This interpretation bulletin is issued by the registrar under the authority of subsection 10.(1 ) of the Lobbyists Registration Act (hereafter "the Act"). The purpose of this bulletin is to help you better understand the phrase "a significant part of the duties" as used in sections 6 and 7 of the Act and as it applies to employees of corporations or organizations.

In-House Lobbyists (Corporate)

Subsection 6.(1 ) of the Act for in-house lobbyists (corporate) requires that employees of individuals or corporations that carry out commercial activities for financial gain must register if they, as a significant part of their duties, communicate with federal public office holders in an attempt to influence - i.e. lobby for - the development, making or amending of laws and regulations, policies or programs, or the award of federal grants, contributions or other financial benefits.

These employees are usually full-time officers of a corporation whose primary function is usually public affairs or government relations work, even though such distinctions may not be reflected in the individual's position title. Their duties would include communications with public office holders, whether formal or informal, in attempts to influence the government's decisions.

Employees whose jobs include a substantial or large amount of time fulfilling the duties described are subject to the registration requirements; 20 percent may be used as a guideline for what constitutes a sigmficant part of their duties.

Registration is not required for some activities. These are set out in detail in the Act, but an example would be employees making submissions to federal public office holders on the employer's behalf with respect to the enforcement, interpretation or application by that official of any federal statute or regulation. This would include routine dealings with government inspectors and other regulatory authorities.

A corporation may have a wide range of lobbying objectives on which several in-house employee lobbyists will work. While much of the information required in a return may be common to the returns of all employees who lobby, each in-house corporate lobbyist is individually responsible for compliance with the Act, and must certify the information in his or her form.

In-House Lobbyists (Organizations)

Subsection 7.(1) of the Act for in-house lobbyists (organizations) requires that the senior officer of an organization that pursues non-profit objectives must register on behalf of the organization when one or more employees communicate with federal public office holders in an attempt to influence - i.e. lobby for - the development, making or amending of laws and regulations, policies or programs, or the award of federal grants, contributions or other financial benefits, and where the accumulated duties of all such employees would constitute a significant part of the duties of one employee.

Many organizations have paid employees who work on government relations, public affairs or specific policy areas or issues. These employees may communicate, even though infrequently, with elected or appointed federal public office holders in attempts to influence government decisions.

When all the lobbying by all paid employees would amount to 20 percent or more of the employment time of one employee, then the senior officer of the organization must register and list in the form the names of those employees who lobby.

The registration requirements do not apply to some activities, and these are set out in the Act. Examples would be: research, standard administrative contacts or the preparation and presentation of briefings to parliamentary committees.

For more information, please do not hesitate to contact:

The Registrar
Office of the Registrar of Lobbyists
Industry Canada
255 Albert Street
10^th Floor
Ottawa, Ontario  K1P 5G8
Tel.: (613) 957-2760
Fax: (613) 957-3078