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COVID-19 emergency funding and registration requirements

Do you have to register if you apply for a federal government-funding program linked to COVID-19?

Registration required

Communications with public office holders about the making, developing or amending of a government-funding program linked to COVID-19 are registrable activities.

Accordingly, if you are a consultant and you communicate about these matters, you need to register.

If you are employed by a corporation or organization, these communications need to be included in the calculation to determine if your corporation or organization has met the significant part of duties threshold to register (i.e. the 20% rule).

Lobbying communication details about COVID-19 government-funding programs must be included in the registration under "Subject Matter Details".

Applying to a federal government-funding program where eligibility is determined by discretionary factors, such as a proposal to obtain a grant or contribution, continues to be a registrable activity.

No registration required

Examples of COVID-19-related funding programs

  • Canada Emergency Wage Subsidy (CEWS)
  • Canada Emergency Business Account (CEBA)
  • Canada Emergency Commercial Rent Assistance (CECRA)

Simply applying to a federal government-funding program linked to COVID-19 where eligibility is determined by a set of non-discretionary factors is not a registrable activity.

Communications with public office holders limited to requests for information about government-funding programs linked to COVID-19 or requests for information about the status of your application are also not registrable activities.

If a registration already exists in the Registry of lobbyists for your corporation or organization or for your client, please see Disclosing COVID-19 emergency funding received below as you may have additional reporting requirements.

Disclosing COVID-19 emergency funding received

If your corporation or organization are already registered or if you are a consultant lobbyist and registered for a client and your corporation or organization, or your client, successfully apply for government funding linked to COVID-19 from any level of government, domestic or foreign, you must disclose in your registration the non-repayable portion of the funding received.

You are required to update your registration no later than 15 days after the end of the month with:

    • the name of the government entity providing the funding,
    • the amount of funding received, if it was received in the most recently completed financial year, and
    • A confirmation (yes or no) that funding is expected during the current financial year.

The table below provides examples of different types of funding which may or may not be disclosed.

Reportable as government funding Excluded from reportable government funding
Grants Repayable contributions
Non-repayable contributions Repayable portions of government loans
Forgiven portions of government loans Tax credits, refunds, exemptions, rebates, and remissions of taxes
Any other non-repayable funding Payment of goods or services contracts

With respect to COVID-19 emergency funding, as with all non-repayable funding, the non-repayable portion must be disclosed in your Registration update.


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