Five-year restriction on lobbying for former designated public office holders

The purpose of this bulletin is to describe the five-year restriction on lobbying that applies to all former designated public office holders set out in subsection 10.11(1) of the Lobbying Act (Act).

This subsection of the Act restricts former designated public office holders from engaging in lobbying activities for a period of five years from the day on which they cease to perform their duties as designated public office holders.

Complete restriction for consultant lobbying (par. 10.11(1)(a))

During the five-year period after they cease to perform their duties, former designated public office holders are prohibited from engaging in any of the consultant lobbying activities set out in paragraphs 5(1)(a) and (b). This means that they are prohibited from communicating with public office holders in respect of any of the matters referred to in paragraph 5(1)(a) and/or arranging meetings with public office holders as contemplated by paragraph 5(1)(b) pursuant to a paid undertaking on behalf of any client.

Complete restriction for in-house lobbying on behalf of an organization (par. 10.11(1)(b))

When former designated public office holders are employed by an organization, they are also prohibited from engaging in any of the in-house lobbying activities set out in paragraph 7(1)(a). That is, they are prohibited from communicating with public office holders on behalf of their employer in respect of any of the matters referred to in paragraph 7(1)(a) during the five-year period after they cease to perform their duties. 

Restriction with limited exception for in-house lobbying on behalf of a corporation (par. 10.11(1)(c))

When former designated public office holders are employed by a corporation, they may communicate with public office holders on behalf of their employer in respect of the matters set out in paragraph 7(1)(a) during the five years after they cease to perform their duties, provided that such activities do not constitute a significant part of their work on behalf of their employer.

The significant part of work exception for in-house lobbying on behalf of a corporation 

Former designated public office holders employed by a corporation may communicate with public office holders on behalf of their employer in respect of any of the matters referred to in paragraph 7(1)(a) as long as engaging in such communications does not constitute a significant part of their work on behalf of their employer.

The Commissioner of Lobbying considers former designated public office holders who are employed by corporations to contravene paragraph 10.11(1)(c) if they communicate with public office holders as part of their work on behalf of their corporation-employer in respect of any of the matters referred to in paragraph 7(1)(a) for 8 hours or more in any given consecutive 4-week period. This would include any time spent preparing for and participating in oral communications with public office holders as well as drafting written communications to public office holders.

This interpretation of paragraph 10.11(1)(c) is consistent with how the Commissioner interprets the significant part of duties in-house registration threshold in paragraph 7(1)(b) of the Act.

Ask the Office of the Commissioner of Lobbying

Contact our Office if you have any questions about the five-year restriction on lobbying set out in subsection 10.11(1) of the Act.

Nancy Bélanger
Commissioner of Lobbying

July 16, 2025
Effective on January 19, 2026