Transitional provisions: Application to former designated public office holders employed by corporations

The first category is made up of former designated public office holders who have already been hired by a corporation as of the date the new interpretation bulletin is published and who engage in in-house lobbying activities as part of their work on behalf of their employers during their five-year restriction period. 

These former designated public office holders will continue to be subject to the previous approach the Office has taken to interpreting and applying the significant part of work threshold, even after the new interpretation bulletin takes effect. This approach was modelled on the methodology the Office had previously used in relation to the significant part of duties in-house registration threshold set out in paragraph 7(1)(b) of the Lobbying Act. That is, this first category of former designated public office holders will not contravene the restriction set out in paragraph 10.11(1)(c) provided that any in-house lobbying that they engage in on behalf of their employers does not exceed 32 hours, including preparation time, in any given consecutive four-week period.

If, at any time after July 16, 2025, a former designated public office holder in this first category ceases to be employed by the corporation that employed them before July 16, 2025, they would be subject to either the second or third category of designated public office holders, described below and as applicable, in the event they become employed by another corporation before the expiry of their five-year restriction period.

Between July 16, 2025, and January 19, 2026, this second category of former designated public office holders will be subject to the Office’s existing approach to interpreting and applying the significant part of work threshold. That is, during the period after the new bulletin is issued to the day on which it takes effect, this second category of former designated public office holders will not contravene the restriction set out in paragraph 10.11(1)(c) provided that any in-house lobbying that they engage in on behalf of their employer does not exceed 32 hours, including preparation time, in any given consecutive four-week period. 

However, on January 19, 2026, and thereafter, this second category of former designated public office holders will be subject to the approach to interpreting and applying the significant part of work threshold set out in this new interpretation bulletin for the remainder of their five-year restriction on lobbying. That is, starting on January 19, 2026 and until their five-year restriction ends, this second category of former designated public office holders will not contravene the restriction set out in paragraph 10.11(1)(c) provided that any in-house lobbying that they engage in on behalf of their employers does not meet or exceed 8 hours, including the time spent preparing for and participating in oral communications with public office holders as well as drafting written communications to public office holders, in any given consecutive four-week period.  

This third category of former designated public office holders, those hired by a corporation on or after the new interpretation bulletin takes effect on January 19, 2026, will be subject to the approach to interpreting and applying the significant part of work threshold set out in this new bulletin for the duration of their five-year restriction on lobbying. That is, this third category of former designated public office holders will not contravene the restriction set out in paragraph 10.11(1)(c) provided that any in-house lobbying that they engage in on behalf of their employers does not meet or exceed 8 hours, including the time spent preparing for and participating in oral communications with public office holders as well as drafting written communications to public office holders, in any given consecutive four-week period.