How do I report government funding?

Summary

This Bulletin explains how to report government funding in your lobbyist registration.

Interpretation

If you are a consultant lobbyist, you need to report:
- if your client has received government funding.

If you are the senior officer of an organization or business that has in-house lobbyists, you need to report:
- if your organization or business has received government funding.

Government funding is funding from:
- any level of government (municipal, provincial, federal) and/or

- government agencies.

Government funding means: 
- a grant,

- a transfer payment, 

- an employer wage subsidy,

- a forgivable loan or the part of a loan that is forgiven,

- other funding arrangement (including, for a school board, money received through taxes levied for school purposes).

Government funding does not include tax credits or rebates. It also does not include money the government pays:
- for goods or services,

- under a fee for service arrangement,

- by loan or loan guarantee, or

- directly to your employees.

On your registration, list funding received, including any amounts of loans forgiven, by your client or organization in the government’s last fiscal year (the fiscal year before filing your registration or renewing your registration). 

The Lobbyists Registration Act, 1998 requires that you update a registration with any new information within 30 days. This means the government funding amounts must be updated 30 days after the end of each government’s fiscal year. However, the Act does not prevent you from listing government funding in a registration earlier than the deadline in the Act.

You must list:
- the total amount of funding from each level of government (municipal, provincial and federal) and

- the name of the government or government agency.

Example
In the 2020-2021 government fiscal year, your organization received a total of $3,250,000. You received $2 million from various ministries of the Government of Ontario, $1 million from the Ontario Trillium Foundation. The organization also received a $150,000 grant and $100,000 in the form of a wage subsidy from the Government of Canada. 

On June 1, 2021, you are filing a new registration. You should list your 2020-2021 funding like this:
- Government of Ontario: $2,000,000
- Ontario Trillium Foundation: $1,000,000
- Government of Canada: $250,000

Application

This Bulletin applies to the following types of lobbyists
- consultant lobbyists
- in-house lobbyists (organizations) and (persons and partnerships)
 

Relevant Legislation

Lobbyists Registration Act, 1998
- s. 4(4)6
- s. 4(5)
- s. 5(3)6
- s. 5(4)
- s. 6(3)5
- s. 6(3.1)

Broader Public Sector Accountability Act, 2010
- s.1 (“public funds”)

History

First issued: October 28, 2011
Amended on: July 1, 2016; March 30, 2020, March 30, 2021

This Bulletin was previously published as Interpretation Bulletin #6, "Determining Government Funding".

Authority

The Lobbyists Registration Act, 1998, makes sure that lobbying in Ontario is transparent and ethical. The Integrity Commissioner, as the Lobbyists Registrar, maintains an online public record of lobbyists and conducts investigations into non-compliance with the Act. The Registrar may issue a bulletin about the interpretation or application of the Lobbyists Registration Act, 1998. 

This Bulletin provides general information. It is not legal advice. It is not a binding statement of how the Integrity Commissioner will interpret the law.