Can my client pay me with public money?

Interpretation Bulletin #4


Some clients are not allowed to pay consultant lobbyists to lobby with public money. 


The law prevents some clients from paying you to lobby with public money. These clients are listed in Appendix A. 

If you accept public money to lobby for these clients, you are breaching the Lobbyists Registration Act, 1998. You could be found guilty of an offence. 

These clients can hire you only if they do not use public money. If you want to lobby for a client listed in Appendix A, you need to file an attestation form:
- stating that your client is not using public funds, and

- that is signed by your client.

You can download the attestation form when you are logged into your registration, or, you can download the BPSAA Attestation Form on our website.

Your client receives public money when the Ontario government, or one of its agencies, gives your client:
- a grant,

- a transfer payment or,

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

Your client is not receiving public money when the Ontario government, or one of its agencies, gives your client: 
- fee for service payments,

- payments for goods or services, or 

- loans.


This Bulletin applies to the following types of lobbyists:
- consultant lobbyists

Relevant Legislation

Lobbyists Registration Act, 1998
- s. 3.1
- s. 4(4)14.1 
- s. 18(7.1)

Broader Public Sector Accountability Act, 2010
- s.1 
- s.4


- First issued: June 24, 2011
- Amended on: July 1, 2016; March 30, 2020

This Bulletin was previously published as Interpretation Bulletin #4, "Publicly Funded Lobbyists Restriction under the Broader Public Sector Accountability Act, 2010".


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.

Appendix A

Under the Broader Public Sector Accountability Act, 2010, these bodies cannot use public funds, or revenues, to pay for consultant lobbyists:
- boards, commissions and other public bodies listed in O.Reg. 146/10 of the Public Service of Ontario Act, 2006
- hospitals
- school boards
- universities
- colleges
- children’s aid societies 
- Ontario Power Generation and its subsidiaries 
- Independent Electricity System Operator
- every corporation controlled by one or more public sector organizations that exists to purchase goods or services for the public sector organization(s). 

Other bodies also cannot use public funds to pay for lobbyists, if the Ontario government gave them $10 million or more in funding in the previous fiscal year, not including fee for service payments, payments for goods or services, or loans.
The Broader Public Sector Accountability Act, 2010 does not prevent these bodies from using public funds for lobbying:
- the Office of the Lieutenant Governor
- the Office of the Assembly or the office of an officer of the Assembly
- a ministry of the Government of Ontario
- an agency of the Government of Ontario
- a municipality
- a local board as defined in section 1 of the Municipal Act, 2001 and section 3 of the City of Toronto Act, 2006
- a board of health under the Health Protection and Promotion Act
- an organization that undertakes its activities for the purpose of profit to its shareholders
- a long-term care home
- a district social services administration board 
- a First Nation.