What is grass-roots lobbying?

Interpretation Bulletin #8


Grass-roots communication is a type of lobbying. This Bulletin explains what it is, and how to record it.


Grass-roots communication is:
- reaching out to the public (e.g. through ads, websites, or social media), and

- asking members of the public to communicate with government, 

- to try to place pressure on the government on an issue 

- posting a link on your website asking people to send a letter to a minister about a new policy
- buying an ad in a newspaper asking the public to contact their MPP in support of your client 
- giving postcards to members of the public to send to the Premier demanding funding for a new program

Only managing grass roots communications is considered lobbying. These activities are lobbying:
- directing a campaign

- making decisions about the message of the campaign, or

- making decisions about the techniques to be used.

These activities are not lobbying:
- day to day administrative work (e.g. website maintenance, photocopying),

- preparing research papers to support a campaign

If a client pays you to manage grass-roots communication, you must register as a consultant lobbyist. If you manage grass-roots communications for an employer, you may be an in-house lobbyist and your senior officer may need to register your lobbying. See Interpretation Bulletin #3A for businesses and Interpretation Bulletin #3B for not-for-profit organizations.

When registering, record grass-roots lobbying in the “communications techniques” section. 


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.1(1) “grass-roots communication”
- s.4(4)14
- s.5(3)16
- ss.6(3)14


First issued: July 3, 2012
Amended on: July 1, 2016; March 30, 2020

This Bulletin was previously published as Interpretation Bulletin #8, "Registering Grass Roots Lobbying".


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.