If an organisation has both an “umbrella” group and smaller regional arms, who registers?

Some organisations have both a larger umbrella body and smaller associated organisations. Others may have a headquarters operation that oversees the operations of its subsidiaries.

In many cases, it is only the headquarters or umbrella organisation that engages in lobbying on behalf of the wider entity. However, some organisations’ lobbying activities may be more complicated. For example, the umbrella organisation or headquarters may direct lobbying by the other levels of their organisation. In other cases, it is the member organisation or subsidiary that leads its own lobbying. The larger entity may have more than 10 employees and therefore fit within the scope of the Act, while the smaller organisation may be largely volunteer-driven and fall outside the scope of the Act.

In any event, the responsibility for registering and submitting returns of lobbying activity rests with the level at which lobbying communications are made, managed or directed, as long as that organisation fits within the scope of the Act. It is at that level that must assess whether or not it falls within the scope of the Act.

If the headquarters/umbrella group with more than 10 employees is leading the lobbying campaign, it is that organisation that must register and submit a return. If the lobbying is led by the lower-level association or subsidiary (again with more than 10 employees), the responsibility would rest with that organisation, rather than the headquarters. Finally, if the lobbying is led by the lower-level association which has less than 10 employees (without being made, managed or directed by the umbrella body), then the lower-level association would not have to register as they would fall outside of the scope of the Act.

This may vary depending on the lobbying campaign. It is possible that various levels of an organisation will independently have to register if they were leading separate lobbying activities. It is equally possible that lobbying led by a larger umbrella group would have to be registered but any lobbying led by their smaller subsidiary would be outside the scope of the Act.


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