When a person undertakes lobbying activities on behalf of a client, who registers and submits a return – the client or the professional representative?
Where a person makes, manages or directs the making of relevant communications on behalf of a client in return for payment, he or she must register and submit a return of lobbying activities. In the return, the client must be identified. In such an instance, it would not be appropriate for the client to submit a return in place of the professional representative, as the client’s return would not make transparent the involvement of the professional in making, managing or directing the communication.
If both the hired professional and the client undertake the same lobbying activities, the professional should submit the return, which would identify the client.
The client may also carry out additional lobbying activities independent of their hired representative (that is, where the client is the one making, managing or directing the making of the relevant communication). In this case, both the client and the hired professional should submit returns. In such circumstances the client submits a return in respect of those lobbying activities which are additional and separate to those carried out on the client’s behalf by the professional lobbyist.
If a hired professional advises a client regarding the client’s lobbying activities, but does not make, manage or direct the making of the relevant communication, then in that instance it is only the client who must register and submit a return.