On February 6, 2020, the Office of the Registrar of Lobbyists in British Columbia (B.C. Regulator) issued Guidance for Organizations (Guidance) in anticipation of the amendments to in-house lobbying laws effective May 4, 2020.

The Guidance indicates that the new in-house lobbying exemption rule is inclusive, not enumerated. In other words, organizations must register any lobbying activity whatsoever, unless they meet all three legislative requirements of the in-house lobbying exemption. Specifically, all organizations must register unless:

• The organization that has fewer than six employees;
• Lobbying activity, in the aggregate for the organization and its affiliates, is below 50 hours in the last 12 months; and
• The primary purpose of the organization is to not to represent the interests of its members, or to promote or oppose the issues, and the lobbying by the individual is for that purpose.

In light of this Guidance, the registration exception in B.C. is very limited and narrow. Very small organizations with minimal lobbying and no member mandates can escape registration requirements, but almost all businesses, industry associations, professional associations, unions and other stakeholders lobbying on behalf of themselves in B.C. will be required to register.