By: Ujwal Ganguly, Associate Director
A New Era of Transparency in Federal Lobbying
In summer 2025, the Office of the Commissioner of Lobbying issued new guidance that will significantly expand which organizations are required to file a lobbyist registration with the Commissioner of Lobbying. Coming into effect today, January 19, 2026, the revised interpretation lowers the registration threshold for not-for-profits and corporations from 32 hours to just eight hours of lobbying activity within any four-week period.
The intent is to enhance transparency and ensure a more complete picture of who seeks to influence federal decisions. But for many corporations, associations, and non-profits that regularly engage with government, but who didn’t meet the threshold for having to register before, this change represents more than an administrative update. It introduces new compliance obligations that could fundamentally change how they plan, track, and disclose their government relations work.
What’s Changing
Under the Lobbying Act, an organization’s most senior paid officer must register when lobbying activities carried out by one or more employees, taken together, constitute a significant part of the duties of one employee. Starting today, the Commissioner of Lobbying considers this threshold met when those activities total eight or more hours in any consecutive four-week period. Previously, “significant part of the duties” was interpreted as roughly 20% of an employee’s time, or about 32 hours per month.
“Lobbying activities” include not only direct communications, but also meetings, emails, or phone calls, and preparatory work, such as drafting briefing materials, coordinating outreach, or strategizing on advocacy campaigns.
In practice, this means it will take much less activity for an organization to cross the registration threshold. A few short meetings or background preparation by several team members could be enough to require registration.
What Counts, and What Doesn’t
What counts towards “lobbying activities” has not changed. The guidance reaffirms that lobbying includes communications about federal legislation, regulations, policies, programs, and funding decisions, as well as grassroots efforts that encourage the public to contact government officials.
Travel time and purely administrative work won’t count toward the eight hours. Additionally, and notably for in-house practitioners, any work related to the awarding of a contract does not count towards the eight hours.
However, the scope of covered activity remains broad, and many organizations will find that what they’ve long considered “business as usual” will now require the organization to register given the reduced threshold.
Former Public Office Holders Face Stricter Limits
A separate guideline also taking effect today tightens the rules for former designated public office holders (DPOHs), such as ministerial staff, senior bureaucrats, and Members of Parliament who undertake lobbying activity as an employee of a corporation. While DPOH’s face a complete five-year post employment ban on undertaking consultant lobbying as well as lobbying as an employee of not for profits, they are allowed to do limited lobbying as an employee of a corporation within their five-year post employment restriction.
For former DPOH’s in corporate roles that were hired after July 16, 2025, lobbying activity on behalf of their employer is permitted only if it stays under the eight-hour threshold within any four-week period (effective today). This eight-hour threshold would also include time spent preparing for the lobbying activity. For any former DPOH’s who were hired in a corporate role prior to July 16, 2025, they can continue to lobby for 32 hours a month for the reminder of their five-year restriction period.
This reinforces the Commissioner’s focus on transparency, public confidence, and the avoidance of perceived conflicts of interest going forward.
Why This Matters, and What Organizations Should Do Now
The new eight-hour threshold means that many organizations previously exempt from registration will now need to file.
At Temple Scott Associates (TSA), we see this as an important inflection point. Organizations can take the following steps to make sure they are following the next guidelines.
- Track lobbying activities carefully: Implement systems to record lobbying-related hours and communications across their team.
- Err on the side of caution: When in doubt, register. The reputational and legal risks of non-compliance far outweigh the administrative effort.
- Educate staff: Ensure employees understand what constitutes lobbying under the Act, particularly those in communications, government relations, or executive roles.
- Review internal policies: Update compliance procedures and clarify responsibilities for registration and reporting.
Organizations that act now will be best positioned to navigate the new framework confidently.
As always, we at TSA are here to help, whether by advising on the new rules, helping develop internal compliance policies, or advising on registration requirements tailored to your organization’s activities.
