Have you been in contact with any public officials?
On 21 January 2016, the first return is due for submission by anyone who has lobbied within the meaning of the Regulation of Lobbying Act 2015 (the Act).
Remember, you are carrying on lobbying activities if you:
- are communicating either directly or indirectly with a “Designated Public Official” and;
- that communication is about “a relevant matter” and;
- that communication is not specifically exempted and;
- you are one of the following:
- a professional lobbyist being paid to communicate on behalf of a client (where the client is an employer ofmore than 10 full time employees or is a representative body or an advocacy body which has at least onefull-time employee);
- an employer with more than 10 employees where the communications are made on your behalf;
- a representative body with at least one employee communicating on behalf of its members and thecommunication is made by a paid employee or office holder of the body;
- an advocacy body with at least one employee that exists primarily to take up particular issues and a paidemployee or office holder of the body is communicating on such issues; or
- any person communicating about the development or zoning of land.
Anyone involved in lobbying, as defined, has to make submissions on relevant lobbying activities three times a year in relation to "relevant periods".
The Act divides the year into three relevant periods: 1 January to 30 April; 1 May to 31 August; and 1 September to 31 December. The Act came into force on 1 September 2015, which means that the first relevant period under the Act is 1 September 2015 until 31 December 2015. Lobbying activities which are captured by the Act and which took place during the first relevant period have to be reported to the Register of Lobbying by 21 January.
What do you need to do?
If you have lobbied within the meaning of the Act during the first relevant period, then by 21 January 2016 you will need to:
- register with the Standards in Public Office Commission on the Register of Lobbying website (www.lobbying.ie); and
- provide the first set of returns setting out the lobbying activities undertaken during the first relevant period, on the Register of Lobbying.
How does the Act otherwise apply to you and/or your business?
These are the steps that we have recommended to our clients to ensure that they are complying with the new lobbying legislation.
- Established whether or not the Act applies to your/your businesses’ activities, and if so, registered with the Register of Lobbying?
- Implemented a lobbying policy to provide a framework for conducting lobbying activities within your business?
- Considered holding an introductory workshop to enable your employees to familiarise themselves with the requirements of the Act as set out in your new policy?
- Considered the need to insert provisions into your contracts; including services agreements, joint venture agreements or when buying or selling a business; to deal with restrictions or respective obligations which may apply under the Act?