Submission to the Province of British Columbia’s “Lobbyists Transparency Act Consultation”
Submissions can be accepted from the public by 2PM (Pacific Time) Sept 19, 2025.
By Sasha Izard
Sept 14, 2025
“The Special Committee to Review the Lobbyists Transparency Act is seeking written input on the Lobbyists Transparency Act (the Act). The Act regulates lobbying activities in BC. The Committee invites input on the Act by logging in or creating an account and uploading a submission (PDF file only) or filling out an open text field by September 19 at 2:00 p.m. (Pacific). Please note there is a 2,000-word limit for submissions. The Committee will be reviewing all submissions received with a view to inviting presentations at public hearings. “
Consultation Details – Consultation Portal
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The following is my submission to the Province of B.C. as part of its “Lobbyists Transparency Act” Consultation:
The LTA should define the word “lobby” as a noun, and the term “lobbying organization”, as a compound noun. Otherwise, lobbies as distinct entities are not recognized by the Act. This creates a major lack of transparency issue, which allows organizations functioning as lobbies by standard of use of the term in the English language to go under the radar as entities with such a purpose, in their dealings with government. This also allows government plausible deniability in its dealings with such groups, which is a major issue that should not be allowed. Without defining such entities, this makes it difficult for the various levels and branches of government to identify and avoid conflict of interest with them. My article and petition on this issue can be read here:
Does the Provincial Government of British Columbia Legally Recognize the Existence of Any Lobby? – Creatively United Community
Petition that the Province of British Columbia define the word “lobby” as a noun in the Lobbyists Transparency Act (LTA)
Many people can identify the NRA as a lobby in the US. In comparison, few Canadians can identify even one lobby group in their own country, albeit there are many. This is a major problem regarding lack of transparency that is a barrier to a truly democratic society.
I also suggest two categories of lobbyist in the LTA (in addition to the category of in-house lobbyist). One distinct category would be “Paid Lobbyists”, being those who are lobbying on behalf of an organization that they receive money from, and this would include those that receive remuneration for their work via salaries, benefits etc., and this would include those on paid board of directors of organizations including businesses, NGOs/non-profits, societies, third-party elector organizations/elections advertising sponsors etc. and this would also apply as other employees who are lobbying on behalf of and receive money from an organization.
I would add a second category that would require registration under the Act and would be identified as such in the BC Lobbyists Registry: “Unpaid lobbyists”. This would include volunteers who are lobbying on behalf of an organization i.e. they do not receive money from an organization, but they are seeking to convince the Provincial government and its elected and unelected officials of things including policy.
I would also add clear conflict of interest provisions in the LTA that would apply to both elected officials and unelected employees of the Province. These provisions would be binding and if broken could be tried in the court of law. An example of a conflict of interest provision that should be added to the LTA would be that a director, executive, principal, or employee of a lobby or lobbying organization, or someone who lobbies for an organization (that is not a government organization) cannot simultaneously sit in government office, be it as an elected official, or as a public servant.
Currently there is a serious lack of such provisions in law. Having guidelines e.g. codes of conduct, instead of law for public officials in this regard is a serious lack of binding and clear regulation on such issues. Guidelines are interpretive, broad and can easily be violated with impunity at present, and their interpretation is open to far too much discretion at the hands of organizational higher ups, who could ignore or mitigate interpretations of them at their own whim without any repercussions.
I would also add in the LTA, that the Provincial Government and local governments and regional governments (which are under provincial jurisdiction), should not be allowed to be a member of a lobby, lobbying organization, or organization that has lobbied the government in the last decade, or intends to lobby the government in the next decade.
I would also add in the LTA that government employees, including both elected and unelected public servants, be forbidden from spending public funds on attending events held by lobbies or lobbying organizations.
Thank you.
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See also: Transparency International Knowledge Hub | Knowledge Hub
Index of articles regarding Law and Bylaw – CRD Watch Homepage
Index of articles regarding lobby events and other meetings between government and lobbyists. – CRD Watch Homepage
CRD Watch Homepage 
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