Q: I know in Illinois you must register prior to any lobbying activity. Does this mean I must register as a lobbyist before communicating with any government agency?

A: You are correct in saying Illinois requires registration as a lobbyist prior to engaging in lobbying activity. However, registration is only required if the activity within the state meets the definition of “lobbying,” which does not cover all communications with a government office.

In fact, the Lobbyist Registration Act only covers communications with a specific list of high-level government officials at both the state and local levels. So, communications with individuals not included in this list would not be considered “lobbying” under the Lobbyist Registration Act and would, therefore, not require registration.

This list of officials are as follows:

• The Governor, Lieutenant Governor, Secretary of State, Attorney General, State Treasurer, and State Comptroller;
• The Chiefs of Staff and Deputies of each of the above officials;
• Cabinet members of any elected constitutional officer, including Directors, Assistant Directors and Chief Legal Counsel or General Counsel;
• Members of the General Assembly;
• Members of any board, commission, authority, or task force of the State authorized or created by State law, by executive order of the Governor, by a local ordinance, or by order of a mayor or village or town president;
• Mayors, presidents, aldermen, commissioners, and trustees of a city, village, or town; and
• County and township board members and countywide and township elected officials.

So, if you are communicating with government agencies in Illinois, whether you will be required to register as a lobbyist depends on with which individuals you will be communicating. So, it is vital to keep in mind which individuals are covered by the Lobbyist Registration Act to ensure full compliance.

More information about this topic can be found in the Lobbying Compliance Guidebook on the State and Federal Communications subscriber website by selecting Illinois from the list of states.