Question: Our company would like to engage in goodwill lobbying. Do we have to register for this activity?

Answer: Goodwill lobbying is a type of lobbying that focuses on communications with legislators and public officials to build positive relationships but not directly advocating for specific legislation or policy changes. Many states require registration for these types of lobbying communications.
In New York, registration is required for goodwill lobbying upon meeting the compensation and expense threshold of expending, incurring, or receiving combined compensation and expenses for the purposes of lobbying in excess of $5,000 in the aggregate during any calendar year. Direct lobbying includes when a person has direct or preliminary contact with a public official to enable or facilitate an attempt to influence. Preliminary contact includes when the lobbyist knows or has reason to know the client will attempt to influence a public official in scheduling a meeting or telephone call with a public official and a client, introducing a client to a public official, or any other contact with a public official on behalf of a client. A person who schedules a meeting or places a call in a purely administrative capacity is not required to be identified as an individual lobbyist; such activity is attributable to the person who directed the call to be made or the meeting to be set up. Anyone, including consultants, who contacts a public official, including preliminary communications to facilitate or enable the eventual substantive advocacy, is engaging in lobbying.
In Pennsylvania, registration is required for goodwill lobbying. Lobbying includes providing any gift, hospitality, transportation, or lodging to a state official or employee for the purpose of advancing the interest of the lobbyist or principal.
In Ohio, registration is not required for engaging in goodwill lobbying provided the individual is not promoting, opposing, advocating, or otherwise influencing legislative, executive agency, or retirement system action. Lobbying registration requirements cannot, however, be avoided simply by never referring by name to a specific legislative bill or executive agency or retirement system decision. If the goodwill activity also includes discussion regarding the generalities within any official action, lobbying registration would be required.
These are just a few examples of goodwill lobbying registrations. We advise you to follow best practices to verify the rules in your jurisdiction.

The information from this response can easily be found on our website in the Lobbying Compliance section of the United States Compliance Laws publication. Please do not hesitate to contact us if you have questions.