I think so. If we look at the American definition, it talks about contacts or direct communication with public office holders. But it also talks about all the efforts in support of preparing for those contacts. Of course, people should be penalized if they do not comply with the legislation. With this expanded definition, the commissioner must also have greater power of sanction. Otherwise, it would be at the whim of the lobbyists to say that they do not establish contacts, but that, in the work that they do, this falls under lobbying because they are developing a potential contact. That would be up to them to declare.
What can be done to make sure that this information is in the registry? Well, that is why the commissioner should have the power of sanction and check if those preparatory activities are actually registered. If that's not the case, she should be able to penalize the offenders.
To be clear, I think that this measure—this expanded definition that works well for the United States—should be applied here as long as the commissioner actually has oversight and greater power of sanction when it comes to enforcing the act.