I have to admit, I'm not the expert on the different types of firms. I'm the expert on what constitutes a registerable or lobbying activity. I'd probably have to answer it in a different way.
The act requires that if an individual is, for payment, communicating with a public office holder regarding a registerable activity...and, as I mentioned earlier, a registerable activity is one that makes a development or change to any policy or program, legislation, or regulation, or tries to obtain a financial benefit such as a crown contract or contribution. In the case of a consultant lobbyist, it depends on whether they're actually being paid to arrange a meeting between their client and a public office holder or trying to obtain a financial benefit. So all of those factors need to be there, and they will determine whether, in the case of a consultant lobbyist, something needs to be registered.