A former minister would have to clear their new work, profession or start-up with the Ethics Commissioner, and they would only need to register to lobby if they personally were lobbying for eight hours per month, and only to request grants or contributions, because that's covered by the act.
However, a former minister or a former member could start a company, pick up the phone and call one of their former cabinet colleagues and say, “Hey, we're doing this thing that's compatible with that thing you're about to spend billions of dollars on, and we think we're right for you,” and that is not captured by the Lobbying Act.
Do I understand that correctly?