The first point is maintaining a distinction between sustained lobbying and occasional engagement. On maintaining a threshold, our recommendation would be to go back to the 32 hours. Also, this would go over to the commissioner's office around clarity on what activities do and do not count. We've been seeing some confusion over the last several months around activities such as preparation for meetings.
We've heard a lot of references to work related to grants and contributions, so more plain language guidance and perhaps an online tool specifically for charities and non-profits would help them navigate the regulation and compliance environment more efficiently.