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The statutory regulation of lobbyists in the UK is a relatively recent occurrence.  Prior to the enactment of legislation in 2014, registers and voluntary codes of conduct were relied upon to provide clarity during the political process.[1]  David Cameron (then Conservative Party Leader) reportedly stated in 2010 that lobbying in the UK was “the next big scandal waiting to happen.”[2]  In 2014 the government introduced the Transparency of Lobbying, Non-party Campaigning and Trade Union Administration Act 2014 (the 2014 Act),[3] which requires consultant lobbyists to provide their details to a publicly available register.  These provisions were introduced in order to “ensure that it is clear whose interests are being represented by consultant lobbyists who make representations to the Government.”[4]  The Act was enacted on January 30, 2014 and the different parts of the Act received commencement orders on later dates.  The requirement to register as a consultant lobbyist entered into force on May 23, 2014,[5] and the remaining provisions entered into force on April 1, 2015.[6]

Part 1 of the 2014 Act required “consultant lobbyists” to provide information to a publicly available register of consultant lobbyists.  The register is hosted and supervised by the Registrar of Consultant Lobbyists,[7] who is required by the Act to be independent of both the lobbying industry and the government.[8]  Under section 2(1) of the 2014 Act, a person is deemed to be carrying on the business of consultant lobbying if

(a)  in the course of a business and in return for payment, the person makes communications within subsection (3) [of section 2] on behalf of another person or persons,

(b)  the person is registered under the Value Added Tax Act 1994, and

(c)  none of the exceptions in Part 1 of Schedule 1 applies.

The requirement that the person be registered under the Value Added Tax Act means that individuals who make less than the VAT threshold, which is currently £83,000 (about US$103,500),[9] do not need to register as consultant lobbyists.[10] 

Information that a consultant lobbyist must provide to the register includes

  • his/her company name and the address of the company’s registered office;
  • the VAT registration number;
  • the names of the company’s directors, any secretary and shadow directors, or partners where applicable;
  • his/her name and the address of his/her main place of business, or other contact address; and
  • the name(s) of his/her clients.[11] 

The register must also include whether the consultant lobbyist subscribes to a code of conduct that is publicly available and, if so, the location of the code.  The details on the register must be updated on a quarterly basis.[12] 

Operating as a consultant lobbyist without registering is a criminal offense punishable with a fine,[13] although the Registrar may opt to pursue civil proceedings and implement a fine of up to £7,500 (about US$8,700).[14]  The government notes that the register “will complement the existing transparency regime, whereby Government ministers and permanent secretaries of Government departments proactively disclose information about who they meet on a quarterly basis.”[15]

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Prepared by Clare Feikert-Ahalt
Senior Foreign Law Specialist
March 2017


[1] Robert Rogers & Rhodri Walters, How Parliament Works 104 (7th ed. 2015).

[2] Andrew Porter, David Cameron Warns Lobbying Is Next Political Scandal, Telegraph (London) (Feb. 8, 2010), http://www.telegraph.co.uk/news/election-2010/7189466/David-Cameron-warns-lobbying-is-next-political-scandal.html, archived at https://perma.cc/5RNV-6EZ2

[3] Transparency of Lobbying, Non-party Campaigning and Trade Union Administration Act 2014 (hereinafter Transparency of Lobbying Act), c. 4, http://www.legislation.gov.uk/ukpga/2014/4, archived at https://perma.cc/47CA-KG8U.

[4] Transparency of Lobbying Act 2014, Explanatory Notes ¶ 4.

[5] Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (Commencement and Transitional Provision No. 1) Order 2014, SI 2014/1236, http://www.legislation.gov.uk/uksi/2014/1236/ pdfs/uksi_20141236_en.pdf, archived at https://perma.cc/R7JM-7AV2

[6] Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (Commencement and Transitional Provision No. 3) Order 2015, SI 2015/954, http://www.legislation.gov.uk/uksi/ 2015/954/pdfs/uksi_20150954_en.pdf, archived at https://perma.cc/SU2A-6SHL.

[7] Registration, Office of the Registrar of Consultant Lobbyists, https://registerofconsultantlobbyists.force.com/CLR_Search (last visited Mar. 22, 2017), archived at https://perma.cc/2KM8-LURP.

[8] Transparency of Lobbying Act 2014, Explanatory Notes ¶ 3.

[9] VAT Registration Thresholds, Gov.uk, https://www.gov.uk/vat-registration-thresholds (last visited Mar. 22, 2017), archived at https://perma.cc/B7FL-7GY8.

[10] Elise Uberoi, House of Commons Library, The Register of Consultant Lobbyists, Briefing Paper No. 07175, Jan. 22, 2016, http://researchbriefings.files.parliament.uk/documents/CBP-7175/CBP-7175.pdf, archived at https://perma.cc/6TMJ-FBWX.

[11] Transparency of Lobbying Act 2014, § 4.

[12] Id. § 5.

[13] Transparency of Lobbying Act 2014, § 12.

[14] Id. §§ 13–16.

[15] Id., Explanatory Notes ¶ 3.

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Last Updated: 04/05/2017