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. David Cameron (then Conservative Party Leader) reportedly stated in 2010 that lobbying in the UK was “the next big scandal waiting to happen.” In 2014 the government introduced the Transparency of Lobbying, Non-party Campaigning and Trade Union Administration Act 2014 (the 2014 Act), 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.” 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, and the remaining provisions entered into force on April 1, 2015.
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, who is required by the Act to be independent of both the lobbying industry and the government. 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), do not need to register as consultant lobbyists.
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.
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.
Operating as a consultant lobbyist without registering is a criminal offense punishable with a fine, although the Registrar may opt to pursue civil proceedings and implement a fine of up to £7,500 (about US$8,700). 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.”
Prepared by Clare Feikert-Ahalt
Senior Foreign Law Specialist
 Robert Rogers & Rhodri Walters, How Parliament Works 104 (7th ed. 2015).
 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.
 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.
 Transparency of Lobbying Act 2014, Explanatory Notes ¶ 4.
 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.
 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.
 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.
 Transparency of Lobbying Act 2014, Explanatory Notes ¶ 3.
 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.
 Transparency of Lobbying Act 2014, § 4.
 Id. § 5.
 Transparency of Lobbying Act 2014, § 12.
 Id. §§ 13–16.
 Id., Explanatory Notes ¶ 3.
Last Updated: 12/30/2020