Lobbying, disclosure and access to government

International good practice standards recommend there should be transparency over the impact of lobbying . However, transparency reforms of the last decade have done little to improve public knowledge of what happens in Westminster or Whitehall. New legislation is needed for the UK to catch-up with its counterparts, including to meet the standard set by the Scottish lobbying register . This should ensure that the public are able to answer key questions: 

• Who is lobbying? 
• When are they lobbying? 
• What are they lobbying about and why? 
• How are they lobbying?

The current regime of ministerial meetings data and register of consultant lobbyists is simply not providing necessary transparency about those with access and potential influence in UK politics. Our research suggests the statutory consultant register covers at most 4 per cent of lobbyists. 

Additionally, some of the most frequently labelled ministerial meetings in 2025 were “to discuss the industrial strategy”, “to discuss trade strategy” and “to discuss criminal courts and wider reform” – impenetrable descriptions that fail to provide a meaningful summary to the public.

We recommend both the introduction of a statutory lobbying register (a register of lobbying interactions provided by all lobbyists, not just consultant lobbyists) and the retention of a ministerial meetings register provided by the Government. Both should be centralised and easily searchable. Transparency International UK’s position paper lays out the current arrangements in more detail and the case for change. 

Meanwhile, the current rules covering lobbying in the House of Lords are too permissive, allowing peers to work for firms selling political access to paying clients. This is a clear conflict of interest. We recommend that the Lords’ Code of Conduct is strengthened, and that peers should be required to dispense of these interests or leave the House of Lords.

It is also notable that the Business Appointment rules, notwithstanding the structural change in 2025, have not seen an overhaul since their introduction in 2012. They are well overdue an update. The current rules governing the revolving door do not sufficiently address the risks of ministers benefiting from privileged access and misusing confidential information. We recommend that the Business Appointment rules should be extended, and their enforcement strengthened.

Transparency of access to and influence over decision-makers is essential for the public to understand how decisions are made, to be able to trust they are being made in the public interest, and to maintain the social contract. Providing transparency over lobbying is also crucial for preventing and identifying potential misconduct by ministers and those seeking to influence them. 

Too little of this activity is currently captured on the public record at Westminster. That the revelations over Greensill , Westferry  and the COVID-19 ‘VIP lane’  for public contracts all came from the work of journalists instead of the statutory lobbying register or departmental disclosures, illustrates the ramifications of this transparency gap.

Annex 2 provides a short summary of international examples and how they compare to Westminster’s approach. While all have their pros and cons, we would suggest that the Canadian approach  to regulating lobbying provides a model to build from that would deliver more meaningful openness over attempts to influence key decision makers through a proportionate and more comprehensive statutory register. 

In relation to the specific questions in the call for evidence, we would suggest that communications made to special advisers, non-executive directors and other senior civil servants should be included in the definition of lobbying activity. 

We consider the VAT registration requirement presents a problematic loophole, and would note that similar registers of consultant lobbyists do not provide exemptions.  If a minimum threshold is deemed appropriate we would suggest alternative methodologies be considered for triggering registration and disclosure. These could be financial but should be relatively low. We would recommend allowing voluntary registration regardless of any threshold set.

Recommendations

Include in-house lobbyists and consultant lobbyists within the scope of the statutory register. Certain exemptions may be considered in order to remove the risk of imposing undue burdens on those who are not undertaking substantive influencing activities.

Require meaningful information on all forms of communication between lobbyists and government, including details of the: 

• form of communication; for example, email, letter, phone call etc. 
• subject matter discussed, which would link back to their registration summary report
• specific public officials they engaged
• date of the communication

Require lobbyists to report on communications with government at least monthly, as is the case in Canada.

Require clarity about the objectives of lobbyists and the topics they discuss with relevant officeholders, as is the case in most other registers (see Annex 2). This should include a summary report from registrants, updated at least every six months, outlining their key objectives, such as the specific legislation, policy, contract or other official business they are seeking to influence. It should also provide an estimate of expenditure on lobbying activities.

Registrants should also have to report the details of anyone they employ involved in lobbying activity that at any point has been a public official, which could apply to those from a select list of institutions. 

The definition of lobbying activity should include communications made to special advisers, non-executive directors and other senior civil servants.

While the timeliness of the disclosures has improved, with all four quarters of 2025 meeting the Government’s own deadlines, these are generous timescales. Government should have more ambitious targets of how quickly they publish the data, moving to a monthly schedule instead. This would be more aligned with the CSPL and Boardman recommendations.

The CSPL previously suggested that the descriptions of ministerial meetings data should be substantially improved, and we agree. Through our analysis, we do not see a material difference in the quality of the meetings descriptions since the CSPL published its Standards Matter 2 report.  

Some of the most frequently labelled meetings in 2025 were “to discuss the industrial strategy”, “to discuss trade strategy”, “introductory meeting” and “to discuss criminal courts and wider reform”- impenetrable descriptions that fail to provide meaningful transparency to the public.  

Our analysis shows that the average number of words used in the ‘purpose’ field of the disclosures in the last two quarters of 2025 (July – December) is just 11. This is a decline from the average of 13 words in the comparable meetings data for 2024. Whilst word count is a crude measure, we would compare this with the lengthier descriptions provided by the Scottish lobbying register which gives the public a much better insight into why the meeting was held, what was discussed, and any agreed outcomes. The average number of words for submissions to the Scottish lobbying register in the same period was 118.  

The previous government committed to introducing a central register of ministerial meetings with outside interests that would have been a key piece in improving lobbying transparency. Disappointingly, the current government is yet to have allocated funding to make progress in delivering this commitment. 

The Call for Evidence specifically asks about non-corporate communication channels. Evidence provided to the Covid-19 inquiry suggests that use of informal messaging was prevalent across government, and there is little external evidence of any change in behaviour. We have previously recommended personal phones be prohibited for use in official government business. If this is considered unfeasible, we recommend the Scottish Government-commissioned Martins Review  as a starting point for considering how best to handle non-corporate communication channels. 

1. We also note the specific question on whether the data provided by the register of consultant lobbyists can be reconciled with the ministerial meetings data. Using official records from 2020, our analysis suggested that at most only 4 per cent of lobbyists who appear in the external meetings data are registered with the Registrar of Consultant Lobbyists.  This data is however inconclusive due to the difficulty of undertaking the analysis. To do this at scale one would need to:

• download, clean and consolidate departmental disclosures 
• split out the attendee field so you have one row per attendee 
• download, clean and consolidate the register of consultant lobbyist entries
• fuzzy match the two datasets 
• go back through and manually search each consultant lobbyist 

This will set out only when a consultant lobbyist who features on the statutory register met with a minister or senior civil servant, and vaguely what they discussed. This analysis will not reveal:

• on whose behalf they were lobbying 
• about lobbying activity that was not a meeting 
• the objective of that lobbying 
• how much the lobbyist has been paid to pursue that objective
• whether the lobbyist employs former public officials e.g. someone who used to work with or for the advocacy target

Arguably the datasets could be more easily reconciled if government created unique identities for those organisations and individuals referenced in departmental disclosures, which would also provide a clearer cross-departmental view of Government’s engagements with external stakeholders. However, this would only ease the data matching element of the missing pieces listed above. It would not improve the quality of the datasets, or the meaningfulness of information provided through this analysis.

Recommendations

The Cabinet Office should collate all departmental disclosures and publish them in one centrally managed database, as recommended by the CSPL.

These datasets should include unique identities for individuals and organisations meeting with government to provide a clearer cross-departmental view of Government’s relationships with key stakeholders, and improved data matching with relevant datasets, including the register of consultant lobbyists.

The description of meetings should be improved to provide more meaningful information about what was discussed and, if possible, why.

The timeliness of publication of the meetings should move to monthly.

Under current rules, members of the House of Lords are allowed to retain interests in lobbying firms so long as they do not directly or indirectly offer clients parliamentary services and may also seek to influence ministers or parliamentary debates so long as this does not exclusively benefit their employers. We argue these rules are too permissive: being a peer and working for a firm that sells political access to paying clients is a clear conflict of interest.

We are currently undertaking an analysis of Lords’ financial interests in organisations engaged in lobbying and political advisory services, and have found peers enjoying paid employment relating to the provision of political advice, strategic advice, public policy and similar– some of which may be proxy terms for activities such as paid lobbying that are prohibited by the Lords Code of Conduct. We are currently drafting our analysis for publication which we will share with the Ethics and Integrity Commission.

We consider that peers should not sit in the House of Lords while holding registerable interests in firms lobbying on behalf of private clients, or while they engage in paid work for foreign governments. 

Recommendations

The Lords' Code of Conduct should be tightened, with its lobbying rules brought in line with the Commons’. 

Peers should be required either to dispense of their interests in lobbying firms or leave the House of Lords.

The Lords’ Commissioner should impose harsher sanctions for serious breaches of the code of conduct. 

The House of Lords Appointment Commission (HOLAC) should have a role in re-assessing peerages where Lords have committed serious wrongdoing that would have triggered a recall petition were they an MP.

There has been little substantive change to the BARs since 2012, and the current government has not announced any changes to update them despite their manifesto commitment.  The rules could have been updated as part of reforms from July 2025, which included the establishment of the Ethics and Integrity Commission and outlined a new process for administering the rules on the revolving door, but the Government chose not to modernise them. 

In our research “Managing revolving door risks in Westminster”  we outline the key risks that the Business Appointment rules should mitigate against:

• Public officials might favour organisations while in office with a view to ingratiating themselves with them and securing a reward of future employment.
• Former public officials might seek to influence their former government colleagues to make decisions in a way that is sympathetic to their new employer. 
• Former public officials may use confidential information to benefit their new employers – for example during procurement procedures.

Our research found that between January 2017 and June 2022:

• Nearly a third (29 per cent) of all new jobs taken up by former ministers and senior officials had a subject overlap with their previous government brief (177 out of 604 roles).
• Nearly one in ten (19 out of 217) of those seeking advice from ACOBA did so in relation to taking up roles in a consultant lobbyist firm.

Whilst we welcomed the July 2025 policy recommendations for potential new fines (for example expecting former ministers who breach the rules on the revolving door to repay their severance pay as a financial penalty for rule breaking) and plans for the oversight of former ministers and public officials leaving government, it is unclear how these will be enforced and the rules themselves remain unchanged. Therefore, our position remains that the current BARs still do not sufficiently protect the policymaking process from the risks posed by the revolving door and remain in urgent need of reform. Past scandals have demonstrated for example, in the case of Greensill Capital, how a former Prime Minister could have unparalleled access to policy makers without consequence – putting billions of pounds of public money at risk.

Recommendations

The Government should further extend the scope of the Business Appointment Rules so that they prohibit appointments for two years where the applicant has had significant and direct responsibility for policy, regulation or the awarding of contracts relevant to the hiring company.

The lobbying restriction should be extended to at least five years, with consideration of an extension for the most senior roles such as Prime Minister and Chancellor of the Exchequer.

The lobbying ban should include a prohibition on any work for lobbying firms within a set time limit.

The Government should introduce more meaningful sanctions, including binding monetary penalties, for those who breach the Business Appointment Rules.