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According to Section 6(4) of the Act:
“… The Registrar must update the Register to include any information or change which is notified in an information return…” and in Section 5(2): “… The information return for a quarter must contain- (a) either the client information for that quarter or a statement under subsection (5), and (b) details of any change in that quarter in the particulars included in the Register under section 4(2)…”
and in Section 6 (5)
“… The Registrar must comply with subsection (4)-(a) if the return is received before the end of the period specified in section 5(6), before the end of the period of 4 working days beginning with the day after the day on which the return is received, or (b) if the return is received after the end of that period, before the end of the period of 8 working days beginning with the day after the day on which the return is received…”
I have interpreted these requirements such that if there are significant problems of clarification of information from quarterly returns, it is reasonable to delay publication whilst those problems are being clarified. Once the quarterly information update or nil return has been published, the client information or nil return will be published on the face of the current Register for three years from the date the information was first published or when the registrant ceased the business of consultant lobbying, whichever is the latest. All quarterly return information will continue to be available for the same five year period that the Register is available in the archived information.
In the event that subsequent changes come to light, if the change is an administrative error (e.g. a spelling mistake), it would be my intention to correct it, without recording the previous information. If the change is substantive (e.g. a change to the name of a client, an additional client, or the removal of a client), the previous information will be recorded on the Register (e.g. “previous client details”) with the date of change.
This guidance is also available as a PDF.