The Registrar has issued the following guidance specifically for think tanks.
For some time, I have been specifically considering the potential for the work of think tanks to require registration under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014. In the course of this work, I have met a number of think tank executives, undertaken considerable desk research and given careful consideration to the work they do.
As a result, I am now in a position to provide further guidance about the circumstances when think tanks will need to join the Register:
- The think tank is registered for VAT;
- Funding is provided for a specific project (a generic donation is not registrable), where the expectation of the funder is that the end product (for example, a report or an event) will be used to directly communicate with a Minister or Permanent Secretary about Government policy.
- “Direct communications” may be written, oral or electronic. Please note that “lobbying” does not need to be referenced at any stage;
- The funder is able to exercise control over the outcome of the project. If there is an independence clause in the funding agreement/contract, it is unlikely that the think tank would be required to register;
- If the think tank is a registered charity, and all the above criteria apply, registration would be required.
In circumstances where most (but not all) of the above criteria were met, in deciding if think tanks needed to join the Register, I would also have regard to the wider public interest.
If after having read this registration guidance, you remain unsure about whether you need to register, please contact my Office.