Business Plan
Published on: Wednesday 4th June 2025
2025 to 2026
Office of the Registrar of Consultant Lobbyists
1 Horse Guards Road (Room 3.26)
London, SW1A 2HQ
020 7271 8827
Table of contents
Purpose and 2025 to 2026 objectives.
Objective 1: Operate an accurate and accessible Register
Objective 2: Provide clear, accessible guidance
Objective 3: Communicate and engage with stakeholders
Objective 4: Ensure compliance
Objective 5: Ensure administrative effectiveness and transparency
The Registrar
The Registrar is an independent statutory office holder appointed under the Transparency of Lobbying, Non-party Campaigning and Trade Union Administration Act 2014 (‘the Act’).
Under the Act, the Registrar is required to:
- establish and manage the UK Register of Consultant Lobbyists;
- develop and publish detailed guidance for consultant lobbyists on their duties under the Act;
- monitor and enforce compliance with the Act’s legal requirements; and
- publish an annual statement of accounts.
The Act sets out two key obligations on consultant lobbyists as defined by the Act:
- register before conducting any consultant lobbying activity;
- submit details of clients they have lobbied for or been paid to lobby for each quarter.
The Registrar collects and accounts for all fees and pays them into the Consolidated Fund. More information about the Registrar’s budget is available in the published Statement of Accounts. Ministers set the fees for the Register and seek to ensure that the total paid in charges is sufficient to offset the total of the costs. The Cabinet Office meets the cost of seconded staff and shared
Introduction
This business plan sets out how I intend to fulfil my statutory obligations in the year from April 2025 and includes a review of 2024-2025. This is the eleventh annual business plan for the Office of the Registrar of Consultant Lobbyists.
My role as Registrar is set out in the Transparency of Lobbying, Non-party Campaigning and Trade Union Administration Act 2014 (‘the Act’). The Registrar is independent of government and the public affairs sector and I account to Parliament for implementation of the provisions of the Act.
Transparent, ethical lobbying can play an important part in effective public policy making. But for this to be the case politicians and officials must also actively seek and consider a variety of policy inputs, not only those from the most organised or well-funded parties. The work of my Office supports this by putting the activities of consultant lobbyists into the public domain.
During 2025-2026 my Office will continue to seek improvements to our processes and activities to maximise transparency, aid compliance and minimise the burden on registrants. This will include a further review of my guidance and continued awareness raising communications. We will continue to explore whether AI can usefully support our work with registrants and other stakeholders.
My preference is to support compliance and my Office works with registrants and potential registrants to provide information and advice. Alongside this, I enforce the requirements of the Act with clarity, using statutory penalties where necessary and investigate where there is reasonable information to suggest non-compliance.
I have consistently advocated to the outgoing and incoming governments a number of changes that I consider necessary to realise the transparency intentions of the Act. These are:
- Make communications with special advisers registrable.
- Require registrants to declare who was lobbied, on what subject, when and by what medium.
- Address the adverse consequences of exemption from the requirements of the Act of those not registered for VAT.
- Clarify the poorly drafted exemption for ‘incidental lobbying’.
These proposals were fully endorsed by the Parliamentary and Constitutional Affairs Committee (PACAC) in their report 30 April 2024. Despite this and almost universal support from the public affairs sector and experts in the UK and beyond, the previous government made no changes and, to date, the current government has not indicated any intention to improve transparency in consultant lobbying.
Harry Rich
Registrar of Consultant Lobbyists and Accounting Officer
Review of 2024 to 2025
This review of the year to 31 March 2025 is set against the objectives that I published for the Office of the Registrar in the 2024-25 business plan.
At 31 March 2025 the Register had 240 registrants, compared to 213 at the end of March 2024. My Office continued awareness raising activity over the last year, with a particular focus around the general election in July 2024. The increase in new registrants indicates strong awareness and we saw a significant increase in registrants following the general election.
I updated my formal guidance in February 2025. The key changes were to clarify the requirement to declare pre-registration consultant lobbying; greater detail on registration of trading subsidiaries; require representations in response to a notice of intention to impose a penalty to be on the form provided with the notice; and greater detail on liability for offences. I also merged my Guidance on registration and Guidance on compliance into a single document.
During the year I worked with the OECD’s Working Party of Senior Public Integrity Officials, the European Lobbying Registrars’ Network and the newly-formed OECD Lobbying Commissioners & Registrars Forum, participating in two conferences to exchange information about international good practice in lobbying transparency. I met and exchanged insights with the chairs of other independent offices involved in overseeing integrity in UK public life.
Objective 1: Operate an accurate and accessible Register
Maintain the accuracy and timeliness of information contained in the Register and ensure that systems are accessible and meet user needs.
Objective 1: Activity 1
Support new registrants and check their data to ensure accurate and timely registration and compliance.
Update: New registrants actively supported and registration information checked for accuracy. All new registrations published within four working days of complete registration application.
Objective 1: Activity 2
Support and enforce timely submission of Quarterly Information Returns and updating of registration and code of conduct data by registrants.
Update: QIRs generally submitted on time and continued rigour in enforcement of compliance. Online induction sessions offered to registrants. Registrants with more than two consecutive quarterly nil returns contacted to check accuracy. Checks conducted on consistent naming of clientsand code of conduct declarations, for accuracy.
Objective 1: Activity 3
Continue to improve user experience, minimise the administrative burden and monitor systems and feedback for potential improvements.
Update: Feedback survey sent to new registrants and open survey on the website for suggested system and website improvements. Ongoing monitoring, working with service provider.
Objective 2: Provide clear, accessible guidance
Keep published guidance under review and take account of feedback from registrants and other stakeholders.
Objective 2: Activity 1
Review guidance to ensure clarity for registrants and others and consult on any significant proposed changes.
Update: Formal guidance updated in February 2025. Key changes: clarify requirement to declare pre-registration consultant lobbying; greater detail on registration of trading subsidiaries; require representations in response to a notice of intention to impose a penalty to be on the form provided; and greater detail on liability for offences. Merged Guidance on registration and Guidance on compliance into a single document.
Objective 2: Activity 2
Offer information and support to the Private Offices of Ministers and Permanent Secretaries (and equivalents) to aid their understanding of the statutory obligations on consultant lobbyists they engage with. This action will be post-election and following post legislative scrutiny changes.
Update: Not done. Awaiting any post-legislative scrutiny outcomes.
Objective 2: Activity 3
Provide guidance to other stakeholders as necessary.
Update: Wrote to all MPs on dissolution of parliament and to ex-MPs starting consultancies.
Objective 3: Communicate and engage with stakeholders
Deliver a programme of communication and engagement with registrants, potential registrants, representative bodies and other stakeholders.
Objective 3: Activity 1
Work with public affairs businesses and their representative bodies to understand them and support awareness and compliance by registrants and those who may engage in consultant lobbying in the future.
Update: Communicated with CIPR and PRCA.
Objective 3: Activity 2
Review engagement activities to respond to potential new consultant lobbyists following the election.
Update: In addition to writing to all MPs, prior to the election, over 40 awareness letters sent in the two months following the election. There was a significant increase in registrations following the election indicating that awareness was high.
Objective 3: Activity 3
Deliver regular induction and update seminars for new and existing registrants to support compliance with statutory duties.
Update: Offered quarterly webinars, which were well-attended.
Objective 3: Activity 4
Disseminate information about the Register to relevant audiences.
Update: Information and updates provided directly to registrants. Awareness activities identify and target those who may engage in consultant lobbying.
Objective 3: Activity 5
Update registrants and stakeholders on any impacts of December 2020 post-legislative scrutiny of the Act when implemented by the government.
Update: No updates because no changes implemented by the outgoing or incoming governments.
Objective 3: Activity 6
Work with and share good practice with other bodies such as the European Lobbying Registrars’ Network (ELRN), the Advisory Committee on Business Appointments (ACOBA) and the Organisation for Economic Cooperation and Development (OECD).
Update: The Registrar attended: OECD conference, working party of Senior Public Integrity Officials, ELRN conference and meetings with the Chairs of Independent Offices. ORCL wrote to some of those receiving ACOBA correspondence to promote awareness of statutory duties under the Act.
Objective 4: Ensure compliance
Ensure that all those who ought to register do so and that quarterly information returns are monitored.
Objective 4: Activity 1
Enforce compliance, making use of statutory penalties where appropriate.
Update: 12 notices of intention to issue a civil penalty issued during the year (2023-24: 19), the bulk of which resulted in a penalty being issued. One information notice issued (2023-24: three).
Objective 4: Activity 2
Review departmental transparency data in relation to Ministers and Permanent Secretaries against declarations on the Register.
Update: Ministers’ and Permanent Secretaries’ meetings and hospitality data reviewed, resulting in one investigation.
Objective 4: Activity 3
Undertake formal investigations where there is reasonable information suggesting non-compliance.
Update: Registrar initiated or continued 13 formal investigations (2023-24: 18) and published summaries of findings of 10 concluded investigations (2023-24: 15).
Objective 5: Ensure administrative effectiveness and transparency
Operate the Office effectively and transparently to deliver against statutory purposes, serving all stakeholders and achieving value for money.
Objective 5: Activity 1
Deliver proportionate risk management and corporate governance to ensure effective administration of the Office.
Update: The Registrar reviews strategic risks each quarter and takes responsibility for governance.
Objective 5: Activity 2
Fulfil statutory and legal obligations in relation to data protection and freedom of information.
Update: Complied with freedom of information duties and with data protection legislation, working with Cabinet Office as joint data controller.
Objective 5: Activity 3
Publish details of the Registrar’s formal correspondence and meetings, statutory information notices, notices of intention to impose penalties (and their conclusion) summaries of investigations and a gifts and hospitality register.
Update: All published on website of the Office of the Registrar.
Objective 5: Activity 4
Update Ministers on the work of the Office through business planning and financial reporting systems.
Update: Registrar updated Cabinet Office officials and sponsor Minister at Cabinet Office as required, including meeting the incoming Cabinet Office Minister.
Objective 5: Activity 5
Report to Parliament as required.
Update: The Registrar’s annual report and accounts for year to 31 March 2024 was laid before Parliament 29 July 2024 and a copy sent to Public Administration and Constitutional Affairs Committee (PACAC) following the Chair’s election in September.
Objective 5: Activity 6
Comply with the Memorandum of Understanding with the Cabinet Office and update by November 2024.
Update: Memorandum updated with the Cabinet Office in January 2025 and published on the Office of the Register of Consultant Lobbyists website. Its provisions are adhered to.
Objective 5: Activity 7
Operate the Office’s financial management systems (including those operated for us by the Cabinet Office), to ensure proportionality, accuracy, effectiveness and value for money.
Update: Worked with Cabinet Office finance team to manage budget, forecasting and monitoring. Minimised costs and optimised value for money, while delivering statutory duties.
Objective 5: Activity 8
Ensure that Business Continuity Plans are understood and reviewed.
Update: Business Continuity Plan in place and reviewed.
Objective 5: Activity 9
Work with our suppliers to monitor and maintain cyber security.
Update: Wework with suppliers for development and security of the Register and website.
Objective 5: Activity 10
Start to explore whether and how Artificial Intelligence might support our work.
Update: Registrar attended a Global Government Forum on AI and Regulation. The Office monitors developments and considers potential future use of AI.
Objective 5: Activity 11
Support and encourage ORCL team learning and development with the Cabinet Office.
Update: Learning and development opportunities encouraged and taken up by the team.
Purpose and 2025 to 2026 objectives
The purpose of the Office of the Registrar of Consultant Lobbyists is to ensure that there is transparency in the engagement of consultant lobbyists with Ministers and Permanent Secretaries (and equivalents) on behalf of their clients, in accordance with the requirements of the Act.
In line with my statutory obligations, I have set these objectives for 2025-26:
- Operate an accurate and accessible Register
- Provide clear, accessible guidance
- Communicate and engage with stakeholders
- Ensure compliance
- Ensure administrative effectiveness and transparency.
The activities that will deliver against these objectives are set out on the following pages.
Activity 2025 to 2026
Objective 1: Operate an accurate and accessible Register
Maintain the accuracy and timeliness of the information in the Register and ensure that systems are accessible and meet user needs.
Why this matters:
Data integrity and accessibility are vital for the credibility of the Registration system: stakeholders must have confidence that information is accurate and must be able to access and use it easily.
We will:
- Support new registrants and check their data to ensure accurate and timely registration and compliance.
- Support and enforce timely submission of accurate Quarterly Information Returns and updating of registration and code of conduct data by registrants.
- Continue to improve user experience, minimise the administrative burden and monitor systems and feedback for potential improvements.
Objective 2: Provide clear, accessible guidance
Keep the Registrar’s formal guidance under review and take account of feedback from registrants and other stakeholders.
Why this matters:
Clear guidance on the requirements of the Act helps registrants to understand their legal obligations and to comply more easily. It also helps other stakeholders to understand and support the registration system.
We will:
- Review guidance to ensure clarity for registrants and others and consult on any significant proposed changes.
- Offer information and support to Private Offices of Ministers and Permanent Secretaries (and equivalents) to aid their understanding of the statutory obligations on consultant lobbyists they engage with.
- Provide information to other stakeholders as necessary.
Objective 3: Communicate and engage with stakeholders
Deliver a programme of communication and engagement with registrants, potential registrants, representative bodies and other stakeholders.
Why this matters:
Engagement, two-way communication and information supports compliance by registrants and awareness and understanding by all stakeholders.
We will:
- Work with public affairs businesses and others engaged in consultant lobbying and their representative bodies to understand them and support awareness and compliance by registrants and those who may engage in consultant lobbying in the future.
- Deliver regular induction and update seminars for new and existing registrants to support compliance with statutory duties.
- Disseminate information about the Register to relevant audiences.
- Work with and share good practice with other bodies such as the European Lobbying Registrars’ Network, the Advisory Committee on Business Appointments (ACOBA) and the Organisation for Economic Cooperation and Development (OECD).
Objective 4: Ensure compliance
Ensure that all those who ought to register do so and that quarterly information returns are monitored.
Why this matters:
The credibility of the registration system depends on the public and industry having confidence in the completeness and accuracy of the Register.
We will:
- Enforce compliance, making use of statutory penalties where appropriate.
- Review departmental transparency data in relation to Ministers and Permanent Secretaries against declarations on the Register.
- Undertake formal investigations where there is reasonable information suggesting non- compliance.
Objective 5: Ensure administrative effectiveness and transparency
Operate the Office effectively and transparently to deliver against statutory purposes, serving all stakeholders and achieving value for money.
Why this matters:
Our administrative arrangements must support effective delivery of the Registrar’s statutory duties with proper levels of transparency and accountability, whilst keeping the administrative and financial burden on registrants as low as possible.
We will:
- Deliver proportionate risk management and corporate governance to ensure effective administration of the Office.
- Fulfil statutory obligations in relation to data protection and freedom of information.
- Publish details of the Registrar’s formal correspondence and meetings, statutory information notices, notices of intention to impose penalties (and their conclusion) summaries of investigations and a gifts and hospitality register.
- Update Ministers on the work of the Office through business planning and financial reporting systems.
- Report to Parliament as required.
- Comply with the Memorandum of Understanding with the Cabinet Office.
- Operate the Office’s financial management systems (including those operated for us by the Cabinet Office), to ensure proportionality, accuracy, effectiveness and value for money.
- Ensure that Business Continuity Plans are understood and reviewed.
- Work with our suppliers to monitor and maintain cyber security.
- Continue to explore whether and how Artificial Intelligence might support our work.
- Support and encourage ORCL team learning and development with the Cabinet Office.
Budget 2025 – 2026
| Resource | 2025 to 2026 budget | 2024 to 2025 budget |
| Registrar’s fees and expenses | £28,000 | £28,000 |
| Register and website | £67,000 | £78,000 |
| Other costs (legal and enforcement, communication, travel, training) | £60,000 | £60,000 |
| Audit fee | £25,000 | £19,000 |
| Programme costs | £180,000 | £185,000 |
| Seconded staff payroll costs | £190,000 | £190,000 |
| Cabinet Office shared services (including finance, IT, accommodation) | £70,000 | £38,000 |
| Resource expenditure financed by Grant in Aid from the Cabinet Office | £440,000 | £413,000 |
| Income | -£240,000 | -£213,000 |
| Resource Departmental Spending Limit (RDEL) | £200,000 | £200,000 |
Notes
Costs are offset by income from registration fees, estimated to be £240,000, which is remitted to the Consolidated Fund.
In accordance with the Act and the Memorandum of Understanding, payroll cost of staff seconded to the Office and shared services costs are absorbed by the Cabinet Office. These costs will be partially offset by fee income.
Legal costs, which include a charge from HM Courts & Tribunals Service for appeals, vary from year to year and are difficult to predict.
Accommodation, shared services and audit costs are determined by Cabinet Office and NAO respectively. The Cabinet Office and NAO charges have increased significantly in 2024-25 and again in 2025-26.
Registration fees
Registration fees are set by Ministers and in 2016 they announced that the fee of £1000 per annum would be held for the spending review period to 2020. The estimated fee income for 2025-2026 is based on £1,000 per annum.