Summary of investigation – Devo Agency Limited
July to October 2025
Organisation or person investigated
Devo Agency Limited (“Devo Agency”)
Matter(s) investigated
Whether Devo Agency is an unregistered consultant lobbyist.
Registrar’s decision
Devo Agency carried on the business of consultant lobbying while not being registered.
Summary of rationale for decision
Section 1(1) of the Transparency of Lobbying, Non-Party Campaigning and Trade Union
Administration Act 2014 (“the Act”) states that a person must not carry on the business of
consultant lobbying unless entered in the Register of Consultant Lobbyists (“the Register”).
Section 2 of the Act defines consultant lobbying. A summary of this definition is: UK VAT
registered organisations and individuals who communicate personally with Government
Ministers or Permanent Secretaries (and equivalents) concerning specified matters on behalf
of a third party and in return for payment.
Devo Agency made two direct communications to the Minister for Local Government and English Devolution between 13 May 2025 and June 2025, before registering as a consultant lobbyist on 1 August 2025. The communications were in relation to their clients Greater Manchester; Liverpool; and North East All-Party Parliamentary Groups. Devo Agency was VAT registered at the time of the communications.
The Registrar considers that the two communications were registerable.
Chronology
9 October 2025
Office of the Registrar of Consultant Lobbyists
Summary of investigation – George Freeman
July to October 2025
Organisation or person investigated
George Freeman MP (“Mr Freeman”)
Matter(s) investigated
Whether George Freeman conducted unregistered consultant lobbying
Registrar’s decision
Based on information and advice provided, Mr Freeman has not conducted unregistered consultant lobbying in relation to the matter under investigation.
Summary of rationale for decision
Under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (“the Act”), a registrable communication is made by a VAT registered company or individual communicating with a Minister, Permanent Secretary (or equivalent) on behalf of a paying client.
While the Act can apply to MPs where they make registrable communications, it does not apply to the usual activities of an MP for which they are paid a Parliamentary salary and the Act does not extend to the regulation of Parliamentary questions tabled by an MP in the ordinary course of Parliamentary business.
Chronology
| Date | Action |
| 28 June | Article in The Guardian referencing Mr Freeman’s work for GHGSat. |
| 4 July | Formal letter from the Registrar to Mr Freeman giving background on the requirement for registering and asking if his activities fall within the criteria to be registered with particular reference to, but not limited to, communications for GHGSat referenced in The Guardian on 28 June. |
| 18 July | Letter from Mr Freeman to the Registrar stating that he does not believe that his work is registrable and that he had sought advice from the House of Commons. |
| 11 August | Letter from the Registrar to Mr Freeman setting out the published communications with GHGSat and the subsequent questions put to Ministers in parliament and asking why he considers these not to be communications to Ministers on behalf of a paying client. |
| 12 August | Letter from Mr Freeman saying he is taking advice from the Clerk of Journals of the House of Commons and will be able to respond after 1 September. |
| 18 August | Letter from the Registrar to Mr Freeman extending the deadline for response to 10 September. |
| 11 Sept | Registrar issues statutory information notice to Mr Freeman to respond to the questions in the 4 July letter. |
| 12 Sept | Email from Mr Freeman’s office acknowledging receipt and that of the House authorities would provide advice on why the communications do not fall under the jurisdiction of the Registrar. |
| 12 Sept | Letter from the House of Commons advising that any proceeding in the House of Commons is protected by Article IX of the Bill of Rights 1689. |
| 6 October | Letter from the Registrar concluding the investigation, cancelling the Information Notice and providing advice on continued compliance. |
6 October 2025
Office of the Registrar of Consultant Lobbyists
New Registrar
Please follow the link to the Announcement for the new Registrar of Consultant Lobbyists
https://www.gov.uk/government/news/announcement-for-the-new-registrar-of-consultant-lobbyists
Message from Harry Rich
Harry Rich’s term as Registrar of Consultant Lobbyists ended on 21 September 2025.
I end my term of office as I began, with the firm belief that transparent, ethical lobbying contributes to informed and effective public policy. But this sets a challenge for ministers and policymakers to actively seek out a range of voices, not just those of the most organised or well-funded.
The 2014 Act and the work of ORCL play an important role in bringing consultant lobbying into the public domain. The registration system has many strengths, particularly its clarity and simplicity. As a result, the overwhelming majority of professional public affairs businesses comply fully.
Through awareness-raising and active communication, we have more than doubled the number of businesses on the Register of Consultant Lobbyists over the past seven years. This growth reflects my preference for supporting compliance rather than seeking to catch out those who fall short. That said, the Act also has weaknesses which could be remedied with modest reforms that would better fulfil its transparency goals:
- Extend registration to cover communications with special advisers.
- Require registrants to disclose who was lobbied, on what subject, when, and by what
means. - Address the unintended consequences of exempting those not registered for VAT.
- Clarify the poorly drafted exemption for “incidental lobbying.”
I want to thank the ORCL team for their commitment to our purpose and to the effectiveness of our operational, awareness and compliance work and their support in my complex investigations of potential breaches of the Act. I am also grateful to Ministers and Cabinet Office colleagues for their support over the past seven years and above all for their consistent recognition of the independence of the role of Registrar.
Finally, I warmly welcome my successor, Claire Bassett, as she takes on this rewarding and demanding role.
Harry Rich
19 September 2025
Summary of investigation – Lord Dannatt
August to September 2025
Organisation or person investigated
The Lord Dannatt GCB CBE MC (“Lord Dannatt”)
Matter(s) investigated
Whether Lord Dannatt conducted unregistered consultant lobbying
Registrar’s decision
Based on information and assurances provided, Lord Dannatt has not conducted unregistered consultant lobbying in relation to the matter under investigation.
Summary of rationale for decision
Based on substantive and unequivocal written information provided, Lord Dannatt made an otherwise registrable communication for which the incidental exemption applies.
Under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (“the Act”), a registrable communication is made by a VAT registered company or individual communicating with a Minister, Permanent Secretary (or equivalent) on behalf of a paying client.
Under the Act there is an incidental exception and my guidance sets out how I apply this narrow exception. Based on the information and assurances provided, the communication was not a substantive part of the main business assessed either:
- by volume; or
- by the value of the work undertaken; or
- by its significance to the client offering; or
- by the significance of its contribution to the business’s non-lobbying activities.
Chronology
15 September 2025
Office of the Registrar of Consultant Lobbyists
Summary of investigation – Labour Infrastructure Forum
July to September 2025
Organisation or person investigated
Labour Infrastructure Forum (“LIF”)
Matter(s) investigated
Whether LIF conducted unregistered consultant lobbying
Registrar’s decision
Based on information and assurances provided, LIF has not conducted unregistered consultant lobbying in relation to the matter under investigation.
Summary of rationale for decision
LIF is not registered for VAT and cannot therefore register under the Act.
Under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (“the Act”), a registrable communication is made by a VAT registered company or individual communicating with a Minister, Permanent Secretary (or equivalent) on behalf of a paying client.
Chronology
10 September 2025
Office of the Registrar of Consultant Lobbyists
Summary of investigation – Hakluyt
July – September 2025
Organisation or person investigated
Hakluyt
Matter(s) investigated
Whether Hakluyt conducted unregistered consultant lobbying
Registrar’s decision
Based on information and assurances provided, Hakluyt has not conducted unregistered consultant lobbying in relation to the matter under investigation.
Summary of rationale for decision
Based on substantive and unequivocal written information provided, Hakluyt did not communicate with Ministers on behalf of paying clients. The communications with a Minister of State at the Department of Business and Trade and with the Secretary of State for Business, Energy and Industrial Strategy are therefore not registrable.
Under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (“the Act”), a registrable communication is made by a VAT registered company or individual communicating with a Minister, Permanent Secretary (or equivalent) on behalf of a paying client.
Chronology
9 September 2025
Office of the Registrar of Consultant Lobbyists
Preferred Candidate Announcement
Following a recruitment campaign, the Cabinet Office has announced their preferred candidate for Registrar of Consultant Lobbyists. The current Registrar’s term will end later this month.
FIRS webinar
The Home Office will run the final webinar of the grace period for the Foreign Influence Registration Scheme on 10 September. More information is available here. Please note FIRS is not administered by ORCL.
Register of External Gifts and Hospitality 25/26
You can download below a record of all external gifts and hospitality for 2025/26 for the Registrar.
Last updated August 2025