Have you registered with the Foreign Influence Registration Scheme (FIRS)?
The Foreign Influence Registration Scheme comes into effect from 01 July 2025. The scheme is a major step in protecting our democracy and society.
The political tier requires those carrying out political influencing activities on behalf of a foreign power to register their activities.
The enhanced tier requires the registration of a wide range of activities carried out on behalf of Russia and Iran.
Registering an arrangement does not mean it is illegitimate, or must cease. Indeed, those declaring their links to foreign powers are supporting the resilience of the UK and its institutions in the face of state threats. There is a three month grace period for those in registerable arrangements when the scheme comes into force. You can find more information about FIRS here and see business and industry guidance here or contact the FIRS team: FIRS-General-Enquiries@homeoffice.gov.uk.
Business Plan
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.
Summary of investigation – Baroness Bloomfield
April – May 2025
Organisation or person investigated
The Baroness Bloomfield of Hinton (“Baroness Bloomfield”)
Matter(s) investigated
Whether Baroness Bloomfield conducted unregistered consultant lobbying
Registrar’s decision
Based on information and assurances provided, Baroness Bloomfield 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, Baroness Bloomfield is not UK VAT registered. She has therefore not conducted unregistered consultant lobbying in relation to the matter under investigation.
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
| Date | Action |
| 9 April | Article in The Guardian regarding Baroness Bloomfield. |
| 23 April | Formal letter from the Registrar to Baroness Bloomfield giving background on the requirement for registering and asking if activities, whether individually or through a company, fall within the criteria to be registered with particular reference to, but not limited to, Terrestrial Energy Limited and communications referenced in The Guardian article. |
| 5 May | Letter from Baroness Bloomfield stating that she was not paid for the communication and providing evidence that she is not VAT registered. |
| 8 May | Letter from the Registrar concluding his investigation. |
8 May 2025
Office of the Registrar of Consultant Lobbyists
Summary of investigation – Lord Dannatt
March – May 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 did not receive payment for the meeting on 27 June 2022, whether as an individual or through a company. He has therefore not conducted unregistered consultant lobbying in relation to the matter under investigation.
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
| Date | Action |
| 14 March | Article in The Guardian regarding Lord Dannatt. |
| 19 March | Formal letter from the Registrar to Lord Dannatt giving background on the requirement for registering and asking if activities, whether individually or through a company, fall within the criteria to be registered with particular reference to, but not limited to, two communications. |
| 29 March | Email from Lord Dannatt to the Registrar stating that the first communication pre-dates the Act and giving further information regarding a meeting with a Departments of Business Energy and Industrial Strategy minister on 27 June 2022. Lord Dannatt stated that both communications were unpaid. |
| 8 April | Letter from the Registrar to Lord Dannatt requesting further information about his or his company’s arrangements with Law Fertilisers. |
| 11 April | Email from Lord Dannatt giving further detail including that paid work started subsequent to completion of government engagement. |
| 15 April | Letter from the Registrar to Lord Dannatt requesting further information regarding the contract or terms under which Lord Dannatt’s company, Mill House Partners, was paid. |
| 23 April | Email from Lord Dannatt to the Registrar providing detailed information on his relationship with Law Fertilisers and with UK Nitrogen. |
| 29 April | Letter from the Registrar to Lord Dannatt requesting details of invoice dates and the periods and services that they covered. |
| 2 May | Email from Lord Dannatt to the Registrar providing invoice details. |
| 8 May | Letter from the Registrar concluding his investigation. |
8 May 2025
Office of the Registrar of Consultant Lobbyists
Summary of investigation – Lord Duncan
April 2025
Organisation or person investigated
The Lord Duncan of Springbank (“Lord Duncan”)
Matter(s) investigated
Whether Lord Duncan conducted unregistered consultant lobbying
Registrar’s decision
Based on information and assurances provided, Lord Duncan 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 Duncan is not UK VAT registered, whether as an individual or through a company. He has therefore not conducted unregistered consultant lobbying in relation to the matter under investigation.
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
| Date | Action |
| 10 April | Article in The Guardian regarding Lord Duncan’s communications with the Parliamentary Under Secretary of State at the Department for Energy Security and Net Zero. |
| 14 April | Formal letter from the Registrar to Lord Duncan giving background on the requirement for registering and asking if activities, whether individually or through a company, fall within the criteria to be registered with particular reference to, but not limited to, the communications shown in The Guardian article. |
| 28 April | Letter from Lord Duncan giving background to his work for Terrestrial Energy Inc. This included confirmation that neither Lord Duncan nor his company were UK VAT registered. |
| 30 April | Letter from the Registrar concluding his investigation. |
30 April 2025
Office of the Registrar of Consultant Lobbyists
Quarter One (January-March 2025)Returns Data
There is an ongoing issue with report for the January-March 2025 quarter that we are working on
resolving. Whilst we work on resolving this issue an accurate report can be downloaded below.
Summary of investigation – Octavius GB Limited
February to April 2025
Organisation or person investigated
Octavius GB Limited (“Octavius”)
Matter(s) investigated
Whether Octavius conducted unregistered consultant lobbying.
Registrar’s decision
Based on information and assurances provided, Octavius 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, Octavius has not made communications with ministers for paying clients. Octavius has therefore not conducted unregistered consultant lobbying in relation to the matters under investigation. A separate investigation into Lord Evans of Watford found that he was not paid as an individual, nor through a company, for the events in question.
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
| Date | Action |
| 25 Feb | Article in The Guardian regarding sponsorship of events. |
| 27 Feb | Formal letter from the Registrar to Balmoral Global Capital Limited giving background on the requirement for registering and asking if activities, whether individually or through a company, fall within the criteria to be registered with particular reference to, but not limited to, the Guardian’s article of 25 February. |
| 28 Feb | Email from Octavius stating they are not a lobbying firm. |
| 3 March | Letter from the Registrar to Octavius asking further questions. |
| 3 March | Email from Octavius providing information about AFFINITY and Octavius. |
| 11 March | Letter from the Registrar requesting further clarity regarding AFFINITY, Octavius and Balmoral Global Limited. |
| 27 March | Information Notice issued for responses to questions in the Registrar’s letter of 11 March. |
| 27 March | Email from Octavius providing an initial response. |
| 30 March | Email from Octavius providing further response to the Information Notice. |
| 22 April | Letter from the Registrar concluding his investigation. |
22 April 2025
Office of the Registrar of Consultant Lobbyists
Summary of investigation – The Lord Gadhia
March – April 2025
Organisation or person investigated
The Lord Gadhia (“Lord Gadhia”)
Matter(s) investigated
Whether Lord Gadhia conducted unregistered consultant lobbying
Registrar’s decision
Based on information and assurances provided, Lord Gadhia 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 Gadhia is not UK VAT registered, he has therefore not conducted unregistered consultant lobbying in relation to the matter under investigation.
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
| Date | Action |
| 20 March | Article in The Guardian regarding Lord Gadhia. |
| 24 March | Formal letter from the Registrar to Lord Gadhia giving background on the requirement for registering and asking if his activities, whether individually or through a company, fall within the criteria to be registered with particular reference to, but not limited to, the meeting of 16 February 2021 cited in The Guardian article of 20 March. |
| 7 April | Email from Lord Gadhia to the Registrar confirming and providing evidence that he is not UK VAT registered. |
| 9 April | Letter from the Registrar concluding his investigation. |
9 April 2025
Office of the Registrar of Consultant Lobbyists
Summary of investigation – The Lord Evans of Watford
February to March 2025
Organisation or person investigated
The Lord Evans of Watford (“Lord Evans”)
Matter(s) investigated
Whether Lord Evans conducted unregistered consultant lobbying
Registrar’s decision
Based on information and assurances provided, Lord Evans 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 Evans did not receive any payment as an individual, nor through a company, he has therefore not conducted unregistered consultant lobbying in relation to the matter under investigation.
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
| Date | Action |
| 25 Feb | Article in The Guardian regarding Lord Evans. |
| 27 Feb | Formal letter from the Registrar to Lord Evans giving background on the requirement for registering and asking if his activities, whether individually or through a company, fall within the criteria to be registered with particular reference to, but not limited to, the communications set out in The Guardian article of 25 February. |
| 19 March | Letter from the Registrar requesting response to letter of 27 February. |
| 19 March | Email from Lord Evans stating he has never asked for money, nor reward, for asking a minister for access. |
| 24 March | Letter from the Registrar asking about financial relationships and roles with the company, or companies, in relation with any ministerial communications and in particular regarding three events. |
| 24 March | Email from Lord Evans responding fully to the Registrar’s questions. |
| 26 March | Email from Registrar’s Office requesting written evidence referred to in Lord Evans’ email of 24 March. |
| 26 March | Email from Lord Evans providing evidence. |
| 28 March | Letter from the Registrar concluding his investigation. |
28 March 2025
Office of the Registrar of Consultant Lobbyists
Summary of investigation – The Rt. Hon. Owen Paterson
January 2023 – February 2025
Organisation or person investigated
The Rt. Hon. Owen Paterson (“Mr Paterson”)
Matter(s) investigated
Whether Mr Paterson carried on the business of consultant lobbying without being registered.
Registrar’s decision
That Mr Paterson 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.
Mr Paterson was a paid consultant for Randox Laboratories Ltd (“Randox”). He personally made six direct communications to the then Secretary of State for Health and Social Care between 26 January 2020 and 24 October 2020. The communications were in relation to Mr Paterson’s client, Randox, and the communications related to matters specified in section 2(3) of the Act. Mr Paterson was VAT registered at the time of the communications. The above six communications were registerable.
Mr Paterson was not registered on the Register at the material time when the communications were made and so was in breach of section 1(1) of the Act. The Registrar has therefore issued to Mr Paterson a penalty notice under section 16 of the Act in the sum of £7,500.
Chronology
| Date | Action |
| 13-12-22 | Letter from the Registrar to the Department for Health and Social Care (“DHSC”) requesting copies of communications from Mr Paterson to Ministers concerning Randox. |
| 12-01-23 | Email from DHSC providing copies of communications from Mr Paterson to Ministers. |
| 24-01-23 | Letter from the Registrar to DHSC regarding the communications. |
| 24-01-23 | Letter from the Registrar to Devonshires, representing Mr Paterson (“Devonshires”), regarding Mr Paterson’s communications with the then Secretary of State for Health and Social Care. |
| 03-02-23 | Letter from Devonshires, inter alia, requesting the Registrar to issue a statutory Information Notice prior to Mr Paterson responding to the Registrar’s questions in his letter of 24 January 2023. |
| 07-02-23 | Registrar issues a statutory Information Notice seeking a response to the questions asked in his letter of 24 January 2023. |
| 09-02-23 | Letter from Devonshires stating that their client is not a consultant lobbyist but otherwise not providing answers to the letter of 24 January 2023. |
| 09-03-23 | Letter from the Registrar to DHSC seeking to confirm the provenance of the messages provided on 12 January 2023. |
| 09-03-23 | Letter from Devonshires, inter alia, stating that Mr Paterson has no records and cannot recall the details of the exchanges and asking the Registrar to close the investigation. |
| 22-03-23 | Letter to the Registrar from DHSC confirming that the messages provided on 12 January 2023 were between Mr Paterson and the then Secretary of State for Health and Social Care. |
| 23-03-23 | Letter from the Registrar to Devonshires responding to points raised in their letter of 9 March 2023 and requesting evidence regarding their assertion that Mr Paterson’s communications to Ministers were incidental[1] to his consultancy business. |
| 30-03-23 | Email from Devonshires requesting an extension to the deadline for a response. Over the following weeks the Registrar corresponded with Mr Paterson’s representative in relation to the deadline for a response. |
| 06-04-23 | DHSC letter confirming the provenance of the communications provided on 12 January 2023. |
| 29-08-23 | Letter from Devonshires stating their intention to respond to the issues raised by the Registrar and requesting copies of the DHSC communications referenced in the Registrar’s letter of 24 January 2023. |
| 11-09-23 | Letter from the Registrar to Devonshires providing the DHSC messages referenced and requesting a response to his letter of 23 March 2023 by 27 September 2023. |
| 03-10-23 | Letter from Devonshires neither providing evidence nor answering the questions in the Registrar’s 23 March 2023 letter. |
| 30-10-23 | Registrar issues a statutory Information Notice seeking the information and evidence requested on 23 March 2023. |
| 21-11-23 | Devonshires requests an extension to respond to the statutory Information Notice to 15 December 2023. |
| 21-11-23 | Registrar agrees to the extension. |
| 15-12-23 | Devonshires responds to the Registrar’s letter of 23 March 2023 and states an intention to appeal against the statutory Information Notice. |
| 15-12-23 | Devonshires submits an appeal to the First-tier Tribunal (General Regulatory Chamber) (“GRC”) against the Information Notice of 30 October 2023. |
| 03-01-24 | Government Legal Department (“GLD”), representing the Registrar, writes to the GRC regarding Mr Paterson’s appeal of 15 December 2023 to inform them it was made 18 days late. |
| 03-01-24 | Letter from the Registrar to Devonshires stating that Mr Paterson’s appeal is out of time and that, assuming the letter of 15 December 2023 is as full and accurate an account as their client is able to give, the Information Notice is closed. |
| 03-01-24 | Letter from Devonshires to the Registrar, inter alia, offering a meeting with Mr Paterson. |
| 02-02-24 | GRC dismissal of Mr Paterson’s appeal is received by GLD (although dated 18 December 2023). |
| 08-04-24 | Letter from the Registrar to Devonshires stating that he is “minded to” conclude that Mr Paterson has conducted consultant lobbying activity in relation to the communications subject to his investigation and requesting any further representations and evidence prior to making any formal provisional decision. |
| 19-04-24 | Letter from Devonshires to the Registrar requesting an extension to respond to the Registrar’s letter of 8 April 2024. |
| 19-04-24 | Letter from the Registrar to Devonshires agreeing to the deadline extension. |
| 30-04-24 | Letter, witness statement and evidence from Devonshires to the Registrar disputing that Mr Paterson had conducted consultant lobbying. |
| 03-07-24 | Letter from the Registrar and a Notice of Intention to issue a civil penalty. |
| 09-08-24 | Letter from Devonshires to the Registrar making representations against the Notice of Intention and providing a further witness statement from Mr Paterson. |
| 23-08-24 | Letter from the Registrar to Devonshires stating, inter alia, that he would make enquiries of Randox and requesting a letter of consent from Mr Paterson to facilitate this. |
| 30-08-24 | Email from Devonshires to the Registrar, agreeing to provide consent. |
| 02-09-24 | Letter from the Registrar to Devonshires outlining the areas of intended enquiry with Randox. |
| 03-09-24 | Email from Devonshires to the Registrar attaching a letter sent by Mr Paterson to Randox on 30 August 2024, giving consent. |
| 04-09-24 | Email from the Office of the Registrar of Consultant Lobbyists (“ORCL”) to Devonshires requesting consent for Randox to respond to the Registrar’s enquiries on a wider basis, as outlined in the Registrar’s letter of 2 September 2024. |
| 12-09-24 | Email from ORCL to Devonshires requesting confirmation of receipt of the email of 4 September 2024. |
| 13-09-24 | Email from Devonshires to ORCL saying they will respond early next week. |
| 18-09-24 | Email from Devonshires to the Registrar, referring him to the consent letter of 30 August 2024 provided on 3 September 2024. |
| 23-09-24 | Letter from the Registrar to Devonshires requesting their client to provide a consent letter to Randox, covering the scope of the enquiries set out in the letter of 2 September 2024. |
| 26-09-24 | Letter from Devonshires to the Registrar, inter alia, agreeing to provide a letter of consent as requested. |
| 27-09-24 | Letter from the Registrar to Devonshires asking for confirmation of when their client’s consent letter has been sent to Randox. |
| 1-10-24 | Mr Paterson sends to Randox a letter of consent to respond to the Registrar’s enquiries. |
| 2-10-24 | Letter from the Registrar to Randox, requesting information regarding Mr Paterson’s consultancy work for them. |
| 29-10-24 | Letters from the Registrar to three Randox directors asking whether Randox intends to reply to the information request of 2 October 2024. |
| 12-11-24 | Letter from the Registrar to Devonshires offering their client an opportunity to prompt Randox to respond. |
| 25-11-24 | Letter from Devonshires to the Registrar, inter alia, saying that Mr Paterson had also tried to contact Randox with no response and attaching a statement previously provided by a Randox employee from 2021. |
| 26-02-25 | Letter from the Registrar to Devonshires, concluding the investigation. Penalty notice issued. |
26 February 2025
Office of the Registrar of Consultant Lobbyists