Guidance update
The Registrar updated the guidance today.
Summary of investigation – Global Counsel Limited (“GCL”)
October 2024 – February 2025
Organisation or person investigated
Global Counsel Limited (“GCL”)
Matter(s) investigated
Whether GCL submitted an inaccurate Quarterly Information Return (“QIR”) to the Registrar.
Registrar’s decision
GCL did not submit inaccurate QIRs in relation to the matter under investigation.
Summary of rationale for decision
Based on substantive and unequivocal written information provided, GCL has not submitted inaccurate QIRs in relation to the matter under investigation.
Under the Transparency of Lobbying Non-Party Campaigning and Trade Union Administration Act (“The Act”), registrants must submit a QIR to the Registrar every quarter giving client information in relation to consultant lobbying, or a nil return.
In January, March and June 2023, Global Counsel met with a minister and this was not declared in GCL’s QIRs. Based on assurances from GCL, the Qatari Freezone Authority (“QFZA”) was a client of Global Counsel MENA, not of GCL. Global Counsel MENA is a subsidiary of GCL and a separate legal entity. It cannot register as a consultant lobbyist as it is not UK VAT registered. Based on assurances provided, GCL did not receive any payments from QFZA, directly or indirectly, for the periods investigated. Under 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
21 February 2025
Office of the Registrar of Consultant Lobbyists
Summary of investigation – Collider Health Limited and Business for Health CIC
January – February 2025
Organisation or person investigated
Collider Health Limited (“Collider Health”) and Business for Health CIC (“B4H”)
Matter(s) investigated
Whether Collider Health and/or B4Hh conducted unregistered consultant lobbying
Registrar’s decision
Based on information and assurances provided, Collider Health and B4H have 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, Collider Health and B4H have not conducted unregistered consultant lobbying.
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.
Collider Health: provided assurances that B4H was not a paying client at this time.
Business for Health: Assurances were given that all funding received by B4H is subject to a clause which gives independent control of the content of funded projects to the Board of B4H, not the funder(s). The Registrar’s guidance explains an exemption for Think Tanks on the grounds that the communications are not in return for payment and this currently applies to B4H. The guidance includes:
‘If funding is provided for a project, but the funder cannot exercise control over the outcome of the project, the activity is unlikely to be registrable. This is because any resulting communication would be expressing the think tank’s views, rather than being on behalf of a client. An independence clause in a funding agreement or contract is indicative of an absence of control by a funder.’
Chronology
11 February 2025
Office of the Registrar of Consultant Lobbyists
Record of Registrar’s external communications in 2025
This is a record of external communications made by the Registrar, Harry Rich, during 2025. We do not publish information about correspondence with whistleblowers who wish to protect their anonymity nor privileged legal communications or communications that would prejudice the conduct of a formal enquiry by the Registrar. The data is updated monthly.
Last updated June 2025
Quarter Four(October-December 2024)Returns Data
There is an ongoing issue with report for the October-December 2024 quarter that we are working on
resolving. Whilst we work on resolving this issue an accurate report can be downloaded below.
Memorandum of Understanding
between the Cabinet Office and the Registrar of Consultant Lobbyists
4. Finance and accountability arrangements
5. Governance and responsibilities
8. Review and forward planning
Annex A – Budget approval and financial reporting process
Annex C – Compliance with government-wide corporate governance and instructions
Annex D – Memorandum on joint data controller responsibilities
1. Introduction
This Memorandum outlines the working relationship between the Cabinet Office (as sponsoring department) and the Registrar of Consultant Lobbyists (“the Registrar” or “the Office of the Registrar” or “the Office”). It encompasses the following:
- the role of the Registrar
- finance and accountability arrangements
- the services and resources the Cabinet Office will provide the Office of the Registrar “the Office” in order that it can carry out its statutory functions
- the sponsor relationship between the Cabinet Office, the Registrar and his Office
- the governance arrangements under which the Registrar and their Office will operate.
The Memorandum is effective from 20 January 2025. It will be reviewed every three years; the next review will be by 20 January 2028. Amendments may be made at any time by agreement between the Cabinet Office and the Registrar.
The Memorandum is not intended to have any legal effect and is not justiciable in any Court of Law.
2. Guiding principles
This Memorandum is based upon the guiding principles that:
- the Registrar, in discharging their statutory functions, is independent of the Government
- the Registrar and the Cabinet Office are committed to openness and transparency in their dealings with each other
- changes to this Memorandum will only be made with the mutual consent of the Cabinet Office and the Registrar.
The Sponsor Team and the Registrar agree to be open and frank in all communications, while protecting the Registrar’s independence, fostering a relationship based on no surprises. The Cabinet Office, as represented by the Sponsor Team, shall provide the necessary support to the Registrar without impinging on their independence.
3. Role of the Registrar
The Registrar was established by the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (“the Act”) in order to create and administer the statutory Register of Consultant Lobbyists.
The functions and powers of the Registrar, an independent statutory office holder, are set out in the Act.
The Registrar, in accordance with the provisions of the Act, fulfils the following functions:
- maintaining and publishing the UK Register of Consultant Lobbyists
- developing and publishing guidance on its functions under the Act
- monitoring and enforcing compliance with the Act’s legal requirements
- publishing an annual statement of accounts.
4. Finance and accountability arrangements
- Parliamentary accountability
The Minister of State for the Cabinet Office accounts for the Registrar’s business to Parliament. Where communication with Parliament is necessary, the Registrar and Cabinet Office will be clear about their respective roles and responsibilities. In particular, the Registrar and Cabinet Office will endeavour to make clear the independence of the Registrar.
The Registrar must prepare an annual statement of accounts, according to a schedule agreed between the Registrar, National Audit Office (NAO) and Cabinet Office. The statement of accounts is reviewed by the Cabinet Office Assurance and Risk Committee, and then sent by the Registrar to the Comptroller and Auditor General, who will examine, certify and report on the statement ahead of laying a copy of the statement before Parliament, in accordance with the Act. Further detail on the financial reporting process is included at Annex A.
The Registrar may be called to account for the activities of their Office at relevant parliamentary select committees.
- Financial accountability
The Registrar is designated by the Permanent Secretary of the Cabinet Office (The Principal Accounting Officer (PAO)) as the Office’s Accounting Officer, and (as set out in the letter of designation) is responsible for assuring Parliament and the public of high standards of probity within the following areas:
- governance
- decision-making and risk management arrangements
- promoting and safeguarding regularity, propriety, affordability, sustainability and value for money
- the ethical and behavioural standards, which are observed by staff, especially in their dealings with other departments and agencies.
- Budgeting
Responsibility for the effective management of the Office’s resources – including an allocated budget and financial authority for payments to be made by the Office – is delegated to the Registrar. The Registrar in return provides assurance to the Cabinet Office that they accept the terms and conditions set out in the budget allocation and financial delegation letter from the PAO. This means, in particular, the acceptance of its financial constraints, financial governance processes and includes working closely with Cabinet Office Financial Accountants and Business Partners on forecasting and actual spend. The budget approval process is set out at Annex A.
Once the annual budget has been agreed by the PAO, the Registrar shall have the authority to incur expenditure approved in the budget in accordance with Cabinet Office internal and external spending controls. This authority is subject to any restrictions imposed by this document, by statute or by the terms of the Cabinet Office PAO’s letter sub-delegating the budget allocation and financial authority. Once the budget has been agreed, any alterations to it proposed by the Cabinet Office would be subject to ministerial approval.
The Registrar shall obtain the Cabinet Office’s prior written approval before:
- entering into any undertaking to incur any expenditure that is not provided for in the Registrar’s annual budget as approved by the Cabinet Office
- incurring expenditure that could have significant future cost implications
- considering action that would constitute a role for the Registrar beyond that envisaged by the Act.
- Charges
In accordance with Section 22 of the Act, the Registrar may impose charges for, or in connection with, the making, updating and maintenance of the Register. The charges are determined in accordance with regulations made by the Minister.
The Minister will determine the level of charges and in doing so, the Minister must seek to ensure that the total paid to the Registrar in charges is sufficient to offset the total costs incurred by the Registrar in exercising their functions.
The financial framework for the Office is at Annex B.
5. Governance and responsibilities
- The Office and Corporate Governance
The Registrar will ensure that the Office is run in accordance with best practice in corporate governance. In particular the Registrar will:
- adhere to advice and guidance issued by the Cabinet Office and recommendations made by the Public Accounts Committee, or other parliamentary authority, that have been accepted by Government and are relevant to the Office insofar as these are not in conflict with the Registrar’s functions and obligations under the Act (a full list of the guidance that the Registrar will comply with is at Annex C)
- ensure that risks are dealt with in an appropriate manner and documented in a risk register in accordance with the Treasury guidance, Management of Risk: Principles and Concepts. The guidance sets out that Accounting Officers (the Registrar) should “ensure the design and systematic implementation of policies, procedures and practices for risk identification, assessment, treatment, monitoring and reporting.” This should include, at a minimum, provision to the Sponsor Team of a quarterly update of the Office’s risk register, including the existence of any active, threatened or reasonably anticipated litigation insofar as disclosure is not in conflict with the Registrar’s role as an independent office-holder
- comply with their duties in relation to Freedom of Information and Data Protection legislation and have appropriate policies in this regard
- maintain an up-to-date register of interests that will be publicly available on the Office’s website and ensure early and ongoing communication with the Sponsor Team on any potential conflict of interest issues.
In accordance with their terms of appointment, the Registrar has a responsibility to adhere to the Code of Conduct for Board Members of Public Bodies, as relevant. The Code is based on the Seven Principles of Public Life and includes guidance on responsibilities, the use of public funds, political activity and the management of conflicts of interest.
- Cabinet Office
- The Minister’s role
The Minister of State for the Cabinet Office will account for the Registrar on all matters concerning the Office in Parliament. The Ministers’ statutory powers in respect of the Office are set out in Transparency of Lobbying, Non-party Campaigning and Trade Union Administration Act 2014; they are:
- to appoint the Registrar and determine their remuneration
- to dismiss the Registrar should the Minister be satisfied that the Registrar is unable, unwilling or unfit to perform the functions of the office
- to make arrangements for staff, accommodation or services to be provided to the Registrar
- to make grants or loans to the Registrar, which may be subject to conditions
- to specify the period within which the Registrar must send a copy of the annual statement of accounts to the Comptroller and Auditor General.
Through the exercise of these powers the Minister:
- is responsible for the policy framework within which the Office operates
- approves the Registrar’s business plan
- maintains a power of appointment/approval in relation to the appointment of the Registrar
- Sponsor Team
Within the Cabinet Office, the Sponsor Team based in the Propriety and Ethics Directorate will act as the day-to-day point of contact for the Registrar and the Office and will coordinate work with other teams across the Cabinet Office as appropriate. The responsible Senior Civil Servant for the sponsorship relationship (the Senior Sponsor) is the Director of Propriety and Ethics.
The Senior Sponsor is the main source of advice to Ministers and to the PAO on the discharge of their responsibilities in respect of the Office, advising on:
- the Registrar’s fulfilment of their statutory remit
- an appropriate budget in order that the Registrar can fulfil their statutory remit
- performance of the Office in achieving value for money in the delivery of its statutory remit.
The Sponsor Team will liaise regularly with the Office to perform the following functions:
- reviewing performance and resource against plans, achievement against targets and expenditure against budget allocations on a quarterly basis
- Oversee the process for appointing the Registrar, working with the Cabinet Office’s appointments team
- providing the Registrar with any relevant guidance issued by the Treasury or the Cabinet Office regarding public bodies
- supporting the Registrar to put into effect any recommendations accepted by the Government which affect the Office and that are issued by the Public Accounts Committee, another parliamentary select committee
- helping to resolve any difficulties that arise, seeking to address them in the first instance informally, at the lowest level and with the lightest touch.
- Appointment of the Registrar
The Registrar is a regulated public appointment as listed in the Public Appointments Order in Council. As a regulated appointment, the principles and processes set out in the Governance Code for Public Appointments, must be followed. Regulated appointments come under the remit of The Commissioner for Public Appointments, who provides independent assurance that such appointments are made in accordance with the principles and processes set out in the Code. Like all public appointments, Ministers are ultimately accountable and responsible to Parliament for the decisions taken about appointments.
The appointment of the Registrar is also subject to pre-appointment scrutiny by the Public Administration and Constitutional Affairs Committee (PACAC), as set out in Cabinet Office Guidance: pre-appointment scrutiny by House of Commons select committees, which provides an added level of scrutiny to such appointments and may involve taking evidence from the Minister’s preferred candidate at a public pre-appointment hearing before the select committee.
- Policy Team
The Policy Team is based in the Propriety and Ethics Team in the Cabinet Office. In leading on policy it will inform the Registrar and the Office in a timely manner of:
- any prospective changes to the statutory framework governing the work of the Office
- any wider policy developments that might have an impact on the Registrar and consult the Office on potential impacts on operational delivery
- Provision of staff and shared services and information sharing
Paragraph 8 of Schedule 2 to the Act provides that the Registrar may make arrangements with the Minister or other persons for:
- staff to be seconded to the Registrar
- accommodation or services to be provided to the Registrar.
In providing staff and services to the Office, the Cabinet Office sponsor team should ensure appropriate expertise and continuity consistent with the Office’s Business Plan and not seek to re-prioritise or downgrade staff according to other Cabinet Office priorities. The Cabinet Office will ensure that the Office is appropriately staffed to support the Registrar’s functions as set out in the Act.
The Office staff will work under Cabinet Office pay and performance management systems. For appraisal purposes they will come under the Cabinet Office performance management systems, with input provided by the Registrar who will be supported on a day-to-day basis by the Office.
- Information sharing
As sponsor department, the Cabinet Office has the right of access to the Office’s records in relation to finance and performance. The Office shall provide such information about its operations, performance or other expenditure as the Cabinet Office may reasonably require. In line with the Act, the Registrar maintains independence in their decision making and operation. Therefore, the provision of information is limited to financial and performance matters.
6. Dispute resolution
Any disputes between the Cabinet Office and the Registrar will be resolved in as timely a manner as possible. The Cabinet Office and the Registrar will seek to resolve any disputes through an informal process in the first instance. If this is not possible, a formal process, overseen by the Senior Sponsor, will be used to resolve the issue. Failing this, the Senior Sponsor may ask the relevant policy Director General to oversee the dispute.
7. Shared services provision
The services provided include:
- Finance, IT, Shared Services and Estates
The Office will use Cabinet Office systems and administrative support for carrying out financial transactions. The Office’s financial processes will be supported by the Cabinet Office while maintaining independence. However, for the purposes of business planning and the spending review, the Office is part of Cabinet Office finance processes.
The Cabinet Office will ensure that the Office is supported by the Strategy, Finance and Performance Directorate (SFP) and Commercial Directorate’s finance and procurement specialists. SFP’s role will be to provide the Office with financial management expertise to ensure the Office’s financial transactions are processed and recorded effectively. Transactions must be disaggregated in such a way as to be consistent with NAO requirements for production of independent accounts and banking. Commercial Directorate will provide commercial expertise to ensure that the Office procures goods and services in accordance with Cabinet Office policy and procurement legislation. SFP will provide the following services as needed:
- financial policy and practice guidance
- processing of financial transactions for payment upon approval by the Head of the Office that they are fit for payment
- maintenance of a record of expenditure and income, production of monthly financial statements, budget monitoring and management accounts
- preparation of annual statutory accounts
- banking services
- asset management and asset register
- internal assurance
- accommodation and support services including:
- desk space for each member of staff separate from the Cabinet Office
- access to meeting room facilities when needed.
Should the Registrar and Office require them, the sponsor team and Cabinet Office corporate functions can provide support services including:
- security advice and guidance, including processing of any national security personnel checks
- health and safety advice and guidance
- business continuity planning
- specialist commercial advice and guidance, including on contracts for goods and services
- contract management
- Government Procurement Card
- internal auditing services (where appropriate)
- fraud and irregularities investigations.
- Information, Communication and Technology Service Delivery
The Registrar will be required to make use of secured Cabinet Office IT equipment and services for official business.
The Registrar is the senior person responsible for compliance. The Head of Office is the designated manager as described in the Secretary of State’s Code of Practice issued under section 46 of the Freedom of Information Act 2000 and is responsible for the Information Assurance Officer role. However, it is the Registrar’s responsibility to comply with the Public Records Act 1958.
The Office will adopt Cabinet Office policies and systems, including its digital archive, records review, information retention and records transfer systems and policies. The following services will be provided by the Cabinet Office:
- desktop services and development of IT strategy and policy
- email and other digital communications services
- electronic document and records management
- IT hardware and software support
- telephone services
- internet and intranet
- print room and mail room services.
- Compliance with General Data Protection Regulation (GDPR)
As the Registrar is a separate registered data controller, it will appoint a Data Protection Officer (DPO) in line with the requirements of Article 37 GDPR.
The Office’s DPO is currently funded by the Cabinet Office. When the DPO was appointed, a decision was made that non-departmental public bodies (including for the purposes of financing, the Registrar), would not be required to contribute to funding the work of their DPOs. It was agreed that the relevant sponsoring department (the Cabinet Office) would provide the required funding. This arrangement will be kept under review and potentially adjusted should costs rise significantly.
The Registrar is a joint data controller with the Cabinet Office and will follow Cabinet Office policies. The responsibilities of the joint data controllers are set out in Annex D.
8. Review and forward planning
As well as the necessary frequent interactions between the Registrar, the Office and the Cabinet Office, including the Senior Sponsor, the parties will arrange regular meetings to discuss matters, which may include amongst other things:
- aims and objectives for the year ahead
- potential risks or proposed changes that could affect the achievement of the Registrar’s statutory functions or the smooth running of the Office
- financing
- staffing and resources
- information on the number of consultant lobbyists registered and the fee income received, as part of the transparent reporting arrangements of the Office
- any other issues that the Registrar and Cabinet Office agree need to be addressed.
Signed | Signed  |
| Date: 20 January 2025 Simon Madden Director of Propriety and EthicsOn behalf of the Cabinet Office | Date: 20 January 2025Harry Rich Registrar of Consultant LobbyistsOn behalf of the Office of the Registrar of Consultant Lobbyists |
The sponsor team and the Office will meet on a quarterly basis for formal sponsorship review and the Senior Sponsor will meet with the Registrar on a quarterly basis. The Minister will meet with the Registrar on at least an annual basis to discuss matters relating to the Office’s objectives, performance and priorities
Annex A – Budget approval and financial reporting process
- The Accounting Officer of the Cabinet Office will appoint the Registrar as an Additional Accounting Officer (“the Accounting Officer”). This will sub-delegate authority for management of the budget for the Office to the Registrar.
- The Registrar’s budget is designated as falling within the Cabinet Office departmental boundary and as a consequence, its budget and accounts are consolidated within the Cabinet Office Estimate and Annual Report and Accounts.
Budget
- The Accounting Officer will develop the proposed budget and business plan for the Office. The business plan sets out how the Registrar will fulfil their statutory functions for the following financial year. The Accounting Officer will work with Cabinet Office Finance to establish an appropriate date for submission of the budget – together with any risks to the budget that have been identified – for ministerial approval. Typically, the budget will be submitted in the final quarter of the financial year.
- The budget will be developed and managed in accordance with Cabinet Office procedures, and principles set out in Managing Public Money Guidance, Consolidated Budgeting Guidance and Main Supply Estimates Guidance.
- Subject to the timing established by Cabinet Office Finance, the Minister will approve the budget in advance of the financial year if they are satisfied that the budget is based on a reasonable forecast of the Office’s direct and indirect costs for the forthcoming financial year, has been developed to ensure value for money and is necessary to allow the Registrar to fulfil their statutory functions as outlined in the business plan. The department’s PAO will write to the Accounting Officer to delegate the budget to them for the financial year ahead.
- The Accounting Officer will, in turn, delegate the budget to the Head of Office, who will be responsible for the management of the budget and the maintenance of accounting records. The Accounting Officer will be accountable for the satisfactory completion of accounting records in accordance with Paragraph 9 of Schedule 2 to the Act.
Forecasting
- The Head of the Office will provide regular updates to the Sponsor Team about actual expenditure against expenditure forecast in the budget, which will include the identification of any risks to the budget or the need to incur expenditure that is not in the approved budget.
- If there is, or is likely to be, a need for the Registrar to incur expenditure that is not in the approved budget, the Accounting Officer will inform the Minister. If the Minister is satisfied that this expenditure is necessary and could not have been reasonably foreseen, they may make a grant in aid under Paragraph 10 of Schedule 2 to the Act.
- The Accounting Officer will inform the Minister, within a timetable agreed by Cabinet Office Finance, an agreed timetable during the relevant financial year if seeking an amendment to the budget during that year at Supplementary Estimate.
Accounts
- In accordance with Schedule 2 to the Act, the Registrar will prepare a statement of accounts in respect of each financial year and send this within a period of time to be specified by the Cabinet Office’s Audit and Risk Committee to the Comptroller and Auditor General.
- The Registrar must ensure that Accounts are provided to the Cabinet Office Finance Team in accordance with deadlines, which have been agreed by the National Audit Office.
- As set out in Schedule 2 of the Act, the Comptroller and Auditor General, will examine, certify and report on the statement, and then arrange for a copy of the certified statement and the report to be laid before Parliament as soon as possible.
Annex B – Financial framework
The following is the financial framework within which the Office will operate:
Amendment and review
The financial framework may be changed in accordance with Government Accounting and Treasury requirements, to take account new developments. If either the Cabinet Office (CO) or the Registrar require changes to be made they shall notify the other in writing.
Compliance with guidance
The Registrar shall comply with Managing Public Money and all relevant instructions and guidance published by His Majesty’s Government (including, for example, Cabinet Office and His Majesty’s Treasury’s guidance), as amended and updated from time to time.
Budgeting and charging
The level of funding required by the Office will be agreed between the Cabinet Office and the Registrar. The Registrar will advise the Cabinet Office of the funding required for both its work and staff. Both parties recognise that the Office must be funded to the amount necessary for it to fulfil its statutory requirements effectively and at the same time secure value for money.
The income the Registrar receives from the charge for registration is owed to the Treasury but there is a netting off arrangement to offset expenditure used for the running costs of the Register. Civil Penalties raised by the Registrar must be surrendered to the Consolidated Fund.
Grant-in-aid
The Office is funded via a grant-in-aid from the Cabinet Office. However, as set out in the Act, the Office will seek to recoup its costs (to date, excluding its staffing and Cabinet Office shared services costs) via the fees charged to registrants.
The Cabinet Office will issue the grant-in-aid in arrears at the end of each financial year (by 31 March). This will include the registration fees paid into the consolidated fund.
The Registrar must obtain the approval of the Cabinet Office, as sponsor Department, if it proposes to:
- make special payments or gifts
- write off losses.
At the end of the financial year the Office will return any issued but unexpended balance of Public Funds to the Cabinet Office. In the event that it becomes apparent during the year that funds are no longer required, the Registrar will surrender that underspend to at the earliest feasible date.
Expenditure
Expenditure of the resources agreed in the budget will be a matter for the Office, subject to the normal requirements of propriety, regularity, audit, value for money and any conditions imposed by the Cabinet Office after consultation with the Office.
The Office is responsible for:
- providing returns to the Cabinet Office as required on actual and forecast resources and cash expenditure during the course of the year
- ensuring that expenditure remains within the resources provided by the Minister of State each year
- notifying the Cabinet Office if any additional funding is required.
The Cabinet Office is responsible for:
- maintaining appropriate and regular communication and advice to the Office at appropriate levels on expenditure matters
- ensuring that any requests for additional funding are put before the Minister of State for consideration and approval in a timely way.
Accounting and reporting
The Registrar is designated by the PAO of the Cabinet Office as the Office’s Accounting Officer, and is responsible (as set out in the letter of designation) for:
- regularity and propriety, keeping of proper accounts, prudent and economical administration, avoidance of waste and extravagance and efficient and effective use of resources
- ensuring that the Office’s systems and processes are subject to proportionate internal controls
- producing annual accounts which conform to the standards set out in the Government Financial Reporting Manual and sending a copy of the statement of accounts, within a period specified by the Minister to the Comptroller and Auditor General, who will then examine, certify and report on the Statement ahead of laying a copy of the Statement before Parliament, in accordance with the Act
- overseeing and maintaining systems to safeguard financial propriety and regularity.
The Registrar may delegate the day-to-day administration of their financial responsibilities, including the Accounting Officer responsibilities to another person as appropriate. However, they shall not assign absolutely to any other person any of the responsibilities set out in this Memorandum or the letter of designation.
The Registrar, as Accounting Officer, is responsible for ensuring that resources authorised by Parliament and sums to be paid out of the Consolidated Fund, in respect of the Office, are used for the purposes intended by Parliament.
The Office will be responsible for keeping proper accounts and proper records in relation to the accounts, including details of the income derived from fees charged to registrants. The Registrar must send a copy of the statement of accounts, within a period specified by the Cabinet Office Audit and Risk Committee, to the Comptroller and Auditor General (C&AG). The C&AG will then examine, certify and report on the statement ahead of laying a copy of the statement before Parliament, in accordance with the Act.
Gifts and hospitality register
The Office shall maintain a record of gifts and hospitality if received. Generally, hospitality is defined as the provision of lunches, dinners and tickets to sporting/social or leisure events.
Giving of gifts
The Office must not purchase any gifts without the prior approval of Cabinet Office Finance. Such approval will only be given in exceptional circumstances.
Statement of Financial Responsibility
The Cabinet Office will provide the Head of the Office with a clear financial authority to incur expenditure on behalf of the Office.
Insurance
Except where there are statutory requirements, the insurance arrangements as set out in Managing Public Money will be followed.
Banking
The Registrar, as its Accounting Officer, is responsible for ensuring that the Office’s banking arrangements are in accordance with the requirements of Managing Public Money and are carried out efficiently, economically and effectively.
Procurement
Procurement by the Office of works, equipment, goods and services shall be based on value for money, for both quality (in terms of fitness for purpose) and delivery against price. Where appropriate, a full option appraisal shall be carried out before procurement decisions are taken.
Advertising and marketing
The Office will abide by the conventions of government publicity and advertising, set out in the Government Communication Service Propriety Guidance, and will ensure in particular that any publicity they issue is:
- relevant to their responsibilities
- objective and explanatory, not tendentious or polemical
- not party political and not liable to misrepresentation as being party political
- produced and distributed in an economic and relevant way, having regard to the need to justify the costs as proper expenditure of public funds.
The Registrar will not employ external consultants to lobby Parliament or Government.
The Registrar will seek further advice from the Cabinet Office where the use of publicity and advertising might be regarded as novel or contentious, and in all cases before employing PR consultants.
Assets
The Office shall maintain an accurate and up-to-date register of its fixed assets. Any interest earned by the Office on its assets will be treated in accordance with the consolidated budgeting guidance issued by Treasury.
The Office shall not enter into any capital expenditure in excess of £5,000 (or the amount recommended in Managing Public Money) without the permission of the Cabinet Office. The Office will liaise with Cabinet Office Commercial if getting three quotes for any spend under £10,000, in line with commercial procedures. The Office shall not dispose of any assets acquired with Public Funds with a net book value in excess of £1,000 (or the amount recommended in Managing Public Money) without the prior written consent of the Cabinet Office. Use of proceeds of any disposal in excess of this amount shall be at the discretion of the Cabinet Office.
Risk management
The Office shall identify, and be responsible for ensuring that, the risks that it faces are dealt with in an appropriate manner, in accordance with relevant aspects of best practice in corporate governance, and shall maintain a risk register, in accordance with Treasury guidance.
The Office shall adopt and implement policies and practices to safeguard the Office against fraud and theft, in line with Treasury guidance.
Borrowing
The Office shall not borrow money. For the avoidance of doubt, borrowing includes temporary borrowing, such as through pre-arranged overdraft facilities.
Lending, guarantees, indemnities and contingent liabilities (including letters of comfort)
The Office shall not, without prior written consent from the Cabinet Office, lend money, charge any asset or security, give any guarantee or indemnity or letter of comfort, nor incur any other contingent liability whether or not in a legally binding form.
Payroll and related matters
The arrangements concerning payroll and associated services such as taxation, National Insurance and pensions of the Office will be administered by the Cabinet Office following the department’s terms and conditions.
Annex C – Compliance with government-wide corporate governance and instructions
The Office shall comply with the following general guidance and instructions, insofar as these are not in conflict with the Registrar’s functions and obligations under the Act:
- This Memorandum of Understanding
- Appropriate adaptations of sections of Corporate Governance in Central Government Departments Code of Good Practice
- Parliamentary and Health Service Ombudsman’s Principles of Good Administration
HM Treasury, Chartered Institute Public Finance and Accountancy guidance:
- Managing Public Money (MPM), including Chapter 6, Fees, Charges and Levies
- Orange book: Management of Risks – Principles and Concepts
- Government Financial Reporting Manual (FReM)
- Departmental Banking: A Manual for Government Departments
- Regularity, Propriety and Value for Money
- Managing the Risk of Fraud and Corruption
- Public Sector Internal Audit Standards
- Relevant guidance and instructions issued by the Treasury in respect of Whole of Government Accounts
- Relevant “Dear Accounting Officer” letters
- Consolidation Officer Memorandum and relevant DCO letters
- Relevant Freedom of Information Act guidance and instructions
- Other relevant instructions and guidance issued by the central departments
- Specific instructions and guidance issued by the sponsor department
- Recommendations made by the Public Accounts Committee, or other parliamentary authorities that have been accepted by the Government and are relevant to the Office.
Annex D – Memorandum on joint data controller responsibilities
The Office collects, holds and uses personal data in discharging its responsibilities. This data can relate to members of the public (for example, lobbyists, correspondents), and to staff members. As the Office uses Cabinet Office IT systems, all of its personal data is held by the Cabinet Office, a separate data controller. The Office also relies on Cabinet Office for HR and finance services, which requires sending personal data to the Cabinet Office.
It is the view of the Cabinet Office and the Office that they are acting as joint data controllers in relation to all personal data processed by the Office.
Both the Cabinet Office and the Office will:
- comply with the data protection principles, and with all relevant data protection legislation
- properly involve their Data Protection Officer in a timely manner in issues that relate to data protection
- ensure an appropriate level of technical and organisational security for the personal data
- publish this memorandum.
The Cabinet Office will be the responsible lead data controller for processing of staff personal data pursuant to carrying out HR or finance functions on behalf of the Office, and in relation to the administration of IT services provided to the Office. These responsibilities include:
- the provision of Privacy Notices to staff about how their personal data are being handled
- the maintenance of processing records under Article 30 GDPR
- reporting data breaches that relate to the processing of HR or finance staff data, or which relate to the IT infrastructure provided
- carrying out any Data Protection Impact Assessments required by law
- responding to data subject requests relating to staff HR/finance data, or the administration of IT services
- manage any contracts of data processors as part of the Cabinet Office IT provision to the Office.
In relation to any personal data which is processed by the Office in carrying out its functions, the Office will be responsible for:
- the provision of Privacy Notices to data subjects setting out how the Office uses their personal data
- the maintenance of processing records under Article 30 GDPR relating to how the Office uses personal data to carry out its functions
- reporting data breaches which occur as a result of the actions of the staff of the Office, including their usage of the IT systems provided to the Office
- carrying out any Data Protection Impact Assessments required by law for activities of the Office
- responding to data subject requests that relate to the carrying out of the tasks of the Office. The Cabinet Office will provide reasonable required assistance to the Office in responding to data subject requests managing any data processor contracts in relation to additional IT services procured by the Office.
Quarter Three (July-September 2024)Returns Data
There is an ongoing issue with report for the July-September 2024 quarter that we are working on resolving. Whilst we work on resolving this issue an accurate report can be downloaded below.
Quarter Two (April-June 2024)Returns Data
There is an ongoing issue with report for the April-June 2024 quarter that we are working on resolving. Whilst we work on resolving this issue an accurate report can be downloaded below.
Summary of investigation – Arden Strategies Limited
July to August 2024
Organisation or person investigated
Arden Strategies Limited (“Arden”)
Matter(s) investigated
Whether Arden conducted unregistered consultant lobbying prior to registration
Registrar’s decision
Based on information and assurances received Arden did not conduct unregistered consultant lobbying, prior to their registration, in relation to the matters under investigation.
Summary of rationale for decision
Based on substantive and unequivocal written information provided, Arden has not conducted unregistered consultant lobbying.
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.
Arden provided open, comprehensive and detailed information on the events conducted prior to registration, which demonstrated that they were open to the public and Arden did not use them to represent their clients. The communications with Ministers were therefore not on behalf of a paying client.
Chronology
15 August 2024
Office of the Registrar of Consultant Lobbyists
Statement of Accounts – 2023/2024
Our report is also available to download as a PDF
Table of Contents
Performance Report
Introduction
The role of Registrar of Consultant Lobbyists was established by the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (‘the Act’), under which those who lobby on behalf of a paying third party are required to register, declare the names of their clients and state whether they subscribe to a relevant code of conduct.
I am a statutory office holder, independent of Government and the public affairs sector and I account to Parliament for implementation of the provisions of 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 requirements; and
- publish an annual statement of accounts.
My compliance duties include a power to conduct formal investigations, to require the supply of information and, in the event of non-compliance, to undertake enforcement action.
Transparent, ethical lobbying can contribute to effective public policy making; but this requires politicians and officials actively to 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.
This is the Registrar’s tenth annual Statement of Accounts, covering the period from 1 April 2023 to 31 March 2024.
Objectives and performance in 2023-24
This review of the year to 31 March 2024 is set against the objectives that I published for the Office of the Registrar in the 2023-24 business plan.
At 31 March 2024 the Register had 213 registrants, compared to 209 at the end of March 2023. The significant increase in registrants in recent years started to level off at the end of 2022. This followed more than a year of active awareness raising and may indicate that awareness is now high and stable. Awareness activities continue and we are now seeing moderate increases in registration. There is naturally some churn in new registrants and leavers.
I updated my formal guidance in July 2023. The key changes were to reiterate that ‘communications’ means communications by any method; to increase clarity about foreign clients; to explain the impact of backdated VAT registration; and to be clear that a code of conduct must be addressed to external parties, rather than the registrant’s employees. I updated my compliance guidance in March 2024 for clarity.
My aim and that of my Office is to ensure that those who should register are aware of and comply with their obligations. Awareness raising activity this year included writing to those who had communicated with Advisory Committee on Business Appointments (ACOBA) regarding roles that carry the potential of lobbying in the future; continuing to write to potential consultant lobbyists across a range of sectors and providing information to MPs standing down at the general election.
I first engaged with the Cabinet Office’s Post Legislative Scrutiny of the Act in January 2021. In July 2023 the government published Strengthening Ethics and Integrity in Central Government, its response to a number of reviews that touched on the operation of the Act and transparency in lobbying. In my subsequent evidence to the Parliamentary and Constitutional Affairs Committee (PACAC) published on 12 September 2023, I welcomed the proposed changes, but expressed my concern that the response missed significant opportunities to enable effective transparency in consultant lobbying:
- Make communications with special advisers registrable.
- Require registrants to declare who was lobbied, on what subject, when and by what medium.
- Address the unintended consequences of exemption from the requirements of the Act for those not registered for VAT.
- Clarify the poorly drafted exemption for ‘incidental lobbying’.
During the year I worked with the OECD’s Working Party of Senior Public Integrity Officials and with the European Lobbying Registrars’ Network, participating in two conferences to exchange information about international good practice in lobbying transparency. At the OECD, I joined an introductory forum of lobbying commissioners and registrars and met with counterparts from Canada and the Netherlands. I attended seminars on lobbying organised by the Committee for Standards in Public Life and by University College London.
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 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. Webinar induction sessions offered to registrants. Registrants with more than two consecutive quarterly nil returns contacted to check accuracy. Checks conducted on consistent naming of clients and 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 a survey is open for everyone on the website for suggested system and website improvements. Ongoing monitoring of system and improvements 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: Updated guidance in July 2023 to aid clarity. In particular, to reiterate that ‘communications’ mean communications through any means or method. Updated guidance on compliance in March 2024 to aid clarity.
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.
Update: Not done. Awaiting any post-legislative scrutiny outcomes following the initial response from government in July 2023.
Objective 2: Activity 3
Provide guidance to other stakeholders as necessary.
Update: Included information on our website for parliamentarians and former parliamentarians and wrote to all MPs who have announced they are standing down at the next general election.
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 PRCA regarding the Public Affairs Code.
Objective 3: Activity 2
Deliver regular induction and update seminars for new and existing registrants to support compliance with statutory duties.
Update: Delivered three well-attended webinars.
Objective 3: Activity 3
Implement cycles of stakeholder engagement to support wider awareness and compliance by registrants and those who may engage in consultant lobbying in the future.
Update: Continued activities to increase awareness of statutory duties. Wrote to companies who may engage in consultant lobbying in the future and have not been written to previously. Started writing awareness letters to those corresponding with the ACOBA, if roles could lead to consultant lobbying.
Objective 3: Activity 4
Disseminate information about the Register to relevant audiences.
Update: Information and updates are 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 published by Ministers.
Update: Published links on the website for the government’s ‘Strengthening ethics and integrity in central government’ in July; and Registrar’s further evidence to the Public Administration and Parliamentary Affairs Committee in September 2023.
Objective 3: Activity 6
Work with other bodies such as the European Lobbying Registrars’ Network, ACOBA and the Organisation for Economic Cooperation and Development (OECD).
Update: I worked with the OECD’s Working Party of Senior Public Integrity Officials attending two conferences and a working party.
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: 19 notices of intention to issue a civil penalty issued during the year (2022-23: 18), the bulk of which resulted in a penalty being issued. Three information notices issued (2022-23: four).
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 requests to Private Offices for further information including a Freedom of Information request.
Objective 4: Activity 3
Undertake formal investigations where there is reasonable information suggesting non-compliance.
Update: Registrar initiated or continued 18 formal investigations (2022-23: 17) and published summaries of findings of 15 concluded investigations (2022-23: 15). Engaged with His Majesty’s Revenue and Customs regarding principles for provision of VAT data, under the Act; and with the Parliamentary and Health Service Commissioner regarding their oversight and added information to our website.
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 compliant 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 Alex Burghart MP, Parliamentary Secretary for the Cabinet Office.
Objective 5: Activity 5
Report to Parliament as required.
Update: The Registrar’s annual report and accounts for year to 31 March 2023 was laid before Parliament 19 July 2023 and a copy sent to Public Administration and Constitutional Affairs Committee (PACAC). The Registrar gave evidence to PACAC’s inquiry Lobbying and Influence: post-legislative scrutiny of the Lobbying Act 2014 and related matters.
Objective 5: Activity 6
Comply with the Memorandum of Understanding with the Cabinet Office.
Update: Memorandum provisions adhered to.
Objective 5: Activity 7
Monitor 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: We work with suppliers for development and security of the Register and website.
Financial position
I am committed to fulfilling my statutory duties effectively and delivering value for money. The cost of running the Office of the Registrar in 2023-24 was £324,147 compared to £325,677 in 2022-23 (see Note 2 Expenditure). Overall, expenditure in 2023-24 represented an underspend of £56,853 (2022-23: £32,323) against the agreed budget for the year.
Under the terms of the Act, ministers set the annual fees to registrants and seek to ensure that the total paid in fees is sufficient to offset the total costs. The Registrar collects and accounts for all fees and pays them into the Consolidated Fund. Income in 2023-24 was £216,656 (2022-23: £206,196) which is an increase of £10,460 over the previous year (see Note 3. Income). Staffing and shared services costs are paid from Cabinet Office budgets.
Plans for 2024 to 2025
During the year ahead, I will continue to build on the stakeholder engagement programme and seek to increase and widen awareness and knowledge of statutory duties, particularly in the context of the general election. I will review whether my guidance would benefit from further changes and monitor the Register, for ease of data entry and access for registrants, staff and the public.
I will continue to work with Cabinet Office to prepare for any changes resulting from their post legislative scrutiny of the Act and to review our Memorandum of Understanding. If changes are implemented, I will seek to widen my work with stakeholders.
Alongside support for registrants and potential registrants, I will enforce the requirements of the Act with clarity, using statutory penalties where necessary and investigate where there is reasonable information suggesting non-compliance.
The Business Plan for 2024-25 is available at: www.registrarofconsultantlobbyists.org.uk
Harry Rich
Registrar of Consultant Lobbyists and Accounting Officer
Office of the Registrar of Consultant Lobbyists
1 Horse Guards Road (Room 3.26)
London, SW1A 2HQ
18 July 2024
Accountability report
Governance report
Statement of Accounting Officer’s Responsibilities
Under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014, the Registrar of Consultant Lobbyists prepares for each financial year, a Statement of Accounts in the form and on the basis set out in the Accounts Direction.
The accounts are prepared on an accruals basis and must give a true and fair view of the state of affairs of the Registrar of Consultant Lobbyists and of its income and expenditure, Statement of Financial Position and cash flows for the financial year.
In preparing the accounts, the Accounting Officer is required to comply with the requirements of the Government Financial Reporting Manual and in particular to:
- observe the Accounts Direction issued by the Cabinet Office, including the relevant accounting and disclosure requirements, and apply suitable accounting policies on a consistent basis;
- make judgements and estimates on a reasonable basis;
- state whether applicable accounting standards as set out in the Government Financial Reporting Manual have been followed, and disclose and explain any material departures in the accounts;
- prepare the accounts on a going concern basis; and
- confirm that the Statement of Accounts as a whole is fair, balanced and understandable and take personal responsibility for the Statement of Accounts and the judgements required for determining that it is fair, balanced and understandable.
The Cabinet Office has appointed the Registrar of Consultant Lobbyists as the Accounting Officer.
The responsibilities of an Accounting Officer, including responsibility for the propriety and regularity of the public finances for which the Accounting Officer is answerable, for keeping proper records and for safeguarding the Registrar of Consultant Lobbyist’s assets, are set out in Managing Public Money published by HM Treasury.
As the Accounting Officer, I have taken all the steps that I ought to have taken to make myself aware of any relevant audit information and to establish that Registrar of Consultant Lobbyist’s auditors are aware of that information. So far as I am aware, there is no relevant audit information of which the auditors are unaware. As Accounting Officer, I take personal responsibility for the Statement of Accounts and the judgements required for determining that it is fair, balanced and understandable.
Governance statement
Introduction
As Accounting Officer, I have responsibility for maintaining a sound system of internal control that supports the achievement of the Office of the Registrar’s policies, aims and objectives, whilst safeguarding public funds and the assets for which I am personally responsible, in accordance with the responsibilities assigned to me in Managing Public Money.
The Office of the Registrar of Consultant Lobbyists exists to implement the provisions in the Act, as a corporation sole. I am independent of consultant lobbyists and Government and report directly to Parliament. The Office of the Registrar has been designated for consolidation into the Cabinet Office Estimate and Accounts. The regime of corporate governance needs to be proportionate to the size and risk profile of the organisation. There is no provision in the Act for a Board of Directors or a separate Audit Committee, although the Cabinet Office Audit and Risk Committee consider my draft accounts and the NAO audit, together with any internal audit activity relevant to my activities.
I discuss and agree the audit schedule with the National Audit Office. To ensure a robust financial control regime, my Office manages my financial arrangements in accordance with the Cabinet Office’s best practice, systems and resources, and I conduct regular reviews and oversight. The work of my Office is conducted strictly in accordance with the requirements of the Act. These systems have been in place for the year under review and up to the date of approval of the annual report and accounts. No internal audits took place within 2023/24 as the Office of the Registrar of Consultant Lobbyists currently does not fall in scope under the Cabinet Office’s Government Internal Audit Agency audit plan. However, as the Office uses the Cabinet Office’s finance and payroll system and shared service centre, internal audits of the Cabinet Office’s processes and governance will sometimes review services that are used by the Office.
Risk Management
I have established a proportionate regime for the management of risk, where the risk environment and the specific risks associated with the delivery of my statutory objectives are reviewed on a quarterly basis and any new mitigating actions required are carefully implemented.
There is no evidence of risk that the Register is not complete or that all appropriate revenues are not being collected. The risk environment remains neutral to benign and no new significant risks were identified.
Information Security
During the past year, there have been no reportable breaches of information security. The Office of the Registrar has complied with the requirements of the General Data Protection Regulation, sharing some data controller responsibilities, as appropriate, with the Cabinet Office (as providers of relevant corporate services to the Office of the Registrar, including IT, and HR). In March 2024, we were alerted to an issue, making the Register vulnerable to cyber attack. There was no breach and we worked with developers to resolve the vulnerability.
Review of Effectiveness
I follow the Cabinet Office’s guidelines and procedures for internal control. During the past year, there have been no instances of fraud or irregularity.
Conflicts of Interests
To provide assurance against conflicts of interest and business appointments:
- The Registrar and all staff are required to declare any related-party transactions annually.
- The Civil Service Management Code is applied, including section 4.3 relating to Standards of Propriety and Business Appointment Rules for Civil Servants.
- The Registrar’s interests are published on the Office of the Registrar’s website and any outside employment held by the Registrar is declared to Cabinet Office and published on the website.
Remuneration and Staff Report
This report sets out details on remuneration and staff that Parliament consider key to accountability. This section is subject to audit.
1. Staff numbers and related costs
1.1 Staff costs comprise
| Description | Registrar (£) | Others (£) | 2023-24 (Total £) | 2022-23 (Total £) |
|---|---|---|---|---|
| Registrar’s fees | 21,361 | – | 21,361 | 20,585 |
| Registrar’s expenses | 2,789 | – | 2,789 | 1,801 |
| Inward secondments | – | 181,471 | 181,471 | 167,649 |
| Total | 24,150 | 181,471 | 205,621 | 190,035 |
1.2 Average number of persons employed
The Registrar is a part-time appointment with an expected commitment of 30-40 days per year and paid at a daily rate of £480. This rate is determined by the sponsor Minister in the Cabinet Office. During the 2023-24 financial year, the Registrar worked and was paid for 43 days (2022-23: 42 days). The appointment is taxable under Schedule E and subject to Class I National Insurance contributions and does not attract a pension.
‘Others’ relates to inward secondees from the Cabinet Office: these equate to the equivalent of three full-time members of staff (2022-23: 3).
| Description | 2023-24 | 2022-23 |
|---|---|---|
| Registrar | 0.17 | 0.16 |
| Others | 3 | 3 |
| Total | 3.17 | 3.16 |
Parliamentary Accountability and Audit Report
This section presents key information which contributes to the organisation’s accountability to Parliament.
The Regularity of expenditure section reports on losses and special payments made during the year. Regularity refers to the principle that all consumption of resources should be made in accordance with the legislation authorising them, and applicable delegated authority and the principles set out in Managing Public Money. Disclosures on fees and charges, are required by Managing Public Money.
In his certificate and report to the Houses of Parliament, the Comptroller and Auditor General provides his opinion on regularity, whether the Remuneration and Staff Report and Parliamentary Accountability disclosures have been properly prepared and whether the information given in the Performance Report and Accountability Report is consistent with the financial statements.
Parliamentary Accountability Disclosures
This section is subject to audit
1.0 Analysis of cash surrenderable to the Consolidated Fund
| Description | Note to accounts | 2023-24 Outturn Accruals (£) | 2023-24 Outturn Cash Basis (£) | 2022-23 Outturn Accruals (£) | 2022-23 Outturn Cash Basis (£) |
|---|---|---|---|---|---|
| Registration fees from consultant lobbyists | 7 | 221,754 | 221,754 | 219,169 | 219,169 |
| Civil penalties from consultant lobbyists | 7 | 2,632 | 2,632 | 4,523 | 4,523 |
| Civil penalties from consultant lobbyists – receivable | 7 | 810 | – | – | – |
| Total amount payable to the Consolidated Fund | 225,196 | 224,386 | 223,692 | 223,692 |
1.1 Income payable to the Consolidated Fund
Registration fees from consultant lobbyists
In accordance with part 1 section 22(5) of the Act, the Registrar must pay into the Consolidated Fund any sums received in respect of charges. The cash received by the Registrar from registration fees is paid to HM Treasury’s Consolidated Fund.
Although cash is surrenderable to HM Treasury’s Consolidated Fund, the Chief Secretary to the Treasury has agreed to a netting off arrangement whereby the Registrar may offset the income against expenditure for budget and outturn purposes. This does not apply to civil penalties charged on consultant lobbyists. Cash receipts in 2023-24 amounted to £221,754 (2022-23: £219,169).
1.2 Consolidated Fund Income
Civil penalties applied to consultant lobbyists
The Registrar of Consultant Lobbyists acts as a collecting agent of the Consolidated Fund in respect of civil penalties applied to consultant lobbyists. The netting off arrangement described above does not apply to civil penalties charged.
The civil penalties collected amounted to £2,632 (2022-23: £4,523) and £810 invoiced as receivable (2022-23: £0). Details of all civil penalties are published on the Office of the Registrar of Consultant Lobbyists website.
2. Regularity of expenditure
There are no losses nor special payments to disclose.
3. Fees and charges
| Description | Note to accounts | Full cost recovery | Cost borne by Cabinet Office (£) | 2023-24 Total (£) | 2022-23 Total (£) |
|---|---|---|---|---|---|
| Registrar’s fees and expenses | 24,150 | – | 24,150 | 22,386 | |
| Inward secondments | – | 181,471 | 181,471 | 167,649 | |
| Costs of providing the Register | 53,032 | – | 53,032 | 52,927 | |
| Compliance and enforcement | 25,388 | – | 25,388 | 45,656 | |
| Notional corporate services recharge | – | 22,408 | 22,408 | 22,410 | |
| Other expenditure | 16,948 | 750 | 17,698 | 14,649 | |
| Full cost of service | 2 | 119,518 | 204,629 | 324,147 | 325,677 |
| Registration fees from Consultant Lobbyists | 3 | (216,656) | – | (216,656) | (206,196) |
| Net expenditure for the year | (97,138) | 204,629 | 107,491 | 119,481 | |
| Notional corporate services recharge | – | (22,408) | (22,408) | (22,410) | |
| Net outturn | (97,138) | 182,221 | 85,083 | 97,071 |
The information is provided for fees and charges purposes, not for the purposes of IFRS 8 Operating Segments. It represents costs included in the Statement of Comprehensive Net Expenditure. The financial requirement of the Registrar of Consultant Lobbyists is to ensure that registration charges are collected from registrants, in accordance with the Cabinet Office’s regulations.
Cost borne by Cabinet Office
In accordance with schedule 2, section 8 (1) of the Act, the Registrar may make arrangements with the Minister or other persons: for staff to be seconded to the Registrar and for accommodation or services to be provided to the Registrar. The Minister has decided not to recover all of these costs by making a charge on registrants, and consequently, the Cabinet Office bears these costs in addition to any net deficit from direct costs/income; see Note to Accounts 1.3 Going concern.
Harry Rich
Registrar of Consultant Lobbyists and Accounting Officer
Office of the Registrar of Consultant Lobbyists
1 Horse Guards Road (Room 3.26)
London, SW1A 2HQ
18 July 2024
The Certificate and Report of the Comptroller and Auditor General to the Houses of Parliament
Opinion on financial statements
I certify that I have audited the financial statements of the Office of the Registrar of Consultant Lobbyists for the year ended 31 March 2024 under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014.
The financial statements comprise the Office of the Registrar of Consultant Lobbyists’
- Statement of Financial Position as at 31 March 2024;
- Statement of Comprehensive Net Expenditure, Statement of Cash Flows and Statement of Changes in Taxpayers’ Equity for the year then ended; and
- the related notes including the significant accounting policies.
The financial reporting framework that has been applied in the preparation of the financial statements is applicable law and UK adopted International Accounting Standards.
In my opinion, the financial statements:
- give a true and fair view of the state of the Office of the Registrar of Consultant Lobbyists’ affairs as at 31 March 2024 and its net expenditure for the year then ended; and
- have been properly prepared in accordance with the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 and Secretary of State directions issued thereunder.
Opinion on regularity
In my opinion, in all material respects, the income and expenditure recorded in the financial statements have been applied to the purposes intended by Parliament and the financial transactions recorded in the financial statements conform to the authorities which govern them.
Basis for opinions
I conducted my audit in accordance with International Standards on Auditing (UK) (ISAs UK), applicable law and Practice Note 10 Audit of Financial Statements and Regularity of Public Sector Bodies in the United Kingdom (2022). My responsibilities under those standards are further described in the Auditor’s responsibilities for the audit of the financial statements section of my certificate.
Those standards require me and my staff to comply with the Financial Reporting Council’s Revised Ethical Standard 2019. I am independent of the Office of the Registrar of Consultant Lobbyists in accordance with the ethical requirements that are relevant to my audit of the financial statements in the UK. My staff and I have fulfilled our other ethical responsibilities in accordance with these requirements.
I believe that the audit evidence I have obtained is sufficient and appropriate to provide a basis for my opinion.
Conclusions relating to going concern
In auditing the financial statements, I have concluded that the Office of the Registrar of Consultant Lobbyists’ use of the going concern basis of accounting in the preparation of the financial statements is appropriate.
Based on the work I have performed, I have not identified any material uncertainties relating to events or conditions that, individually or collectively, may cast significant doubt on the Office of the Registrar of Consultant Lobbyists’ ability to continue as a going concern for a period of at least twelve months from when the financial statements are authorised for issue.
My responsibilities and the responsibilities of the Accounting Officer with respect to going concern are described in the relevant sections of this certificate.
The going concern basis of accounting for the Office of the Registrar of Consultant Lobbyists is adopted in consideration of the requirements set out in HM Treasury’s Government Financial Reporting Manual, which requires entities to adopt the going concern basis of accounting in the preparation of the financial statements where it is anticipated that the services which they provide will continue into the future.
Other Information
The other information comprises information included in the Performance and Accountability Report, but does not include the financial statements and my auditor’s certificate and report thereon. The Accounting Officer is responsible for the other information.
My opinion on the financial statements does not cover the other information and, except to the extent otherwise explicitly stated in my certificate, I do not express any form of assurance conclusion thereon.
My responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or my knowledge obtained in the audit, or otherwise appears to be materially misstated.
If I identify such material inconsistencies or apparent material misstatements, I am required to determine whether this gives rise to a material misstatement in the financial statements themselves. If, based on the work I have performed, I conclude that there is a material misstatement of this other information, I am required to report that fact.
I have nothing to report in this regard.
Opinion on other matters
In my opinion the part of the Remuneration and Staff Report to be audited has been properly prepared in accordance with Secretary of State directions issued under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014.
In my opinion, based on the work undertaken in the course of the audit:
- the parts of the Accountability Report subject to audit have been properly prepared in accordance with Secretary of State directions made under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014; and
- the information given in the Performance and Accountability Reports for the financial year for which the financial statements are prepared is consistent with the financial statements and is in accordance with the applicable legal requirements.
Matters on which I report by exception
In the light of the knowledge and understanding of the Office of the Registrar of Consultant Lobbyists and its environment obtained in the course of the audit, I have not identified material misstatements in the Performance and Accountability Reports.
I have nothing to report in respect of the following matters which I report to you if, in my opinion:
- adequate accounting records have not been kept by the Office of the Registrar of Consultant Lobbyists or returns adequate for my audit have not been received from branches not visited by my staff; or
- I have not received all of the information and explanations I require for my audit; or
- the financial statements and parts of the Accountability Report subject to audit are not in agreement with the accounting records and returns; or
- certain disclosures of remuneration specified by HM Treasury’s Government Financial Reporting Manual have not been made or parts of the Remuneration and Staff Report to be audited is not in agreement with the accounting records and returns; or
- the Governance Statement does not reflect compliance with HM Treasury’s guidance.
Responsibilities of the Accounting Officer for the financial statements
As explained more fully in the Statement of Accounting Officer’s Responsibilities, the Accounting Officer is responsible for:
- maintaining proper accounting records;
- providing the C&AG with access to all information of which management is aware that is relevant to the preparation of the financial statements such as records, documentation and other matters;
- providing the C&AG with additional information and explanations needed for his audit;
- providing the C&AG with unrestricted access to persons within the Office of the Registrar of Consultant Lobbyists from whom the auditor determines it necessary to obtain audit evidence;
- ensuring such internal controls are in place as deemed necessary to enable the preparation of financial statements to be free from material misstatement, whether due to fraud or error;
- preparing financial statements which give a true and fair view in accordance with Secretary of State directions issued under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014;
- preparing the annual report, which includes the Remuneration and Staff Report, in accordance with Secretary of State directions issued under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014; and
- assessing the Office of the Registrar of Consultant Lobbyists’ ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless the Accounting Officer anticipates that the services provided by the Office of the Registrar of Consultant Lobbyists will not continue to be provided in the future.
Auditor’s responsibilities for the audit of the financial statements
My responsibility is to audit, certify and report on the financial statements in accordance with the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014.
My objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue a certificate that includes my opinion. Reasonable assurance is a high level of assurance but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.
Extent to which the audit was considered capable of detecting non-compliance with laws and regulations including fraud
I design procedures in line with my responsibilities, outlined above, to detect material misstatements in respect of non-compliance with laws and regulations, including fraud. The extent to which my procedures are capable of detecting non-compliance with laws and regulations, including fraud is detailed below.
Identifying and assessing potential risks related to non-compliance with laws and regulations, including fraud
In identifying and assessing risks of material misstatement in respect of non-compliance with laws and regulations, including fraud, I:
- considered the nature of the sector, control environment and operational performance including the design of the Office of the Registrar of Consultant Lobbyists’ accounting policies.
- inquired of management and those charged with governance, including obtaining and reviewing supporting documentation relating to the Office of the Registrar of Consultant Lobbyists’ policies and procedures on: identifying, evaluating and complying with laws and regulations; detecting and responding to the risks of fraud; and the internal controls established to mitigate risks related to fraud or non-compliance with laws and regulations including the Office of the Registrar of Consultant Lobbyists’ controls relating to the Office of the Registrar of Consultant Lobbyists’ compliance with the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 and Managing Public Money;
- inquired of management and those charged with governance whether: they were aware of any instances of non-compliance with laws and regulations; they had knowledge of any actual, suspected, or alleged fraud;
- discussed with the engagement team how and where fraud might occur in the financial statements and any potential indicators of fraud.
As a result of these procedures, I considered the opportunities and incentives that may exist within the Office of the Registrar of Consultant Lobbyists for fraud and identified the greatest potential for fraud in the following areas: revenue recognition, posting of unusual journals, complex transactions and bias in management estimates. In common with all audits under ISAs (UK), I am required to perform specific procedures to respond to the risk of management override.
I obtained an understanding of the Office of the Registrar of Consultant Lobbyists’ framework of authority and other legal and regulatory frameworks in which the Office of the Registrar of Consultant Lobbyists operates. I focused on those laws and regulations that had a direct effect on material amounts and disclosures in the financial statements or that had a fundamental effect on the operations of the Office of the Registrar of Consultant Lobbyists. The key laws and regulations I considered in this context included the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 and Managing Public Money.
Audit response to identified risk
To respond to the identified risks resulting from the above procedures:
- I reviewed the financial statement disclosures and testing to supporting documentation to assess compliance with provisions of relevant laws and regulations described above as having direct effect on the financial statements;
- I enquired of management and the Audit and Risk Committee concerning actual and potential litigation and claims;
- I reviewed minutes of meetings of those charged with governance; and
- in addressing the risk of fraud through management override of controls, I tested the appropriateness of journal entries and other adjustments; assessed whether the judgements on estimates are indicative of a potential bias; and evaluated the business rationale of any significant transactions that are unusual or outside the normal course of business;
I communicated relevant identified laws and regulations and potential risks of fraud to all engagement team members and remained alert to any indications of fraud or non-compliance with laws and regulations throughout the audit.
A further description of my responsibilities for the audit of the financial statements is located on the Financial Reporting Council’s website. This description forms part of my certificate.
Other auditor’s responsibilities
I am required to obtain sufficient appropriate audit evidence to give reasonable assurance that the expenditure and income recorded in the financial statements have been applied to the purposes intended by Parliament and the financial transactions recorded in the financial statements conform to the authorities which govern them.
I communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control I identify during my audit.
Report
I have no observations to make on these financial statements.
Gareth Davies
Comptroller and Auditor General
National Audit Office
157-197 Buckingham Palace Road
Victoria
London
SW1W 9SP
18 July 2024
Financial statements
Statement of account
Statement of Comprehensive Net Expenditure for the year ended 31 March 2024
This account summarises the expenditure and income generated and consumed on an accruals basis.
| Description | Note | 2023-24 (£) | 2022-23 (£) |
|---|---|---|---|
| Total income | 3 | (216,656) | (206,196) |
| Staff costs | 2 | 205,621 | 190,035 |
| Purchase of goods and services | 1, 2 | 96,118 | 113,232 |
| Notional corporate services recharge | 2 | 22,408 | 22,410 |
| Total operating expenditure | 1, 2 | 324,147 | 325,677 |
| Net operating expenditure for the year | 107,491 | 119,481 |
Notes 1 to 9 form part of these accounts
Statement of Financial Position as at 31 March 2024
This statement presents the financial position and comprises three main components: assets owned or controlled; liabilities owed to other bodies; and equity, the remaining value of the entity.
| Description | Note | As at 31 March 2024 (£) | As at 31 March 2023 (£) |
|---|---|---|---|
| Current assets | |||
| Trade and other receivables | 5 | 3,813 | 5,542 |
| Cash and cash equivalents | 6 | 212,936 | 214,610 |
| Total assets | 216,749 | 220,152 | |
| Current liabilities | |||
| Trade and other payables | 7 | (406,435) | (406,923) |
| Total liabilities | (406,435) | (406,923) | |
| Total assets less total liabilities | (189,686) | (186,771) | |
| Taxpayers’ equity | |||
| General fund | (189,686) | (186,771) | |
| Total taxpayers’ equity | (189,686) | (186,771) |
Harry Rich
Registrar of Consultant Lobbyists and Accounting Officer
Office of the Registrar of Consultant Lobbyists
1 Horse Guards Road (Room 3.26)
London, SW1A 2HQ
18 July 2024
Notes 1 to 9 form part of these accounts
Notes to the accounts
1. Statement of accounting policies
1.1 Statement of compliance
This Statement of Accounts has been prepared in accordance with the 2023-24 Government Financial Reporting Manual (FReM) issued by HM Treasury and under an accounts direction issued by the Cabinet Office in accordance with the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014. The accounting policies contained in the FReM apply International Financial Reporting Standards as adapted or interpreted for the public sector context. Where the FReM permits a choice of accounting policy, the accounting policy which is judged to be the most appropriate to the particular circumstances of the Registrar of Consultant Lobbyists for the purpose of giving a true and fair view has been selected. The particular policies adopted by the Registrar of Consultant Lobbyists are described below. They have been applied consistently in dealing with items that are considered material to the Statement of Accounts.
1.2 Basis of preparation
This Statement of Accounts has been prepared under the modified historical cost convention.
1.3 Going concern
The offset registrant fees are recognised as income while the deemed Grant in Aid is recognised as funding. As the registrant fees only cover certain costs, ORCL’s accounts show net operating expenditure and that liabilities exceed assets resulting in negative equity. However, it is appropriate to account for ORCL as a going concern as Parliament has authorised spending for ORCL GIA for 2024-25 in the Central Government Main Supply Estimates 2024-25 (HC-1383).
1.4 Expenditure
The Registrar purchases a license for the Register software. As the Registrar does not bear the risks and rewards of ownership, the Register is not recognised as a fixed asset and instead the relevant costs are expensed.
The Cabinet Office provides certain corporate functions to the Office of the Registrar of Consultant Lobbyists. These include finance, estates and IT.
These functions are recharged to the Registrar as an apportionment of costs, calculated: a) for corporate services, as a cost per full-time equivalent employee within the Cabinet Office multiplied by the number of full-time equivalent employees in the entity; and b) for estates, the cost per full-time equivalent employee for the provision of the Cabinet Office estate, multiplied by the number of full-time equivalent employees in the entity.
1.5 Revenue from contracts with customers
The FReM has made an adaption in applying IFRS 15 for government entities: where, by statute or Treasury consent, an entity is permitted to retain the revenue from taxation, fines and penalties, this revenue shall be treated as arising from a contract and accounted for under IFRS 15 (15a).
Under IFRS 15 (15a) ORCL recognises consideration received as revenue only when it has no remaining obligations to transfer services to the consultant lobbyists and all, or substantially all, of the consideration promised by the consultant lobbyist has been received by ORCL and is non-refundable.
1.6 Revenue – fees from consultant lobbyists
Part 1, section 22 of the Act stipulates:
- The Registrar may impose charges for or in connection with the making, updating and maintenance of entries in the Register.
- The charges are to be determined by or in accordance with regulations.
- In making the regulations, the Minister must seek to ensure that the total paid to the Registrar in charges is sufficient to offset the total of the costs incurred by the Registrar in exercising the functions under this Part (whether or not those costs are directly connected with the keeping of the Register).
- If a charge imposed for making an application or a return to the Registrar is not paid, the Registrar may treat the application or return as not having been made.
- The Registrar must pay into the Consolidated Fund any sums received in respect of charges under this section.
The registration period, with associated obligations on ORCL and registrants, runs from 1 January to 31 December each year with the fee therefore covering two financial years. Monies collected from the fee are recognised appropriately across the two financial years with a portion of the fee retained for the current financial year and the rest deferred to the next financial year.
Refunds are payable to lobbyists who terminate their registration before the end of the registration period.
HM Treasury has agreed that these charges (which are treated as taxes in National Accounts) may be subject to a netting off arrangement whereby they may be netted off against expenditure in budgetary terms and may be recorded as income in the SOCNE.
Cash receipts from fees are surrenderable to HM Treasury’s Consolidated Fund.
1.7 Civil penalties from consultant lobbyists
ORCL also acts as a collecting agent for civil penalties on behalf of HM Treasury’s Consolidated Fund. The netting off arrangement does not apply to these fines charged upon consultant lobbyists. Cash receipts from both fees and civil penalties are surrenderable to HM Treasury’s Consolidated Fund.
1.8 Grant-in-aid
The Registrar of Consultant Lobbyists is a corporation sole and receives financing in the form of grant-in-aid from the Cabinet Office. The level of grant-in-aid is sufficient to cover gross cash expenditure given income is surrenderable to HM Treasury’s Consolidated Fund.
Grant-in-aid is issued on a deemed basis since the Office of the Registrar of Consultant Lobbyists does not hold an expenditure bank account which is attached to the accounting system. Grant-in-aid is recognised at the point of cash receipt and is credited to the General Fund.
1.9 Cash and cash equivalents
Under a memorandum of understanding, payments are made, on behalf of the Office of the Registrar of Consultant Lobbyists (ORCL) by the Cabinet Office, through its central bank account. Receipts are collected by ORCL into their bank account and subsequently these receipts are transferred into the Cabinet Office central bank account.
1.10 Financial assets
Trade and other receivables are recognised at cost which is deemed to be materially the same as the fair value. Trade and other receivables include registration charges due from consultant lobbyists and prepayments and accrued income and cash collected by the Cabinet Office from consultant lobbyists on behalf of the Registrar.
1.11 Impairment of Financial Assets
An allowance for expected credit loss is determined for financial assets and recognised when material in the context of forecast future economic conditions. ORCL has a policy of pursuing outstanding debt from consultant lobbyists and, where recovery is in doubt, a provision is made.
1.12 Financial liabilities
Trade and other payables are recognised at cost which is deemed to be materially the same as the fair value. Trade and other payables include refunds due to consultant lobbyists, accruals, deferred income and amounts payable to the Consolidated Fund.
1.13 Value added tax
The Registrar for Consultant Lobbyists is not VAT registered. Irrecoverable VAT is charged to the relevant expenditure category.
1.14 Impending application of newly issued accounting standards not yet effective
The following standard is expected to be applied in 2025-26; effective 1 April 2025.
IFRS 17 Insurance contracts
IFRS 17 establishes principles for the recognition, measurement, presentation and disclosure of insurance contracts. The objective of IFRS 17 is to ensure that an entity provides relevant information that faithfully represents those contracts. This information gives a basis for users of financial statements to assess the effect that insurance contracts have on the entity’s financial position, financial performance and cash flows.
Impact
The Office of the Registrar of Consultant Lobbyists will assess the impact of this new standard in advance of the effective date. Currently, there are no insurance contracts within these accounts.
2. Expenditure
| Description | 2023-24 (£) | 2022-23 (£) |
|---|---|---|
| Staff costs(1) | ||
| Registrar’s fees | 21,361 | 20,585 |
| Registrar’s expenses | 2,789 | 1,801 |
| Inward secondments | 181,471 | 167,649 |
| Total staff costs | 205,621 | 190,035 |
| Goods and services | ||
| IT costs | 53,032 | 52,927 |
| Supplies and services(2) | 11,543 | 13,033 |
| Auditors’ remuneration and expenses(3) | 14,950 | 11,500 |
| Enforcement legal advice(4) | 15,433 | 34,447 |
| Other staff related costs | 1,160 | 1,325 |
| Total goods and services | 96,118 | 113,232 |
| Non-cash | ||
| Notional corporate services recharge | 22,408 | 22,410 |
| Total | 324,147 | 325,677 |
Note 1: Staff costs are disclosed in the Remuneration and Staff Report within the Accountability Report.
Note 2: Supplies and services have decreased by £1,490 from £13,033 to £11,543 mainly due to a reduced level of costs of litigation in the current year.
Note 3: NAO audit fees increased from £11,500 to £14,950. During the reporting year, no payment was made to the auditors for non-audit work.
Note 4: Enforcement legal advice decreased by £19,014 from £34,447 to £15,433 due to a reduced level of advice required on non-litigation issues and complex investigations.
3. Income
| Description | 2023-24 (£) | 2022-23 (£) |
|---|---|---|
| Fees from consultant lobbyists | (216,656) | (206,196) |
| Total | (216,656) | (206,196) |
The Cabinet Office determines the registration fee which includes costs associated with maintaining the Register and processing registration and quarterly information returns. The registration fee runs from 1 January to 31 December. The fee for 2024 and 2023 was £950. The quarterly information return fee has remained at £12.50 per quarter for both 2024 and 2023.
The fee for consultant lobbyists joining the Register part way through the year is calculated on a pro-rata basis.
4. Financial instruments
Funding for ORCL is received as grant-in-aid from the Cabinet Office. Therefore, the Registrar of Consultant Lobbyists is not exposed to significant liquidity or interest rate risk.
5. Trade and other receivables
| Description | As at 31 March 2024 (£) | As at 31 March 2023 (£) |
|---|---|---|
| Current – amounts falling due within one year | ||
| Amounts due from consultant lobbyists for fees | 805 | 3,371 |
| Amounts due from consultant lobbyists for civil penalties | 810 | – |
| Prepayments | 2,198 | 2,171 |
| Total | 3,813 | 5,542 |
6. Cash and cash equivalents
| Description | As at 31 March 2024 (£) | As at 31 March 2023 (£) |
|---|---|---|
| Balance at 1 April | 214,610 | 208,914 |
| Net change in cash and cash equivalent balances | (1,674) | 5,696 |
| Balance at 31 March | 212,936 | 214,610 |
| The following balance at 31 March was held at: | ||
| Government Banking Service | 212,936 | 214,610 |
| Balance at 31 March | 212,936 | 214,610 |
The cash will be used to settle amounts payable to the Consolidated Fund.
7. Trade and other payables
| Description | As at 31 March 2024 (£) | As at 31 March 2023 (£) |
|---|---|---|
| Current – amounts falling due within one year | ||
| Refunds due to consultant lobbyists | 1,198 | 1,198 |
| Other payables | – | 505 |
| Accruals | 22,000 | 23,858 |
| Deferred income(5) | 158,041 | 157,670 |
| Amounts payable to the Consolidated Fund – received:(6) | ||
| Fees from consultant lobbyists | 221,754 | 219,169 |
| Civil penalties from consultant lobbyists | 2,632 | 4,523 |
| Amounts payable to Consolidated Fund – receivable: | ||
| Civil penalties from consultant lobbyists | 810 | – |
| Total | 406,435 | 406,923 |
Note 5: Deferred income is further explained at Note 3.
Note 6: Information on the amounts payable to the Consolidated Fund is provided at Note 1 in the Parliamentary Accountability Disclosures Section.
8. Related party transactions
The Registrar of Consultant Lobbyists is a corporation sole funded by the Cabinet Office. The Registrar has had a number of transactions with the Cabinet Office in relation to corporate services. Neither the Registrar nor their staff have undertaken any material transaction with registered consultant lobbyists during the year. Compensation due to the Registrar in year has been disclosed in the Remuneration Report.
9. Events after the reporting period
In accordance with the requirements of IAS 10 Events after the Reporting Period, events after the reporting period are considered up to the date on which the accounts are authorised for issue by the Accounting Officer. This is interpreted as being the date on the Certificate and Report of the Comptroller and Auditor General to the Houses of Parliament. There are no events after the reporting period which affect these accounts.