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Here are answers to some of the most common questions that we are asked. These set out the general position, but you can find more detailed and definitive information on many of these topics in the legislation and the guidance that the Registrar has issued. If you have a question that is not answered here or in the legislation or published guidance, please contact the Office of the Registrar and we will be happy to help: Enquiries@orcl.gov.uk.
The Registrar is an independent statutory office holder appointed under the Transparency of Lobbying, Non-party Campaigning and Trade Union Administration Act 2014 (‘the Act’).
Under the Act, the Registrar is required to:
The Act sets out two key obligations on consultant lobbyists as defined by the Act
When investigating whether a person or organisation should be on the Register, the Registrar may issue a statutory information notice, requiring the provision of relevant information. The Registrar may issue a civil penalty notice where a person or organisation has not complied with the requirements of the Act. This includes: undertaking consultant lobbying whilst unregistered; failing to respond to a statutory information notice (or responding in an inaccurate, late, or incomplete manner); or failing to provide a Quarterly Information Return (or doing so in an inaccurate, late, or incomplete manner).
The Registrar is not a regulator. If a registrant wishes to declare on the Register that they abide by a code of conduct, the Registrar determines whether the proposed code is ‘relevant’ to consultant lobbying and can therefore be declared on the Register. This assessment includes the requirement for a code to include some external and independent oversight in the monitoring or handling of complaints of breach of that code. However, the Registrar has no role in the handling of any such complaints, nor in monitoring adherence to any declared code.
Yes. The Registrar investigates allegations about a person or organisation who is suspected of carrying out consulting lobbying without being on the Register. Please email as much detail as possible to Enquiries@orcl.gov.uk.
The Registrar is an office holder appointed by statute and is independent of Government. They are accountable directly to Parliament, principally through the Public Administration and Constitutional Affairs Committee. The Registrar provides their annual report and accounts to Parliament. As with other public bodies, the Registrar has a sponsor Department, (Cabinet Office in this case) whose Minister arranges for the provision of staff and services to support the Registrar in delivering their statutory duties.
Policy and legislation relating to lobbying are the responsibility of the Cabinet Office, not the Registrar.
It is illegal to conduct consultant lobbying activity without first being on the statutory Register. In broad terms, consultant lobbying is contacting a UK Government Minister or Permanent Secretary (or certain equivalents) on behalf of a third party, in return for payment. There is a definition in the Act and the Registrar’s guidance contains more detailed information on applying that definition. Please contact us if you are unsure if your activities require you to register.
No. The statutory obligation applies only to consultant lobbying, so lobbying by in-house teams or individuals is outside the remit of the Registrar. In the interests of general transparency, such people may wish to consider including themselves on the voluntary registers maintained by industry bodies, such as the UK Lobbying Register (maintained by CIPR) and/or the Public Affairs Register (maintained by PRCA).
No. The Register exists to give public clarity and transparency about which organisations and individuals undertake consultant lobbying work and for whom.
No. If your organisation is not registered for VAT, then you cannot join the Register.
Delivering or being paid in advance for consultant lobbying work whilst unregistered is an offence under the Act, even if committed unintentionally. It is therefore highly likely that you will receive a civil penalty for any pre-registration consultant lobbying activity when you do register. Where you proactively declare such breaches, the Registrar will take that into account in determining any penalty, as opposed to higher penalties that are likely for offences that are not proactively disclosed.
You can apply to join the Register via the Register portal or you can email us at Enquiries@orcl.gov.uk. In either case, once we have confirmed that the activity requires registration, gathered all necessary information and you have paid the registration fee, we will enter your details on the published Register. Although this process can take some time, once we have confirmed your registration details and you have paid the fee, we backdate the legally effective date of your registration to the date you contacted us to initiate registration.
Registration costs £1000 a calendar year. This is made up of the registration fee of £950 and £12.50 per Quarterly Information Return period. If you join the Register part-way through a year, you will pay a pro-rata fee. There is also a fee of £12.50 for processing your initial registration. Fee levels are determined by a Cabinet Office Minister through secondary legislation.
All payments due to the Registrar (whether registration fees or civil penalties) are invoiced and the invoice will include payment details.
No. Lobbying of Members of Parliament falls outside the remit of the Registrar. The legislation allows for lobbying of special advisers to be included alongside ministers and Permanent Secretaries by regulation, but this has not been done.
In simple terms, your responsibility is to keep your information on the Register up to date. You must supply information in a Quarterly Information Return (QIR) in the two week period after the end of a quarter. This confirms whether or not you have undertaken (or been paid in advance for) consultant lobbying work during the preceding quarter and lists the clients concerned. You must also advise the Registrar of changes to the other statutory information in your published Register entry and details of any relevant code of conduct. Your legal obligation is to advise the Registrar of these changes in the QIR, but you should inform us of any changes to contact information immediately so that we can communicate with you properly.
Yes, though you will not be able to do so through your online Register account. Once the QIR has been formally submitted, if you need to make a correction, please email Enquiries@orcl.gov.uk with the details and we will amend your entry.
Failure to provide accurate and complete such information within the statutory time periods is an offence under the Act, even if committed unintentionally. The requirements and timeframe for providing QIRs are clear and the Registrar is therefore very likely to issue a civil penalty for a missing, late, inaccurate or incomplete QIR.
The registration fee applies for a full calendar year, so we send out fee renewal invoices around six week before the start of the new registration year and you should pay this by mid-December. If you do not pay your fee before 1 January you will be removed from the Register with effect from that date and will need to re-register before you can legally undertake any consultant lobbying work.
The Registrar understands that some registrants may not undertake consultant lobbying activity in every quarter. After two consecutive QIRs that specify that no consultant lobbying was undertaken or paid for during the period, the registrant will be marked in the Register as ‘not an active consultant lobbyist’, but will remain registered and therefore able to provide consultant lobbying services legally in future.
Contact the Office by email to Enquiries@orcl.gov.uk and we will agree the effective date of your leaving the Register, which will be used to calculate and issue you a pro rata refund in respect of the remainder of that calendar year’s registration fee.
The Registrar is the only statutory body concerned with registration of consultant lobbying activity in relation to UK Government Ministers and Permanent Secretaries. However, you might find the following useful: