Here are answers to some of the most common questions that we are asked. These answers should be read alongside the more detailed information in the legislation and the guidance that the Registrar has issued. The FAQs do not aim to deal with unusual or complex situations and the Office of the Registrar is happy to provide further information or guidance firstname.lastname@example.org
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). If a person or organisation commits an offence under the Act the Registrar can impose a civil penalty of up to £7500 or refer the matter to the Director of Public Prosecutions for potential criminal prosecution.
The Registrar is not a regulator, but ensures that consultant lobbying activity is registered in accordance with the Act. 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 the code. If a code of conduct is declared on the Register, this will include a route for complaints. The Registrar has no role in the handling of any such complaints, nor in monitoring adherence to any declared code.
Yes. The Registrar takes allegations about a person or organisation who is suspected of carrying out consulting lobbying without being on the Register seriously. If there is sufficient evidence, the Registrar will conduct a formal investigation. Please send as much detail as possible to email@example.com.
The Registrar is an office holder appointed by statute and is independent of Government. They are accountable 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 communicating with 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 on behalf of yourself is outside the remit of the Registrar. In the interests of transparency, such people may wish to consider including themselves on the voluntary industry body registers, such as the UK Lobbying Register (maintained by CIPR) 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 voluntarily 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 voluntarily disclosed.
You can apply to join the Register via the Register portal. We will enter your details on the published Register within four working days of a completed registration. You will be sent a registration fee demand, which must be paid within 30 days to validate your 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 the Cabinet Office through secondary legislation.
The payment demand will include payment details.
No. Lobbying of Members of Parliament falls outside the remit of the Registrar (unless the MP is also a Minister). The legislation allows for lobbying of special advisers to be included alongside Ministers and Permanent Secretaries by regulation, but this has not been enacted.
Yes. to opt in or out, email firstname.lastname@example.org giving your name, email address and organisation that you work for.
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, including any change to your code of conduct declaration. 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.
What will I be asked in the QIR?
You will be required to:
Yes, though you will not be able to do so through your online Register account. Once the QIR has been submitted, if you need to make a correction, please email email@example.com with the details and we will amend your entry. If the correction is made after the QIR deadline and is an inaccuracy rather than for example, a typo, it is an offence under the Act and will be referred to the Registrar.
Failure to provide accurate and complete information within the statutory time period 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.
What if I’m not sure whether an activity is registerable?
The registration fee applies for a full calendar year, so we send out fee renewal notices in November and you must pay this by 31 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 declaring that no consultant lobbying was undertaken or paid for during the period, the registrant will be marked in the Register as ‘This registrant has completed nil returns for the last six or more months’, but will remain registered and therefore able to provide consultant lobbying services legally in future.
Contact the Office by email to firstname.lastname@example.org. You can leave from the date you email us or from a future date. You cannot backdate the date you leave. Your leaving date will be used to calculate and issue you a pro rata refund for 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:
Category: Archive - Tuesday 7th June 2016
The latest exercise for processing the January – March 2016 Quarterly Information Returns was completed successfully. Of the 116 organisations required to submit QIRs, 103 undertook consultant lobbying.
Category: Archive - Monday 23rd May 2016
On 26 April, Alison White, the Registrar of Consultant Lobbyists, spoke at a meeting of public affairs professionals in Belfast, hosted by the PRCA, Northern Ireland.
Category: Corporate documents - Wednesday 30th March 2016
Today the Registrar of Consultant Lobbyists published her Business Plan for 2016-17. The Plan sets out how she intends to fulfil her statutory obligations.
Category: Statutory notices issued - Wednesday 30th March 2016
On 19 December the Registrar of Consultant Lobbyists, Alison White, issued her first Civil Penalty Notice to Advocate Policy and Public Affairs Consulting Ltd.
Category: Archive - Friday 25th March 2016
The Register of Consultant Lobbyists is one year old on 25 March 2016. This is the first time there has been statutory lobbying legislation in the UK. Currently standing at 114 registrants, the Register includes organisations such as lawyers, accountants and a think tank, as well as those from the public affairs sector.
On Monday 21st March the Registrar launched her policy on information publication and retention, following a Consultation in December through to January.
Category: Archive - Tuesday 26th January 2016
On Thursday 21 January the Office of the Registrar of Consultant Lobbyists held an event on Lobbying regulation at the BIS Conference Centre in London.
Category: Consultations - Wednesday 23rd December 2015
Today the Registrar of Consultant Lobbyists launched a consultation on information publication and retention.
Category: Archive - Thursday 10th December 2015
The Cabinet Office announced on 10 December that the registration fee for 2016 will increase to £950 (plus £12.50 per quarterly update).
Category: Archive - Monday 30th November 2015
On 20 November, Alison White, the Registrar of Consultant Lobbyists, spoke at the ‘Lobbying transparency and disclosure: expert and regulator seminar’ at the University of Stirling.