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Whether Devo Agency is an unregistered consultant lobbyist.
Registrar’s decision
Devo Agency carried on the business of consultant lobbying while not being registered.
Summary of rationale for decision
Section 1(1) of the Transparency of Lobbying, Non-Party Campaigning and Trade Union
Administration Act 2014 (“the Act”) states that a person must not carry on the business of
consultant lobbying unless entered in the Register of Consultant Lobbyists (“the Register”).
Section 2 of the Act defines consultant lobbying. A summary of this definition is: UK VAT
registered organisations and individuals who communicate personally with Government
Ministers or Permanent Secretaries (and equivalents) concerning specified matters on behalf
of a third party and in return for payment.
Devo Agency made two direct communications to the Minister for Local Government and English Devolution between 13 May 2025 and June 2025, before registering as a consultant lobbyist on 1 August 2025. The communications were in relation to their clients Greater Manchester; Liverpool; and North East All-Party Parliamentary Groups. Devo Agency was VAT registered at the time of the communications.
The Registrar considers that the two communications were registerable.
Chronology
Date
Action
9 and 14 July
Emails sent to the Office of the Registrar of Consultant Lobbyists with evidence of potential consultant lobbying.
16 July
Formal letter from the Registrar to Devo Agency giving background on the requirement for registering and asking if activities, whether individually or through a company, fall within the criteria to be registered with particular reference to, but not limited to, communications with ministers regarding the northern powerhouse education, employment and skills summit 2025; and any communications with the Minister for for Local Government and English Devolution on behalf of the Greater Manchester and Liverpool All-Party Parliamentary Groups or their sponsors.
30 July
Email from Devo Agency to the Registrar giving background on the company and an event in June and a cancelled event in July.
1 Aug
Devo Agency joins the Register.
12 Aug
Letter from the Registrar to Devo Agency requesting further information regarding communications at or before the event in June.
13 Aug
Email from Devo Agency to the Registrar regarding the event in June.
20 Aug
Letter from the Registrar to Devo Agency requesting further information about the communications and the paying clients for the June event.
3 Sept
Email from Devo Agency to the Registrar providing further information about communications relating to the pan-Northern meeting with the Minister for Local Government and English Devolution on behalf Devo Agency’s clients: Greater Manchester; Liverpool; and North East All-Party Parliamentary Groups.
10 Sept
Letter from the Registrar giving advice to ensure future compliance with the Act. Notice of Intention to issue a civil penalty is issued.
9 Oct
Civil Penalty Notice issued, following no representations from Devo Agency regarding the Notice of Intention.