Lobbying targets

Information on lobbying targets is disclosed to the Transparency Register. Under the EU General Data Protection Regulation, the National Audit Office notifies the lobbying targets separately on the collection and storage of their personal data.

The Transparency Register does not directly affect the work of the lobbying targets but may require clarification of the existing stakeholder cooperation and hearing procedures. The principle of transparency also highlights the need to take equality into account in stakeholder cooperation.

Information on hearings and working groups must be documented appropriately so that it is clear who was heard, by what procedure, on what subject and at what stage. In addition, networked forms of working may require more clearly defined operating models if they are intended to be part of more formal stakeholder cooperation and hearings.

Parliament and the ministries as lobbying targets

Organisations engaged in lobbying must disclose long-term and systematic lobbying and lobbying consultancy that targets Parliament and the ministries to the Finnish Transparency Register.

Lobbying or lobbying consultancy is targeted at Parliament or the ministries if the target is:

• a Member of Parliament

• a Member of Parliament's personal assistant

• a staff member of parliamentary groups

• a minister

• a special adviser to a minister

• a state secretary appointed for a minister's term of office

• a public official of the Parliamentary Office

• a public official of a ministry, or

• a rapporteur appointed by a ministry.

Under the Transparency Register Act, some lobbying targets are named in the Register. The NAOF maintains and updates a public list of the persons to be named.

The name of the lobbying target is disclosed in the Transparency Register in the case of:

• a Member of Parliament

• a minister

• a special adviser to a minister

• a state secretary appointed for a minister's term of office

• the Secretary-General or Deputy Secretary-General of Parliament

• the Permanent Secretary or a head of department of a ministry, or

• a rapporteur appointed by a ministry.

In the case of other public officials, the organisation, department and unit is disclosed in the Transparency Register. In the case of political assistants, the parliamentary group they represent is disclosed.

Information on lobbying targets shown in the Finnish Transparency Register

The organisations subject to the disclosure obligation disclose to the Transparency Register the subjects of their lobbying, the persons contacted on each subject and the method of communication.

As regards the lobbying targets, only information on the role or position of the decision-maker is disclosed to the Transparency Register. The information to be disclosed to the Register on the lobbying targets does not include information related to their private life or other roles in society, such as the duties as a municipal politician or positions of trust.

In addition to a decision-maker, the lobbying target may also be a member of the board of directors of a lobbying organisation. However, if, for example, an MP is a member of the board of directors of an association, a board meeting of the association is not reported to the Transparency Register. This is because board meetings are the association's internal activities, and an MP as the association's board member is not a lobbying target as referred to in the law.

Nevertheless, if the lobbying target, for example in the role of the association’s board member carries out lobbying on behalf of the association they represent, the association in question is obliged to disclose this lobbying to the Transparency Register. In other words, communication between lobbying targets and other decision-makers may also fall within the scope of the disclosure obligation.

Organisations engaged in lobbying register with the Transparency Register when they start lobbying or when the limit for small-scale lobbying is exceeded and report their activities to the Register every six months, in July–August and in January–February.

Disclosures submitted to the Transparency Register are public and free to browse. The disclosures are retained on the website of the Transparency Register for 10 years, after which they are archived permanently.

Lobbying that targets Parliament or the ministries

Lobbying means influencing public decision-making, preparation or implementation, either directly or indirectly. It is a systematic activity that aims to build trust between lobbyists and decision-makers in the long term by establishing relationships. The Transparency Register does not prevent lobbying but increases its transparency.

A key feature of lobbying is the aim to get decision-makers to act in a manner that promotes the lobbyist's interest. Lobbying is an integral part of the political system and democracy, and the purpose of the Transparency Register is not to prevent lobbying but to increase its transparency.

According to the Transparency Register Act, lobbying refers to communication with a lobbying target on behalf of an organisation with the aim of influencing the preparation and decision-making of a matter by promoting a particular interest or objective.

Lobbying consultancy, in turn, refers to professional lobbying on behalf of a customer or providing support to a customer in lobbying. Such activities are typically practised in Finland by communications agencies and possibly by law firms in the field of legal consultancy.

More information about the Finnish Transparency Register for lobbying targets

The National Audit Office is happy to advise the staff of Parliament and the ministries on matters related to the Transparency Register. We can also provide training on the subject. You can send requests for contact, questions as well as reports and requests for rectification related to the information in the Transparency Register to avoimuusrekisteri@vtv.fi.