The Transparency Register – new obligations for lobbyists

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The Transparency Register Act entered into force at the beginning of 2024, obliging organizations to report their lobbying activities to the new Transparency Register from 2024. Organizations that engage in lobbying activities must register with the Transparency Register by 31st of March 2024 and the actual reporting will start thereafter, in late summer 2024.

What is the Transparency Register?

The Transparency Register is a public register that is accessible online, and which anyone can view. The register is used to report on lobbying activities targeted at the Parliament and Finnish ministries, i.e. lobbying, as well as consulting on lobbying. The register is available, and the notifications can be opened through the Transparency register (avoimuusrekisteri.fi). Reports must be filed twice a year. The objectives of the introduction of the new register include improving the transparency of legislative lobbying and strengthening the transparency of the administration.

Who is required to report?

The following parties are obligated to register with the Transparency Register:

  • legal persons, for example companies and organizations, who engage in lobbying and related consulting, and
  • private business operators whose main activity is lobbying or related consulting.

Parties not subject to the obligation to provide information for the Transparency Register include for example:

  • private persons,
  • state authorities or state-owned enterprises,
  • municipality authorities and authorities of the wellbeing services county,
  • housing companies,
  • parties, party associations and parliamentary groups,
  • independent public institutions other than universities, and
  • private business operators who do not engage in lobbying or related consulting as their primary form of business.

The lobbyist (or consultant) is obliged to make a notification, not the party subject to the lobbying activity.

What is lobbying?

Lobbying activities that must be reported to the Transparency Register and lead to a registration obligation are long-term and systematic contacts with Parliament and Finnish ministries that are intended to promote a specific interest or objective by directly or indirectly influencing preparation or decision-making processes by the Parliament or relevant ministries. The relevant objectives may be, for example, political, economic, or other societal interests or objectives. It’s irrelevant how the lobbying activity is carried out (e.g. how the contact is made) or whether the target of the lobbying activity has initiated the contact.

In addition to lobbying activities, the Transparency Register also includes information on consulting on lobbying provided by, for example, external consultants. Such advice may be provided either as direct contacts to the subject of the lobbying by the consultant, or as services provided behind the scenes by advising or assisting the client in its lobbying activities.

Information on the following types of activities does not need to be reported to the Transparency Register:

  • small-scale lobbying (The limit to this is five contacts per calendar year),
  • normal use of services with authorities (such as grants and permits, participation in procurement processes or advice from a public authority),
  • participation in statutory bodies, working groups, advisory councils or similar multi-member bodies, or similar bodies established for a public task by public authorities or pursuant to law, or parliamentary or ministerial consultations, where such participation is documented,
  • public appearances at public meetings and events,
  • lobbying, when this is defined by law as the role of the relevant organization, and
  • sending newsletters and customer letters

How to register and make notifications?

To register for the Transparency Register, please visit the Transparency Register (avoimuusrekisteri.fi). The registration should include basic information about the organization and its activities, as well as the organization’s memberships in lobbying associations. The registration notification must be submitted by the end of March 2024 if the organization is currently active in lobbying. Otherwise, the registration must be submitted on the start date of the lobbying or related consulting.

The lobbying or related consulting shall be reported twice a year, in January-February (reporting period from July to December) and July-August (reporting period from January to June, from April of 2024 to June), by means of an operation notification. These notifications shall be made per topic, so that the notification contains information on the parties with whom the relevant organization has been in contact with, and the means of contact. From 2026 onwards, the July-August operation notification shall also include financial information on the lobbying.

The registration notifications and operation notifications submitted by organizations are available from the Transparency Register (avoimuusrekisteri.fi).

Supervisory authority and sanctions

For lobbying companies (and companies consulting on the same), registration with and reporting to the transparency register is a legal requirement. The National Audit Office is responsible for overseeing notifications registered to the Transparency Register and for supervising the reporting obligation. The National Audit Office can require relevant parties to submit a notification or to add, supplement or correct information reported to the Transparency Register, or provide other additional information. In grave circumstances, the National Audit Office can impose a conditional fine to guarantee the effectiveness of a notice to a party’s to comply with its reporting obligations. The National Audit Office also offers advice on the Transparency Register.

For more information please contact