Recent supervisory decision affects assessments of when lobbying must be disclosed

In a decision associated with its supervision of the Finnish Transparency Register, the National Audit Office (NAOF) takes a stand on methods of contact in lobbying. The decision concerns the way in which contacts associated with a trip are counted.

Lobbying organisations must take this recent decision into account when assessing the scale of their lobbying activities and if the activities should be disclosed to the Finnish Transparency Register.

A trip of several days is basically not a single contact

The NAOF’s supervisory decision concerns a report for 2024 in which the discloser stated that their lobbying activities were small in scale. The discloser regarded a trip of several days as a single contact.

Under the Transparency Register Act, the main methods of contact used in lobbying must be disclosed. The methods of contact referred to in the drafting documents of the Act are e-mail or other correspondence, online meeting, meeting or visit, telephone call, instant messages or other similar methods. There is no specific reference to trips.

The NAOF deems that a trip of several days cannot basically be regarded as an individual contact comparable to these methods. The calculation of contacts associated with a trip should factor in contacts relating to the preparations for as well as the programme and content of the trip. If the discloser disagrees, they should provide evidence based on which the NAOF can verify the number of contacts.

The limit for small-scale lobbying is five contacts

Rather than individual contacts, the subjects of lobbying should be reported to the Finnish Transparency Register. The number of individual contacts is nevertheless essential when a potential discloser assesses the scope of their lobbying and determines whether or not the activities should be reported to the Finnish Transparency Register.

Small-scale lobbying refers to activities that comprise no more than five individual contacts during a calendar year. This limit of five contacts has been set to eliminate the need to disclose individual contacts made every few months, or a one-off contact of more intensive nature, if the organisation does not otherwise engage in lobbying.

The NAOF provides advisory services for lobbyist as well as assistance in unclear cases. In cases where it is uncertain if the disclosure obligation applies, the NAOF will assess the nature of the lobbying on a case-by-case basis, if necessary. Should you have any concerns, please contact the advisory service of the Finnish Transparency Register.

Finnish Transparency Register Guidance Tel. +358 9 432 5888, weekdays at 10:00–14:00 avoimuusrekisteri@vtv.fi

Contact person

Ines Gullichsen Senior Auditor Tel. +358 50 575 9051 ines.gullichsen@vtv.fi