Questions and answers

Presentation of the Finnish Transparency Register

1. What is the Finnish Transparency Register?

Any representation of interests (lobbying) that targets Finnish Parliament or the ministries as well as lobbying consultancy must be reported to the Transparency Register.

Lobbying refers to contacts that aim to influence a matter or decision-making by promoting a certain interest or objective. Lobbying consultancy refers to professional lobbying carried out on behalf of a customer, or to providing support to a customer in lobbying.

Read more about the Transparency Register and its operating principle.

2. Is the Transparency Register a meeting diary?

No. There is no need to report every contact or its date separately to the register.

The idea is that lobbying activities or lobbying consultancy targeting Finnish Parliament or a ministry are disclosed to the register by subject. This means that the following must be disclosed:

• subjects of lobbying

• persons who have been contacted about the subjects

• main method of communication

• resources used on lobbying (financial information).

Each subject only needs to be disclosed once, even if there had been several contacts relating to it. Similarly, the same target of lobbying is only reported once for each subject, even if the same person had been contacted several times about the same subject.

For example, if a Member of Parliament is mentioned in connection with a subject, this indicates that the organisation has contacted the Member of Parliament in question about the subject at least once during the reporting period. While there may have been more contacts, there is no need to report all of them.

3. When should lobbying be disclosed to the Transparency Register? Can disclosures of activities be submitted to it on a continuous basis?

No. You cannot submit disclosures of activities each time a target is contacted. The Transparency Register does not work like a meeting diary.

Under the Finnish Transparency Register Act, lobbying and lobbying consultancy activities are disclosed twice a year. Lobbying activities carried out between January and June are disclosed to the Register in July or August, and those in the period between July and December are reported in January or February.

Read more about the reporting schedules of the Finnish Transparency Register.

Who must register with the Transparency Register?

4. Does the Finnish Transparency Register Act also apply to foreign organisations?

The Transparency Register Act also applies to foreign legal persons that engage in long-term and systematic lobbying activities or consultancy relating to them targeted at Finnish Parliament or ministries.

5. Our organisation is part of a lobbying organisation. Are we subject to the disclosure obligation automatically, or only if we engage in lobbying activities?

The organisation must report to the Transparency Register if it engages in lobbying activities, in other words contacts Finnish Parliament or a ministry and consequently seeks to influence drafting or decision-making in a specific matter.

Membership in a lobbying organisation does not create a disclosure obligation if the organisation itself does not contact decision-makers for lobbying purposes, that is, does not engage in lobbying activities.

6. Who does not need to register?

For example, the activities of private individuals or non-organised civil society need not be disclosed to the Transparency Register. See full list of actors who need not register.

How to submit registration

7. How can I request or receive authorisations to use the Transparency Register on behalf of my organisation? And who can submit disclosures to the Transparency Register on behalf of the organisation?

The Transparency Register can be used by anyone who has an automatic right to act on behalf of the organisation because of their role, or who has been specifically authorised by the organisation to do so.

Rather than in the Transparency Register’s online service, these authorisations are granted in the Suomi.fi service or requested by submitting an application to the Digital and Population Data Services Agency. The organisation may authorise as many people as it wishes to use the Transparency Register.

Read instructions for authorising users.

8. When submitting a registration, should an organisation also include its affiliations with foreign lobbying organisations?

Yes. The organisation's memberships in all associations engaged in lobbying activities should be disclosed to the register. Such associations mainly include those that engage in centralised lobbying activities, which often are umbrella organisations. Knowledge of memberships in these organisations helps to understand the scale of the lobbying activities and the actors involved in it.

Small-scale lobbying activities

9. What does small-scale lobbying mean?

Lobbying is deemed small in scale if lobbying targets are contacted no more than five separate times during a calendar year.

For example, a telephone conversation, a meeting or an email message is considered one contact. An individual contact can have several simultaneous recipients in different organisations. In this case, it is considered a single contact.

The limit of five separate contacts allows small lobbying actors to contact targets occasionally without having to register with the Transparency Register.

10. Our organisation engages in small-scale lobbying. Should it register?

No. Small-scale lobbying activities need not be disclosed to the Transparency Register.

A small-scale actor should monitor their lobbying activities and register when the limit of small-scale activities is exceeded. Lobbying is no longer deemed small in scale if lobbying targets are contacted more than five separate times during a calendar year.

11. Can lobbying consultancy be small in scale?

No. All lobbying consultancy must be reported to the Transparency Register regardless of the number of contacts.

12. Do you need to submit a disclosure if you have registered with the Transparency Register but you have only engaged in lobbying activities on a small scale, or not at all?

Yes, all registered organisations must submit a disclosure indicating at least the scope of their lobbying activities every six months. The scope is determined by the number of contacts the organisation has had with lobbying targets during the reporting period: more than 5 contacts, at most 5 contacts or no contacts at all.

The number of contacts is only significant when assessing if the threshold for small-scale lobbying activities has been exceeded (at most 5 contacts per calendar year). An organisation engaged in small-scale lobbying activities does not need to itemise the subjects of lobbying in their disclosure.

If the lobbying activities continue to be small in scale, the organisation should deregister. An organisation with small-scale activities can only deregister if its lobbying activities have not exceeded the limit for small-scale activities in the current year at the time of deregistration.

Deregistration should also be submitted if the organisation discontinues its lobbying activities altogether.

13. What counts as a single contact?

For example, a single telephone conversation, meeting or email relating to lobbying is regarded as a separate contact. An individual contact can have one or more lobbying targets as recipients.

For example, an individual email message sent to several lobbying targets is regarded as a single contact. A meeting with several lobbying targets is also considered a single contact if everyone is present and involved in the discussion at the same time.

However, if a lobbying email has been sent separately to different recipients, this involves several contacts, even if each email sent out is similar in content or all emails were sent on the same day.

Lobbying

14. A network, parent company, umbrella organisation or similar organises a lobbying event. Are all participants subject to the disclosure obligation?

The legal person organising the event must report it to the Transparency Register. The participants' obligation to disclose the event depends on whether or not they engage in lobbying at it.

Mere participation in the event is not lobbying and does not create a disclosure obligation. However, if an actor engages in lobbying targeted at Finnish ministries or Parliament at the event, this must be disclosed.

15. If a lobbying target, such as a Member of Parliament, is a member of our organisation's Board of Directors, do we have an obligation to disclose the Board meetings and the matters discussed at them?

An association’s Board meetings are internal activities that do not need to be disclosed even if the Board members include lobbying targets.

A Member of Parliament (or some other lobbying target) serves as a Board member and is responsible for the association's activities in the same way as other Board members. Consequently, a person who is a Member of Parliament or works at a ministry is not a lobbying target referred to in the Transparency Register Act when serving as a Board member.

16. I contact a person serving as a municipal and/or regional councillor who is also a Member of Parliament. Will the organisation I represent be subject to the disclosure obligation?

This depends on what you contact them about. If the contact is relevant to the target's role referred to in the Transparency Register Act, the contact must be disclosed. The threshold for interpreting a Member of Parliament as a lobbying target is low.

If necessary, contact the National Audit Office of Finland for case-by-case instructions.

17. Can an individual, such as a politician, be a lobbyist and a lobbying target at the same time?

Yes. The key is identifying the role that the person plays at any given time: whether they act as a private person, decision-maker or representative of an organisation.

Private individuals’ political activities or contacts with lobbying targets, or contacts of a political party or its affiliated entity with lobbying targets, are not reported to the Transparency Register. Being active in politics does not eliminate the disclosure obligation, however, if the same person engages in lobbying as a representative of an organisation.

Lobbying on behalf of an organisation must be disclosed as required by law.

18. We participate in an event convened by Parliament or a ministry. Should we disclose it?

The crucial issue is whether the discussion takes place within the framework of a working group set up by an authority or other similar body, participation in which is documented.

This means that the disclosure obligation does not apply to participation in documented working groups, advisory boards, bodies or hearings that have been set up by an authority or that are statutory. This includes committee hearings and ministries' requests for an opinion.

Unofficial contacts must be reported to the Transparency Register. As such unofficial communication can be regarded cooperation in which no information on the contacts is recorded in the working documents.

19. Should an event at which an organisation presents its activities be disclosed if the participants include lobbying targets?

Mere presentation of activities need not be disclosed, unless its purpose is to influence the preparation of or decision-making on a matter. Consequently, the organisation is subject to the disclosure obligation if it engages in lobbying at the event. In this case it must report all lobbying targets that it has contacted.

The same principle applies if an organisation is invited to Parliament or a ministry to present its activities, or if representatives of Parliament or a ministry visit the organisation: the organisation is subject to the disclosure obligation if it engages in lobbying in connection with the event.

20. We produce public social media content for lobbying purposes. Should this be disclosed to the Transparency Register?

No. Public lobbying on social media aimed at everyone need not be disclosed, not even if the social media publication addressed lobbying targets separately.

21. How can lobbying be distinguished from a private individual's activities in different contexts, such as events, hobbies or social evenings?

As a basic premise, the actor must themselves recognise when they are lobbying and when acting as a private individual. Private individuals' activities need not be disclosed to the Transparency Register.

Matters falling within the scope of privacy protection are not reported to the Transparency Register. Consequently, discussions and getting to know people at events that were not organised to promote a certain objective or interest are usually not subject to the disclosure obligation.

If an actor strives to influence the drafting of and decision-making on a matter on behalf of the organisation they represent and promote a certain interest or objective, this type of a discussion does not comprise a private individual's activities.

22. What kinds of contacts with Parliament or ministries need not be disclosed?

For example, small-scale lobbying, ordinary dealings with authorities, speaking at public events or participation in documented working groups, advisory boards and hearings set up by an authority need not be disclosed.

Read more and see a full list of situations that need not be disclosed in the section ”Which activities are not disclosed”.

23. If you discuss security of supply issues with public officials at ministries, should the discussions be disclosed or are they secret?

Under the Transparency Register Act, contacts with a lobbying target must be disclosed if their aim is to influence drafting and decision-making. However, the Transparency Register Act does not repeal the secrecy provisions concerning security of supply matters to which the lobbyist and the lobbying target are subject and with which they must comply.

Lobbying consultancy

24. A communication firm sells consultancy services related to lobbying to its customer and, on behalf of their customer, arranges meetings with Parliament and ministries in which the customer participates. Who must report their activities to the Transparency Register?

The communication firm must report its lobbying consultancy. This case involves lobbying on behalf of the customer. The customer also reports the contacts in their disclosure of activities if they participate in meetings or other contacts.

Each legal person is obliged to disclose their lobbying activities and/or lobbying consultancy.

25. If a company providing lobbying consultancy prepares a lobbying plan for a customer organisation but the customer does not use it, who reports what to the Transparency Register?

Drawing up a lobbying plan involves providing lobbying consultancy to a customer, regardless of whether the plan goes ahead or not. The party that prepared the lobbying plan, in this case the company that provided lobbying consultancy, will disclose the plan.

An actor providing consultancy services must recognise when they are engaging in lobbying or lobbying consultancy and how these activities relate to advocating the customer’s goals in society.

The Transparency Register Act does not require actors to only disclose services designated as lobbying or lobbying consultancy ordered by a customer. A service ordered by a customer may also include communications and marketing services, internal development or legal advice. In unclear situations, it is advisable to check with the customer.

The organisation that commissioned the lobbying plan is, for their part, obliged to disclose all lobbying activities it which it engages.

26. A lobbying consultancy company lobbies on behalf of its customers and provides them with lobbying consultancy services. What should be reported to the Transparency Register when a consultant is involved in planning a customer’s lobbying activities and lobbying on behalf of the customer?

A company providing lobbying consultancy is obliged to disclose both the support it offers to the customer and the contacts the company has made on behalf of or together with the customer.

Disclosing the subjects

27. How do I report a subject to the Transparency Register?

The subject of lobbying must be disclosed as accurately as possible. For example, this may mean the level of an individual policy, legislative, budgetary or development measure, or project.

If the lobbying has targeted an official government project, the subject is reported by selecting 'official project’ in the system and entering its project number.

An organisation can also disclose a self-defined subject. The subject should be disclosed in Finnish or Swedish, using 50 to 600 characters.

The subject indicates to the public the issue the organisation has attempted to influence through its communication. This is why it is important to describe the subject clearly, making it possible for an outsider to understand the issue about which the organisation has contacted the decision-maker.

28. We send an invitation to a meeting to several lobbying targets, but only one of them participates. Should the targets who responded or participated in the event be itemised in the disclosure?

Sending an invitation to a lobbying target may involve lobbying if the content of the invitation has already been created with this aim in mind. In this case, all lobbying targets to whom the invitation was sent must be disclosed, regardless of whether they participate or respond.

If the lobbying target participates in the event and it involves lobbying, this must also be disclosed. If a discussion at the event later leads to closer contacts with the target that must be regarded as lobbying, these contacts must be disclosed.

29. We email invitations to our company's celebratory event to a long list of recipients. The recipients include lobbying targets. Is this deemed lobbying?

See the answer to question 28 above.

30. We discuss a number of different subjects at a meeting with a Member of Parliament. Should the meeting be disclosed as pertaining to a single subject, or should all the subjects discussed at the meeting be reported separately?

All subjects of lobbying should be disclosed, regardless of whether they were discussed at the same time or at separate meetings. All subjects brought up at the meeting in question should consequently be reported separately, and the Member of Parliament in question should be linked to each subject.

If the subject of the meeting was also discussed with other lobbying targets on another occasion, they should be linked to the same subject. This means that a subject only needs to be recorded once in the disclosure of activities, even if it has been discussed with various targets in different situations.

31. We meet a lobbying target several times and discuss the same subject of lobbying each time. Should each meeting be reported separately?

No. The Transparency Register is not a meeting diary. Every contact or its date need not be disclosed separately.

Disclosures to the Transparency Register are submitted by subject. If you have met several decision-makers and only discussed a single subject, it is sufficient to only disclose this subject once. You then disclose all lobbying targets that have been contacted about the subject by linking them to it. In other words, you need not report when and how many times you have met each individual in connection with the subjects and targets of lobbying.

Financial information

32. Does financial information need to be reported for small-scale lobbying?

An actor engaging in small-scale lobbying activities, in other words up to five contacts with targets during a calendar year, is not required to register with the Finnish Transparency Register. If the actor registers but reports that their activities were small in scale throughout the calendar year, financial information need not be reported for that year.

33. Our employee spends working time on creating lobbying material but does not personally participate in lobbying and communication. Should this working time be included in the person-years?

If the employee in question has not participated in lobbying activities and contacting lobbying targets relevant to them, this person should not be included in the total number of people who participated in lobbying.

As they are not included in the total, the working time they spent on preparing the lobbying materials is not regarded as work input in lobbying activities.

34. If the organisation is not registered with the Transparency Register (for example because it only engages in small-scale lobbying) but it purchases lobbying consultancy services, should it register and disclose these purchases?

If the organisation has not engaged in its own lobbying activities subject to the disclosure obligation, it does not need to register with the Transparency Register. Neither does the organisation need to register only to disclose the purchase of consultancy services.

An organisation engaged in lobbying consultancy reports the advice they have provided and the turnover derived from it in their disclosure of activities.

35. We serve lunch and coffee to a lobbying target at a lobbying meeting. Should only the target's share of the entertainment be included in the representation costs of the lobbying activities, or also the share of those who represented the lobbying organisation?

If you provide lunch for the lobbying target, all costs incurred by the organisation from the entertainment relating to the lobbying activity in question should be included. This means that all costs of the lunch meeting are included, also those incurred by the representatives of the lobbying organisation.

Others

36. Do the registration and disclosures of activities of the parent company, umbrella organisation or federation also cover the activities of subsidiaries, affiliated associations or similar?

No. Each legal person is subject to the disclosure obligation in its own right. Each organisation that engages in lobbying in its own name should register and disclose its lobbying activities separately.

If you are unsure of your organisation's obligation to submit disclosures to the Transparency Register, you can contact the National Audit Office for guidance.

37. The organisation has statutory tasks. Does it have to disclose its lobbying activities?

The organisation is not obliged to report lobbying activities in which it engages as a task specifically imposed on it by law. Consequently, ordinary contacts with Parliament or ministries associated with the performance of statutory duties are not subject to the disclosure obligation.

If, in addition to its statutory duties, the organisation also engages in lobbying or lobbying consultancy activities that are not expressly laid down as its statutory duties by law, they must be reported to the Transparency Register. Whether an activity is part of the performance of statutory tasks or not should be assessed separately in each individual case.

38. Is a legal person fully or partly owned by a city (such as a limited liability company) subject to the disclosure obligation?

The Act does not provide for exceptions to the registration and disclosure obligation of legal persons fully or partially owned by cities or municipalities.

If a city or municipality has established a legal person (such as a limited liability company) to carry out its statutory duties, the situation must be assessed on its individual merits. The disclosure obligation does not apply to the performance of statutory duties.

If you are unsure of your organisation's obligation to submit disclosures to the Transparency Register, you can contact the National Audit Office for guidance.

39. Is sales or product development work subject to the disclosure obligation?

Selling or supplying services or goods to an authority are regarded as normal communication that is not subject to the disclosure obligation. Participation in a public procurement procedure is also excluded.

Pursuant to the Act, lobbying means contacts with a lobbying target aiming to influence the drafting of and decision-making on a matter by promoting a certain interest or objective.

In practice, this means that lobbying may also be related to business interests, budgeting, procurement or other similar activities. For example, lobbying activities that focus on the budget and appropriations must be reported to the Transparency Register.

If necessary, contact the National Audit Office of Finland for case-by-case instructions.

40. Does a lobbyist's form of employment play a role for the disclosure obligation?

No. As a basic premise, a lobbyist's employment relationship or the nature of their job do not affect the disclosure obligation. The organisation must recognise when persons working on its behalf engage in lobbying within the scope of the Transparency Register Act.

For example, a volunteer may participate in lobbying activities carried out on behalf of an organisation if they represent the organisation as part of the organisation’s planned lobbying activities. If the person contacts lobbying targets in their own name, this comprises a private individual’s activity that need not be disclosed.

Please note! In disclosures of financial information, whether or not a person who participated in lobbying received a wage or other financial benefits from their work is significant. The total number of persons who participated in lobbying should only include those

• who participated in the organisation’s lobbying activities during the previous calendar year, and

• who received a wage or other financial benefits from this work.

If no persons who received a wage or other financial benefits participated in the lobbying activities in the previous calendar year, the organisation should select 0 as the total number of persons in the financial information.

Read more about disclosing financial information.

41. An umbrella organisation, federation, parent company or similar provides advice relating to advocacy to its members, subsidiaries or similar. Should this be disclosed to the Transparency Register?

No. Advice provided by an organisation to its members need not be disclosed.

42. How does a network of different organisations report its lobbying activities to the Transparency Register?

If the network is a legal person, it must register with the Transparency Register and disclose its lobbying activities. In this case, the organisations in the network need not disclose the network's lobbying separately. The organisations are still obliged to disclose their other lobbying activities themselves, however.

If the network is not a legal person, any legal persons operating as part of it are obliged to report. In this case, any lobbying organisations that engage in lobbying must disclose this as part of their lobbying activities.

The network's name can be added to the subject field of the disclosure of activities if the organisation wishes to bring it up in the Transparency Register.

43. If I lobby Finland's Permanent EU Representation in a country, should I report this to the Transparency Register?

The public officials working in Finnish missions abroad are excluded from the scope of the Transparency Register Act. However, lobbying a target to which the Act applies should be disclosed, even if the activities take place abroad.

44. We must maintain an internal personal data file in order to report our lobbying activities to the Transparency Register. Does the NAOF provide instructions on maintaining a personal data file?

For instructions on maintaining a personal data file and data protection, you should contact the Office of the Data Protection Ombudsman.