Advisory Board for the Finnish Transparency Register: Clear guidelines on reporting financial information

In the interest of transparency in lobbying, it is important that not only the subjects, targets and methods of communication but also the resources used are reported. The Advisory Board would like to see sufficiently specific examples and instructions in the regulation to ensure that the disclosers understand what is expected of them.

In its position, the Advisory Board calls for a reassessment of the proposal according to which the disclosure obligation would also apply to persons carrying out background work when the persons participating in lobbying activities and the total volume of the activities are reported. Including any background work carried out by the discloser’s personnel in the total volume of lobbying activities is justified.

The Advisory Board proposes that the reporting could be based on the discloser’s understanding of the number of persons who participate in the lobbying activities and their person years.

The twice-yearly disclosures of activities have added to the disclosers’ administrative burden. In the drafting phase of the legislation, the need for reporting arrangements that would minimise the administrative burden was stressed. As significant annual cuts are currently being made in discretionary government grants for non-governmental organisations, any increase in the organisations’ administrative burden should be a last resort.

As authorities’ representatives, Jonna Carlson from the NAOF, Sami Demirbas from the Ministry of Justice, and Timo Moilanen from the Ministry of Finance as well as Academy Research Fellow Juho Vesa opted out of the position.

Financial information concerning lobbying and lobbying consultancy activities will be reported to the Finnish Transparency Register for the first time in disclosures of activities submitted in summer 2026. At that time, financial information for 2025 will be reported.

Position