More detailed guidelines on disclosing lobbying activities
The NAOF has issued more detailed reporting guidelines for actors engaging in small-scale lobbying and the languages in which the data must be submitted to the Finnish Transparency Register. An Excel template for collecting lobbying data is also available.
The Act on the Finnish Transparency Register lays down the threshold for small-scale lobbying activities. To be regarded as small-scale activities, lobbying can comprise no more than five individual contacts with one or more lobbying targets during a calendar year. An individual contact can have one or more lobbying targets as recipients.
The legislator’s intention was to exclude actors whose lobbying is permanently on a small scale from the Finnish Transparency Register due to the low level of their activities. If the scale of the lobbying activities varies, so that they are sometimes below the threshold for small-scale lobbying and sometimes exceed it, the actor must register with the Finnish Transparency Register.
All lobbyists must submit a disclosure but the subjects of small-scale lobbying need not be itemised
All registered lobbyists must submit a disclosure of activities twice a year. If the scale of the lobbying activities has been small during the reporting period, however, the actor is not obliged to itemise their subjects in the disclosure of activities. This means that if the scale of an actor’s lobbying activities varies, they must keep track of whether or not the threshold for the small scale is exceeded.
If this threshold is not exceeded at all during the entire year, there is no need for the actor to itemise the subjects of their lobbying for the year in question. If the threshold is exceeded at some point during the year, the subjects of the lobbying activities must be itemised in the next disclosure, as the activities are no longer small in scale and the disclosure obligation applies to them.
An actor registered with the Finnish Transparency Register who estimates that they only engage in small-scale lobbying activities can leave the Finnish Transparency Register by filling in a deregistration form in the service portal. Once the registrar has accepted the deregistration, the actor no longer has any obligations towards the Finnish Transparency Register.
The guidelines on the Finnish Transparency Register’s website will be updated in keeping with these more detailed instructions.
Disclosures to the Finnish Transparency Register must be made in Finnish or Swedish
In compliance with the Language Act (423/2003), all data must be recorded in the Finnish Transparency Register in Finnish or Swedish. Actors who have reported their data in English or some other language will be asked to translate the data into Finnish or Swedish.
If you have reported your data in some other language, you can also contact the registrar on your own initiative, in which case the registrar will open your disclosure of activities for editing. You can contact the registrar by email at avoimuusrekisteri@vtv.fi. By logging into the service portal, you can freely update the data provided in your registration.
Reporting template to support data collection
To facilitate the collection of the data that must be submitted to the Finnish Transparency Register, the NAOF provides a ready-made template in Excel format in which actors can collect the data concerning their lobbying activities. This tool, the use of which is voluntary, helps to collect the data in the correct format for the Finnish Transparency Register. The Excel file cannot be uploaded to the system as such, which is why the subjects must be entered in the Finnish Transparency Register manually using the service portal during the disclosure period.
Instructions for filling in the reporting template are provided on the table tab of the file.