Questions and answers
Is the Finnish Transparency Register a meeting journal?
The Transparency Register is not a meeting journal, but contacts are specified in the Register according to the subject of lobbying. This means that the lobbyist should disclose:
the subject of lobbying
the persons contacted regarding the subject, and
the methods of communication.
The numbers or dates of contacts are not reported to the Transparency Register.
Is it possible to disclose lobbying activities to the Finnish Transparency Register at any time, as soon as they have been carried out?
No, it is not. The law provides for two disclosure periods: January–February and July–August.
What does small-scale lobbying mean?
Small-scale lobbying, lobbying consultancy or PR activities refer to activities where there are no more than five contacts with lobbying targets during a calendar year.
An individual contact may be directed to one or more lobbying targets. In practice, the contacts may either be directed five times at the same targets or be divided between different targets. The key point is that there are no more than five contact times in total.
A contact is, for example, an individual lobbying-related telephone conversation, meeting or email time. However, contacts are not considered to include mass communication, newsletters or customer letters addressed to a large number of recipients or other similar communication.
An individual contact may have several different targets in different organisations. A contact can be, for example, an email that is sent to several lobbying targets or a meeting that is attended by several lobbying targets. Such a case is thus regarded as a single contact instead of multiple contacts.
My company carries out small-scale lobbying. Does it have to register?
There is no need to register, because the Finnish Transparency Register Act does not apply to small-scale lobbying.
Small-scale lobbying refers to lobbying activities where the communication during a calendar year includes no more than five individual contacts in total with one or more lobbying targets.
As soon as the limit of five contacts is exceeded, the actor must register with the Transparency Register.
Why has the limit for small-scale activities been set at five contact times?
The limit of five contact times allows individual contacts every few months or closer non-recurring communication consisting of several contacts. In practice, the limit distinguishes small-scale lobbying from large-scale, recurring lobbying activities, which are monitored by means of the Finnish Transparency Register.
Small-scale lobbying has been excluded from the scope of the Act to ensure that occasional small-scale lobbying does not cause an unreasonable administrative burden or administrative sanctions.
The Transparency Register focuses on increasing the transparency of significant and professional lobbying. In practice, the lobbying activities of large companies, large non-governmental organisations, labour market organisations and other organisations engaged in professional lobbying are more likely to exceed the threshold set for the disclosure obligation than the activities carried out by small companies, small non-governmental organisations or private entrepreneurs.
How should small-scale lobbying activities be reported to the Finnish Transparency Register?
If the lobbying activities of the entire calendar year have been of small scale, i.e. the number of contacts has not exceeded five, it should be stated in both the summer and winter disclosures of activities that the activities have been of small scale.
If the lobbying activities were of small scale in the first reporting period of the year (January–June), it should be reported in the online service during the summer disclosure period that the lobbying activities during the spring were of small scale.
If the limit for small-scale activities (no more than five contact times) is exceeded during the autumn reporting period (July–December), the activities of the entire previous year, including any contacts made during the spring, should be disclosed in the winter disclosure period.
If there were no lobbying activities in one of the reporting periods (January–June or July–December), it should be disclosed in the online service during the relevant disclosure period (July–August or January–February) that no lobbying activities were carried out.
Financial information on even small-scale activities should be disclosed annually during the summer disclosure period. Financial information should be provided for the first time in summer 2026.
The registration authority, i.e. the National Audit Office of Finland, should be notified if the activities become permanently small-scale. A permanent change requires that the registered discloser notices that its lobbying activities have remained small-scale and assesses that they will continue to be of small scale.
Should financial information be provided on small-scale lobbying (no more than five contacts during the calendar year)?
Yes, it should. Provision of financial information during the summer disclosure period can be avoided only if no lobbying, lobbying consultancy or lobbying-related PR activities have been carried out during either reporting period of the calendar year.
Financial information should be provided for the first time in summer 2026.
Are organisations receiving statutory government grants subject to the disclosure obligation?
As a rule, a legal person or a private entrepreneur carrying out lobbying or lobbying consultancy at central government level is subject to the disclosure obligation. Carrying out statutory tasks does not trigger the disclosure obligation, but activities outside the statutory tasks fall within the scope of the Finnish Transparency Register Act.
Do a parent company's registration and disclosures of activities also cover its subsidiaries?
A parent company's registration and disclosures of activities do not cover the activities of its subsidiaries. Each official legal person has independent rights and obligations. Each subsidiary should register separately and report on its lobbying activities company-specifically.
However, case-by-case assessment is sometimes necessary. If the actor is uncertain as to whether it is subject to the disclosure obligation, it may contact the National Audit Office.
Can a central association perform the disclosure obligation on behalf of its member associations?
The central association's registration and disclosures of activities do not cover the activities its member associations. Each official legal person has independent rights and obligations. Each member association should register separately and report on its lobbying activities association-specifically.
However, case-by-case assessment is sometimes necessary. If the actor is uncertain as to whether it is subject to the disclosure obligation, it may contact the National Audit Office.
Are higher education institutions subject to the disclosure obligation?
Higher education institutions are not subject to the disclosure obligation when carrying out their tasks specifically laid down in the law.
Whether an activity falls outside the scope of statutory duties requires a case-by-case assessment. A statutory task does not provide justification for not registering an actor in the Register. In the assessment, it is important to pay attention to distinguishing between the performance of statutory tasks and communication related to lobbying.
Lobbying or lobbying consulting carried out outside statutory tasks falls within the scope of the disclosure obligation if it meets the definition of lobbying.
Researchers often make contacts as university researchers through the university, and this kind of communication is comparable to lobbying by private individuals. The activities of private individuals fall outside the scope of the disclosure obligation.
Is a legal person (e.g. a limited liability company) wholly or partly owned by a city subject to the disclosure obligation?
As a rule, yes. The law does not provide an exception to the registration and disclosure obligation for legal persons wholly or partly owned by cities or municipalities.
A situation-specific assessment is required if a city or municipality has established a legal person (e.g. a limited liability company) to perform its statutory task. This is because statutory tasks do not fall within the scope of the disclosure obligation. If the actor is uncertain as to whether it is subject to the disclosure obligation, it may contact the National Audit Office.
If I contact a local and/or regional councillor who is also a Member of Parliament, do I become subject to the disclosure obligation?
The obligation to disclose activities to the Transparency Register applies to lobbying targeted at decision-making in Parliament or a ministry.
Exceptions to this include situations referred to in section 4 of the Finnish Transparency Register Act, such as local council meetings where a Member of Parliament would have a dual role as both a local councillor and a Member of Parliament.
The exact answer depends on the context in which the lobbying is carried out. If necessary, the National Audit Office provides case-by-case guidance. In any case, the threshold for interpreting a Member of Parliament as a lobbying target is low.
Is sales work or product development subject to the disclosure obligation?
There is no fully unambiguous answer to the question. The exact answer depends on the context in which the lobbying is carried out.
The sale or provision of services or goods to a public authority is regarded as normal communication that does not give rise to the disclosure obligation. Similarly, participation in a public procurement procedure is not subject to the disclosure obligation.
Lobbying related to the budget and the use of appropriations should be disclosed.
Under the law, lobbying refers to communicating with the lobbying target with a view to influencing the preparation and decision-making of a matter by promoting a specific interest or objective. In practice, such an interest or objective may also be related to business interests, the budget, procurement or corresponding activities.
If necessary, the National Audit Office provides case-by-case guidance.