Which activities should be disclosed

Lobbying, i.e. influencing activities, means contacts aiming to promote a specific interest or objective directly or indirectly by influencing the preparation and decision-making related to a matter. This interest or objective is often political or commercial or relevant to some other societal matter, and it is promoted by influencing the content of, for example, a regulatory, budgetary, procurement, development or policy measure, or the initiation or termination of a measure.

Lobbying consultancy, i.e. advisory services provided as a business, must also be disclosed to the Finnish Transparency Register. The consultant may either engage in direct lobbying on behalf of a client or provide advice and support for a client’s lobbying activities.

Contacts with lobbying targets without a client relationship (public relations activities) must also be reported if their purpose is to establish contacts or exchange information which are useful in lobbying consultancy.

Lobbying that targets Parliament and the ministries

Any long-term and systematic lobbying and lobbying consultancy that target Parliament or the ministries must be reported to the Finnish Transparency Register.

Lobbying targets Parliament or a ministry if it is directed at:

• a Member of Parliament

• a parliamentary assistant

• a staff member of parliamentary groups

• a minister

• a special adviser to a minister

• a State Secretary appointed for a minister's term of office

• a public official of the Parliamentary Office

• a public official of a ministry, or

• a rapporteur appointed by a ministry.

The lobbying target is named in the Transparency Register when the target is:

• a Member of Parliament

• a minister

• a special adviser to a minister

• a State Secretary appointed for a minister's term of office

• Secretary General or Deputy Secretary General of Parliament

• a Permanent Secretary or head of department of a ministry, or

• a rapporteur appointed by a ministry.

For other public officials, their organisation, unit and department should be disclosed to the Transparency Register. In case of political assistants, the disclosure should indicate the parliamentary group they represent.

The Finnish Transparency Register’s online service provides a list of lobbying targets, which is maintained by the National Audit Office and updated twice a year. However, there is no centralised information collection on government agencies’ rapporteurs, which is why they must be named separately in the Transparency Register.

Long-term and systematic lobbying

Networking and long-term relationships with policy-makers are essential for the success of lobbying. Lobbying or influencing activities often begin before the official decision-making process or project starts and take place through both official and informal channels.

Lobbying activities that involve more than five individual contacts with the subject during a calendar year must be reported to the Finnish Transparency Register. This also includes contacts made before an official project or working group is set up.

Contact methods

Lobbying is about making contacts to influence the preparation and decision-making related to a matter by promoting a certain interest or objective.

Parliament and the ministries are influenced by contacting them in different ways. Different contact methods include:

• face-to-face meetings

• online meetings

• telephone calls

• e-mails

• text messages

• messaging, for example on social media channels

• other contact methods.

Regardless of what contact method is used or who initiated the contact, lobbying must be reported to the Finnish Transparency Register if it targets Parliament or a ministry and is long-term and systematic.

Lobbyists or lobbying consultants are obliged to submit disclosures to the Transparency Register themselves. This obligation does not apply to lobbying targets.