Disclosing financial information

Financial information is provided retrospectively for the previous calendar year during the July–August disclosure period. As the information always applies to a whole calendar year, disclosing the information requires that the actor subject to the disclosure obligation (i.e. the discloser) has been registered with the Finnish Transparency Register for at least one calendar year.

Financial information provides further information on the financial resources that organisations use to influence Parliament and the ministries. Only lobbying or lobbying consultancy that falls within the scope of the Finnish Transparency Register Act is disclosed in the financial information. In practice, financial information is therefore disclosed on the activities that the discloser has reported in the disclosures of activities. If the lobbying activities of a registered organisation have been small-scale during the previous calendar year, financial information on them must be disclosed in any case, although the subjects of lobbying are not disclosed in the disclosures of activities.

Financial information on lobbying and lobbying consultancy is disclosed notwithstanding trade secrets. Financial information is also disclosed in connection with deregistration if it has not yet been disclosed for the previous calendar year.

Financial information is not disclosed if the discloser, during the previous calendar year, has not carried out any lobbying or lobbying consultancy or made contacts with lobbying targets outside a client relationship as referred to in the Finnish Transparency Register Act. These guidelines are based on the Finnish Transparency Register Act (430/2023) and the implementing regulation issued by the National Audit Office on the compilation of financial information. The regulation entered into force on 13 December 2024. The regulation and the explanatory memorandum on the regulation are available in Finnish here.

Financial information is to be disclosed to the Finnish Transparency Register for the first time in July–August 2026. The information concerns lobbying or lobbying consultancy carried out during the calendar year 2025. In future, financial information is disclosed annually.

Financial information to be disclosed on lobbying

Financial information is disclosed on lobbying if the actor subject to the disclosure obligation has carried out lobbying as referred to in the Finnish Transparency Register Act during the previous calendar year. Financial information on lobbying activities includes

• the total number of persons involved in lobbying during the previous calendar year and the number of person-years they spent on lobbying

• the costs of outsourced lobbying consultancy in euros, and

• the marketing and representation costs related to lobbying.

Total number of persons involved in lobbying

The total number of persons involved in lobbying refers to the persons who participated in the discloser's lobbying activities during the previous calendar year and who received a salary or other financial benefit for the work in question.

The discloser's lobbying activities refer to the lobbying activities that the discloser carried out during the previous calendar year and on which the discloser has submitted a disclosure of activities.

The persons involved in lobbying refer to the persons who participated in actual contacts with lobbying targets. These persons include not only the discloser's employees but also, for example, elected officials if they have received a salary or other financial benefit for the work in question.

In the disclosure of activities, the discloser must disclose the total number of the persons involved in lobbying. If no persons who received a salary or other financial benefit were involved in the discloser's lobbying activities during the previous calendar year, this must be reported in the disclosure of activities.

Person-years spent on lobbying

The person-years spent on lobbying refer to the total labour input that the persons included in the total number of persons involved in lobbying spent on the discloser's lobbying activities.

The person-years that these persons spent on lobbying activities is reported in the disclosure of activities in aggregate according to the following ranges:

• less than 1 person-year

• 1–2.9 person-years

• 3–4.9 person-years

• 5–10 person-years or

• more than 10 person-years.

Person-year refers to the labour input one person has spent on lobbying in relation to the labour input of a full-time employee during a calendar year. The maximum number of person-years that one person can spend on lobbying is one, which would mean that the person carries out lobbying on a full-time basis.

The labour input spent on lobbying refers to any work that is related to the discloser's lobbying as referred to in the Finnish Transparency Register Act, such as all tasks and measures in connection with communications with lobbying targets.

The discloser estimates, to the best of its knowledge, the labour input of each person involved in lobbying in relation to the labour input of a full-time employee during a calendar year.

Example 1: During the previous calendar year, the discloser had five full-time employees, and they were all involved in the discloser's lobbying activities. During the calendar year, each of these employees spent 30% of their labour input on lobbying. The person-years spent by the discloser on lobbying would therefore be calculated as follows: 0.3+0.3+0.3+0.3+0.3 = 1.5 person-years. In its disclosure of activities, the discloser selects the following range: 1–2.9 person-years.

Example 2: During the previous calendar year, the discloser had one full-time employee and an elected official, and they were both involved in the discloser's lobbying activities. During the calendar year, the full-time employee spent 80% of their labour input on lobbying. The elected official, who received a remuneration for their work, carried out lobbying-related tasks occasionally during the previous calendar year, and the labour input the election official spent on these activities corresponds to 5% of the labour input of a full-time employee during a calendar year. The total person-years spent by the discloser on lobbying would therefore be calculated as follows: 0.8+0.05=0.85 person-year. In the disclosure of activities, the discloser selects the following range: less than 1 person-year.

The costs of outsourced lobbying consultancy in euros

The disclosers that have acquired outsourced lobbying consultancy in the previous calendar year disclose the costs of the outsourced services in euros. The costs must be disclosed only for outsourced consultancy related to the discloser's lobbying in the previous calendar year.

Lobbying consultancy refers to professional lobbying carried out on behalf of a client or providing support to a client in lobbying. Lobbying consultancy can be, for example, planning of lobbying, communications or activities, charting the client's stakeholders, using the consultancy provider's competence and contacts or other consultancy related to the organisation's lobbying.

Outsourced lobbying consultancy does not refer only to services designated as lobbying or lobbying consultancy. Outsourced services whose costs must be disclosed can also be, for example, communications and marketing services, internal development or legal advice if these services are related to the discloser's lobbying. In the disclosure of activities, the information is disclosed in euros.

Marketing and representation costs related to lobbying

The lobbying-related marketing and representation costs incurred during the previous calendar year are disclosed in the disclosure of activities. Marketing and representation costs are disclosed separately.

These costs refer to costs related to marketing and representation in connection with the lobbying carried out by the discloser during the previous year. What is essential is that the costs are caused by lobbying directed at lobbying targets referred to in the Act.

Lobbying-related marketing and representation costs may arise in situations where only part of the total costs is directed at the lobbying targets referred to in the Finnish Transparency Register Act. Such situations include, for example, events organised by the discloser where the participants also include other persons than lobbying targets, or targeted marketing campaigns that are also directed at other actors than lobbying targets. In this case, the discloser should, to the best of their knowledge, estimate the share of the total costs related to the discloser's lobbying. If, for example, half of the guests at a lobbying-related event are lobbying targets referred to in the law, the discloser can estimate that 50% of the total costs of the event are representation costs referred to in the Transparency Register Act.

Lobbying-related marketing and representation costs are disclosed separately in the disclosure of activities according to the following ranges:

• less than EUR 1,000

• EUR 1,000 – 4,999

• EUR 5,000 – 9,999

• EUR 10,000 – 24,999

• EUR 25,000 – 49,999

• EUR 50,000 – 99,999

• EUR 100,000 – 199,999

• EUR 200,000 – 299,999

• EUR 300,000 – 399,999

• EUR 400,000 – 500,000

• more than EUR 500,000.

Lobbying-related marketing costs

Lobbying-related marketing costs refer to the acquisition costs of marketing materials and services used in the discloser's lobbying. Marketing materials refer, for example, to such materials for a marketing campaign directed at lobbying targets that are used in the communication with the lobbying targets.

Lobbying-related marketing costs include, for example:

• The costs of advertising and communication campaigns, such as the planning and production of advertising materials, and communications campaigns outside lobbying consultancy agreements.

• Costs related to events and trade fairs, such as participation fees, venue rentals, exhibition stands, brochures and other event materials.

• Direct marketing directed at lobbying targets, such as email campaigns and other marketing.

• Purchasing of marketing services, such as services from advertising agencies and other consultancy related to content production, when directed at lobbying targets.

• Sponsor agreements and cooperation.

The above examples of marketing costs do not comprise an exhaustive list but are indicative examples of possible lobbying-related marketing costs. Such costs are lobbying-related costs only if they are related to the discloser's lobbying activities directed at the lobbying targets referred to in the law.

Lobbying-related representation costs

Lobbying-related representation costs include the costs caused by discloser's lobbying-related hospitality or other courtesies directed at lobbying targets. Lobbying-related representation aims at promoting the discloser's objectives and interests by, for example, creating new relationships with lobbying targets or maintaining existing ones. Representation costs include all costs incurred in representation for lobbying purposes.

Lobbying-related representation costs include, for example:

• The costs of catering and meals, such as business lunches and dinners or coffee served at meetings.

• The costs of events, such as the costs of organising parties or seminars (e.g. venue rentals, catering services, performer or speaker fees).

• Gifts or tokens of appreciation to lobbying targets (e.g. event tickets, gifts in kind, gift cards)

• Lobbying-related business trips and associated travel and accommodation costs

• Other lobbying-related representation costs

The above examples of representation costs do not comprise an exhaustive list but are indicative examples of possible lobbying-related representation costs. Such costs are lobbying-related costs only if they are related to the discloser's lobbying activities directed at lobbying targets referred to in the law.

Financial information to be disclosed on lobbying consultancy

Financial information on lobbying consultancy is disclosed if the organisation has carried out lobbying consultancy during the previous calendar year. Financial information is disclosed only on lobbying consultancy that falls within the scope of the Transparency Register Act.

The financial information disclosed on lobbying consultancy is the turnover (in euros) from lobbying consultancy carried out in the previous calendar year.

The turnover (in euros) from lobbying consultancy refers to the turnover that the discloser has received from lobbying consultancy falling within the scope of the Finnish Transparency Register Act and that the discloser has reported in a disclosure of activities. The discloser must therefore distinguish between the turnover from lobbying consultancy and the turnover from its other activities.

If the organisation has carried out lobbying in addition to lobbying consultancy, it must also disclose financial information on its lobbying.