Information on lobbying is to be collected as from 1 April — this is how you should prepare

Long-term and systematic lobbying or lobbying consultancy that targets Parliament or the ministries must in future be disclosed to the Finnish Transparency Register. This is done by filling in a disclosure of activities in the Transparency Register every six months.

2024 is the first year that the Transparency Register Act is in force, and therefore, instead of six months, the first disclosure of activities will exceptionally be submitted for only three months: April to June.

Lobbying activities carried out from April to June 2024 will be reported to the Transparency Register between 1 July and 31 August 2024 by submitting a disclosure of activities.

The period from January to March has this year been exceptionally reserved for submitting registrations so that all actors currently engaged in lobbying have registered with the Transparency Register before submitting the disclosure of activities.

What information on lobbying is to be entered in the disclosure of activities?

Lobbying activities are reported to the Transparency Register based on subjects: the subjects on which lobbying has been carried out are entered in the disclosure of activities.

In other words, unlike in a meeting journal, each contact that the organisation makes and that includes lobbying is not reported to the Register, and it does not appear from the Register whether lobbying activities related to a subject have been carried out once or, for example, 100 times.

The subjects of lobbying are entered in the disclosure one by one. If the subject of lobbying is an official Government project, the subject of lobbying is the project number. Otherwise, the discloser enters the subject (50–600 characters).

The subject of lobbying should be indicated as accurately as possible, for example at the level of an individual policy, legislative, budgetary or development measure or at project level. The information is provided in the disclosure of activities notwithstanding trade secrets.

Each subject is accompanied by information on which actors falling within the scope of the Act have been contacted in relation to the subject and by what method.

The lobbying targets, i.e. information on the persons lobbied, are provided in the system in a table maintained by the NAOF. The correct targets are filtered and selected in the table. The main method of communication is also selected for the targets. Different methods are provided in the system as checkboxes. The discloser can also enter the method of communication themselves if there is no suitable option.

The disclosure of activities is complete when all subjects of lobbying including the lobbying targets and the methods of communication have been disclosed and the information has been published. The disclosure can also be edited after its publication as long as the disclosure period is open.

In its own activities, the actor subject to the disclosure obligation must also comply with its obligations under the EU General Data Protection Regulation. The actor is independently responsible for complying with these obligations.

What information on lobbying consultancy is to be entered in the disclosure of activities?

In addition to their own lobbying, actors engaged in lobbying consultancy should also disclose:

• lobbying carried out on behalf of a client

• lobbying consultancy and

• their own public relations activities outside a client relationship.

Lobbying carried out on behalf of a client is otherwise reported as described above, but the basic details of the client that has obtained consultancy must also be provided. If the client has a Finnish business ID, the basic details of the client are retrieved from the Business Information System (YTJ) with the business ID. If necessary, the information can be supplemented manually.

In the case of lobbying consultancy, the client's basic details and the subjects of consultancy are disclosed. It is also described in the disclosure how the consultancy is related to the client's lobbying (“Type of support”). The support provided may include, for example, drawing up an influencing plan for a client on a specific subject.

Public relations activities outside a client relationship are disclosed to the Register if the purpose of the communication is to establish such contacts with lobbying targets that benefit the carrying out of lobbying consultancy or to exchange information with lobbying targets. In this case, the subject as well as the lobbying targets and the methods of communication are disclosed.

The disclosure of activities is complete when all subjects of lobbying including the lobbying targets and the methods of communication have been disclosed and the information has been published. The disclosure can also be edited after its publication as long as the disclosure period is open.

In its own activities, the actor subject to the disclosure obligation must also comply with its obligations under the EU General Data Protection Regulation. The actor is independently responsible for complying with these obligations.

What does the disclosure of activities look like?

Disclosures of activities will be submitted for the first time as from 1 July 2024. The system is being built and developed further, but the pictures below show what the form looks like at the moment. We reserve the right to make changes.

Text continues after pictures.

How can my organisation prepare for submitting a disclosure of activities?

Information on lobbying and lobbying consultancy should be stored in the organisation's own systems so that it will be as easy as possible to transfer the information to the Transparency Register.

Organisations must collect and maintain information on their own lobbying activities starting from 1 April 2024. The information will be entered in the Transparency Register for the first time during the summer disclosure period, i.e. from 1 July to 31 August 2024. In the future, the information will be disclosed to the Register every six months.

As the Transparency Register is based on subjects, organisations should pay attention to the planning of subjects. Everyone who works with lobbying should be familiar with the subjects on which the organisation carries out lobbying or lobbying consultancy. The reporting will be easier once the subjects have been jointly agreed.

The maintenance of information on lobbying activities can be simplified if everyone who carries out lobbying can update the organisation's common system for their part. The descriptions of subjects should be updated on a cycle suitable for the organisation, e.g. once a month.

So far, the disclosures of activities must be made manually in the service portal of the Transparency Register, but the National Audit Office is developing a solution for more efficient transfer of data. We will inform you of this later.