Questions and answers

1. Is the Finnish Transparency Register a meeting journal?

No, the Transparency Register is not a meeting journal, i.e. each contact and its date are not reported separately to the Register.

Lobbying or lobbying consultancy directed at Parliament or a ministry is disclosed to the Register on the basis of the subject. This means that the following should be disclosed to the Register:

1. the subjects of lobbying

2. the persons contacted regarding the subjects

3. the methods of communication.

2. Is it possible to disclose lobbying activities to the Finnish Transparency Register at any time, as soon as they have been carried out?

No, disclosures of activities cannot be made at any time as soon as contacts take place.

Under the law, lobbying or lobbying consultancy targeted at Parliament or the ministries is disclosed to the Register twice a year. The lobbying activities carried out in January–June are disclosed to the Register in July–August. The lobbying activities carried out in July–December are disclosed to the Register in January–February.

3. What does small-scale lobbying mean?

Small-scale lobbying refers to activities where there are no more than five contacts with lobbying targets during a calendar year.

A contact is, for example, an individual telephone conversation, meeting or email message. An individual contact can have several different recipients in different organisations, but it is regarded as one contact.

However, contacts are not considered to refer to mass communication, such as newsletters or customer letters addressed to a large number of recipients, social media posts or other similar communication.

4. My company carries out small-scale lobbying. Should it register?

No, a company does not have to register if it has no more than five individual contacts with lobbying targets during a calendar year.

However, if the limit of five contacts is exceeded during the calendar year, the company must register with the Transparency Register.

5. Why has the limit for small-scale activities been set at five contacts?

The limit of five contacts allows individual contacts every few months or closer non-recurring communication consisting of several contacts.

The limit distinguishes between small-scale lobbying and large-scale recurring lobbying, which is monitored by means of the Transparency Register. Small-scale lobbying has been excluded from the scope of the law so that occasional small-scale lobbying does not cause an unreasonable administrative burden on organisations.

The purpose of the Transparency Register is to highlight significant and professional lobbying, such as the lobbying activities of large companies, large non-governmental organisations, labour market organisations and other organisations engaged in professional interest representation.

6. How should small-scale lobbying activities be reported to the Finnish Transparency Register?

An actor carrying out small-scale lobbying does not have to register with the Transparency Register.

However, if the lobbying activities have been small between January and June but the limit for small-scale lobbying (up to five contacts in a calendar year) is exceeded between July and December, the actor should register with the Transparency Register and disclose all the lobbying activities it carried out in the previous calendar year between January and February of the following year.

The scope of the organisation's lobbying activities can vary from year to year.

The organisation may have previously registered with the Transparency Register and disclosed its lobbying activities. However, in a certain year, its lobbying activities may remain small-scale, i.e. there are no more than five contacts during the calendar year.

If the lobbying activities have been small-scale between January and June, it is sufficient that it is indicated in the disclosure of activities to be submitted in July–August that the activities have been small-scale. However, please note that regardless of the volume of lobbying activities carried out between July and December, the activities of the entire calendar year must always be reported in the disclosure of activities to be submitted in January–February of the following year.

If the actor did not carry out any lobbying in either half-year (January–June or July–December), it should be reported during the relevant disclosure period (July–August or January–February) that no lobbying activities were carried out during the previous six-month period. However, please note that if small-scale lobbying activities have been carried out during the previous calendar year, this must nevertheless be reported in the disclosure to be submitted in January–February.

If the actor did not carry out any lobbying in either half-year (January–June or July–December), it should report during the relevant disclosure period (July–August or January–February) that no lobbying activities were carried out.

If the lobbying activities of the organisation remain permanently small-scale, the Register should be notified of this. A notification of permanent small-scale activities can only be submitted if the lobbying has remained small-scale during the current year.

If the lobbying activities of the organisation cease completely, this should also be notified to the Register.

7. Should financial information be provided on small-scale lobbying (no more than five contacts during the calendar year)?

An actor that carries out small-scale lobbying does not have to register with the Transparency Register or disclose financial information on its lobbying activities.

However, the scope of the organisation's lobbying activities can vary from year to year. The organisation may have previously registered with the Transparency Register and disclosed its lobbying activities. In this case, the organisation must continue to disclose financial information on its lobbying activities, even if its lobbying has remained small-scale.

Only if the organisation has carried out no lobbying or lobbying consultancy during the calendar year, it is no longer obliged to provide the financial information. If the organisation also notifies that its lobbying activities have ceased completely or remain permanently small-scale, it is no longer obliged to disclose any information to the Register.

The financial information is always disclosed for a whole calendar year. As the first disclosures of activities are submitted to the new Transparency Register on lobbying activities carried out starting from 1 April 2024, financial information is reported for the first time for the calendar year 2025 in summer 2026.

8. Are organisations receiving statutory government grants obliged to disclose their lobbying activities to the Transparency Register?

This depends on whether they carry out such long-term and systematic lobbying or lobbying consultancy targeted at Parliament or the ministries that is not part of their statutory duties. Government grants as such have no influence on whether the activities should be disclosed to the Transparency Register.

9. Do a parent company's registration and disclosures of activities also cover the activities of its subsidiaries?

No, they don't. Each legal person has independent obligations. Each subsidiary must register separately and report on its lobbying activities company-specifically.

If you are uncertain whether your organisation is obliged to disclose its activities to the Transparency Register, you can contact the National Audit Office of Finland.

10. Can a central association attend to the disclosure obligation on behalf of its member associations?

A central association's registration and disclosures of activities do not cover the activities its member associations. Each legal person has independent rights and obligations. Each member association should register separately and report on its lobbying activities association-specifically.

If you are uncertain whether your organisation is obliged to disclose its lobbying activities to the Transparency Register, you can contact the National Audit Office of Finland.

11. Are higher education institutions subject to the disclosure obligation?

Higher education institutions are not obliged to disclose their lobbying activities to the Transparency Register when carrying out tasks specifically laid down for them in the law. However, if a higher education institution instead of or in addition to this engages in lobbying or lobbying consultancy activities that are not part of its statutory tasks, it should disclose these activities to the Transparency Register.

Whether an activity falls outside the scope of statutory tasks must be assessed case by case. Therefore, even if an actor has statutory tasks, it may still have to disclose other activities it carries out to the Transparency Register.

12. 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 any exceptions to the registration and disclosure obligation for legal persons wholly or partly owned by cities or municipalities.

The matter must be assessed case by case if a city or municipality has established a legal person (e.g. a limited liability company) to perform its statutory task. Statutory tasks are not subject to the disclosure obligation.

If you are uncertain whether your organisation is obliged to disclose its activities to the Transparency Register, you can contact the National Audit Office of Finland.

13. If I contact a local and/or regional councillor who is also a Member of Parliament, do I become subject to the disclosure obligation?

This depends on the subject on which you contact them. The threshold for interpreting a Member of Parliament as a lobbying target is low. If necessary, you can get case-by-case guidance from the National Audit Office of Finland.

14. Is sales work or product development subject to the disclosure obligation?

There is no unambiguous answer to the question.

The sale or provision of services or goods to a public authority is regarded as normal communication that is not subject to the disclosure obligation. Nor is participation in a public procurement procedure subject to the disclosure obligation.

Under the law, lobbying refers to communicating with a lobbying target with a view to influencing the preparation and decision-making in a matter by promoting a specific interest or objective. In practice, such an interest or objective may also be related to business interests or to budget, procurement or corresponding activities.

Lobbying related to the budget and the use of appropriations should be disclosed to the Transparency Register.

If necessary, you can get case-by-case guidance from the National Audit Office of Finland.

15. We send an invitation to our company's celebration event by email with a large distribution list. The recipients also include lobbying targets. Is this regarded as lobbying?

Sending an invitation to an event is not, as such, regarded as lobbying.

If a lobbying target takes part in the celebration and lobbying is carried out there, this communication should be reported to the Transparency Register.

If discussions at the event later lead to such closer communication between the actor subject to the disclosure obligation and the lobbying target as can be considered lobbying, the communication should be reported to the Transparency Register.

16. How can lobbying be distinguished from private individuals’ activities in different situations, such as events, hobbies or sociable evenings?

As a rule, actors should themselves identify when they are carrying out lobbying and when they are acting as a private individual. Lobbying is long-term and systematic and carried out in the name of a legal person or a private entrepreneur. The activities to be reported to the Transparency Register do not include the activities of a private individual.

Matters falling within the scope of privacy protection are not disclosed to the Transparency Register. Therefore, discussions and getting acquainted with people at events that have not been organised to promote a specific objective or interest are usually not subject to the disclosure obligation.

However, if a discussion at an event leads to such closer communication between the actor subject to the disclosure obligation and the lobbying target as can be considered lobbying, the communication should be reported to the Transparency Register.

17. Are contacts between the parties of collective bargaining during the bargaining subject to the disclosure obligation?

No, contacts between the parties during collective bargaining are not subject to the disclosure obligation.

18. Does the form of employment relationship of the person engaged in lobbying play any role in the arising of the disclosure obligation?

No, the employment relationship or nature of the work of the person engaged in lobbying has no influence on the disclosure obligation. The disclosure obligation arises in the case of long-term and systematic lobbying or lobbying consultancy directed at Parliament or the ministries in the name of a legal person.

19. Are the activities carried out by persons in positions of trust subject to the disclosure obligation? What about those of volunteers?

Yes, a legal person is subject to the disclosure obligation if an individual it has appointed to a position of trust or its voluntary employee carries out long-term and systematic lobbying or lobbying consultancy targeted at Parliament or the ministries.

However, volunteer work by a private individual is not included in the activities to be reported to the Transparency Register.

20. An umbrella organisation consults its members in lobbying. Should such consultancy be reported to the Transparency Register?

No, consultancy provided by an umbrella organisation to its members is not included in the activities to be reported to the Transparency Register.

21. A foreign company contacts Finnish public officials. There are more than five contacts during the calendar year, but none after that. What measures should be taken?

The Finnish Transparency Register Act also applies to foreign legal persons in the case of long-term and systematic lobbying or lobbying consultancy directed at Parliament or the ministries.

If there are more than five contacts during a calendar year, the foreign company should register with the Finnish Transparency Register and disclose its lobbying activities to it. If the company later permanently ceases to carry out lobbying in Finland, the disclosure obligation ends. In such a case, the company should notify the Register of the end of its lobbying activities.

22. We post public content on social media for lobbying purposes. Should such lobbying be disclosed to the Transparency Register?

No, public lobbying targeted at everyone on social media is not included in the activities to be reported to the Transparency Register, even if lobbying targets are specifically tagged in the social media posts.

23. If a company providing lobbying consultancy draws up a lobbying plan for a client company but the client company does not implement it, what should be disclosed to the Transparency Register and who should submit the disclosure?

Drawing up a lobbying plan is considered lobbying consultancy regardless of whether the plan is implemented or not. The actor that drew up the lobbying plan, i.e. in this case the company that provided lobbying consultancy, should disclose the lobbying plan.

The provider of lobbying consultancy should identify when lobbying or lobbying consultancy is concerned, and how the activities are related to the pursuit of the client's interests in society. Under the law, the services disclosed to the Transparency Register do not have to be specifically lobbying or lobbying consultancy services ordered by the client. The service ordered can also be, for example, a communications or marketing service, internal development or legal advice.

The company that ordered the lobbying plan, in turn, is obliged to disclose to the Transparency Register any lobbying activities that it carries out itself.

24. Are volunteers and persons in positions of trust, for example, subject to the disclosure obligation?

The organisation should identify when the persons acting on behalf of it carry out lobbying that falls within the scope of the Transparency Register Act. Lobbying activities carried out on behalf of the organisation by persons in positions of trust fall within the scope of the Transparency Register.

Volunteering is usually a private individual's activity and therefore does not fall within the scope of the Transparency Register. However, volunteers may also participate in planned lobbying on behalf of the organisation, in which case their lobbying activities should also be disclosed to the Transparency Register.

25. If the organisation presents its activities at an event that is also attended by lobbying targets, should the eventbe reported to the Transparency Register?

As a rule, such events do not lead to disclosure obligation. The situation is different if the purpose of the event is to influence the preparation and decision-making in a matter.

26. If Parliament or a ministry organises an event to which an organisation is invited to present its activities, should the organisation report the event to the Transparency Register?

Presentation of activities as such is not considered lobbying under the Transparency Register Act. The situation is different if the organisation also takes the opportunity at the event to influence the preparation and decision-making in a matter.

27. If the organisation presents its activities at a public event, such as a trade fair, and a lobbying target happens to be in the audience, should the event be reported to the Transparency Register?

Presentation of the organisation's activities as such does not constitute lobbying regulated by law.

The situation described may include lobbying, but if it lacks the essential elements of lobbying regulated by the law, i.e. long-term and systematic nature and an attempt to influence thepreparation and decision-making in the matter, it is not considered lobbying regulated by the law.

28. If a parliamentary committee visits another country and asks a company for information on its operations in that country, should this communication be disclosed to the Transparency Register?

Answering such enquiries does not have to be disclosed to the Transparency Register. The situation is different if the organisation also takes the opportunity to influence the preparation and decision-making in a matter.

29. Should responding to an impact assessment be disclosed to the Transparency Register?

No, because such communication is organised and documented by the authorities.

30. If matters related to security of supply are discussed with public officials of ministries, should these discussions be reported to the Transparency Register or are they issues that should be kept secret?

In matters concerning security of supply, the Act on the Transparency Register should be complied with, i.e. if the activities are intended to influence the preparation and decision-making in the matter, they should be disclosed. However, the Transparency Register Act does not override the secrecy provisions that apply to matters related to security of supply and that the lobbyist and the lobbying target must comply with.

31. Should the organisation's memberships in foreign lobbying associations be disclosed in the registration?

Yes, the organisation's memberships in all lobbying associations should be disclosed to the Register. Such associations include mainly associations that are engaged in centralised lobbying activities and that often act as umbrella organisations. Knowledge of memberships in such organisations helps to understand the scale of the lobbying activities and the actors involved. 

32. How can I request or receive authorisations to act in the Transparency Register on behalf of my organisation? And who can submit disclosures to the Transparency Register on behalf of the organisation?

See our instructions on authorisations: Use of Suomi.fi authorisations in the Finnish Transparency Register.

An organisation can authorise as many persons as it wishes to use the Transparency Register. The Transparency Register can be used on behalf of the organisation by anyone authorised to do so by the organisation. Authorisations cannot be granted in the web service of the Transparency Register, but they are granted in the Suomi.fi service or applied for from the Digital and Population Data Services Agency.

33. A communications agency sells consultancy services related to lobbying to its client and, on behalf of the client, arranges such meetings with Parliament and the ministries in which the client participates. Who are obligated to report on their activities to the Finnish Transparency Register?

The communications agency must disclose the lobbying consultancy it has carried out. In this case, lobbying on behalf of a client is concerned. The client must also report the meetings in its disclosure of activities if it participates in the meetings.

Each legal person is obliged to report its own lobbying activities and/or lobbying consultancy.

34. A communications agency has a client that is a network consisting of several companies. The communications agency provides lobbying consultancy services to this network. How should the communications agency report this client relationship to the Finnish Transparency Register?

The communications agency must always report its lobbying consultancy activities to the Finnish Transparency Register and, in this connection, disclose its client. If the network is a legal person, the communications agency should disclose the network as its client. If the network is not a legal person but a non-registered association, for example, the communications agency should disclose all the companies in the network as its clients.

35. How should a network of companies report on its lobbying activities to the Finnish Transparency Register?

If the network is a legal person, the network must register with the Finnish Transparency Register and report on its lobbying activities. In this case, the companies belonging to the network do not need to report separately on the lobbying activities carried out by the network. However, the companies are still obliged to report on their other lobbying activities.

If the network is not a legal person, such as a registered association, the reporting obligation lies with the legal persons that are part of it. In this case, the companies that belong to the network and carry out lobbying should report the lobbying activities as part of their own lobbying activities. If a company wishes to mention the network in the Transparency Register, it can add the name of the network to the subject field in the disclosure of activities.

36. A network or an umbrella organisation organises a lobbying event. Are all participants subject to the disclosure obligation?

The event organiser must report the event to the Finnish Transparency Register. The disclosure obligation of the participants depends on whether they carry out lobbying at the event.

Mere participation in the event is not regarded as lobbying and does not lead to a disclosure obligation. However, if the participant carries out lobbying targeted at ministries or Parliament at the event, this must be reported to the Transparency Register.

37. If a lobbying target, such as an MP, is a member of the board of our organisation, do board meetings and matters related to them fall within the scope of the disclosure obligation?

An association's board meetings are regarded as its internal activities and do not fall within the scope of the disclosure obligation, even if there are lobbying targets among the board members.

An MP (or another lobbying target) is a board member and responsible for the association's activities in the same way as the other board members. As a board member, an MP (or another lobbying target as referred to in the Transparency Register Act) is therefore not a lobbying target as referred to in the Transparency Register Act.

38. Do I have to report my lobbying activities if I am involved in politics?

It is essential to identify in what role you act, i.e. whether you act as a private person or as a representative of an organisation.

Lobbying activities carried out on behalf of an organisation must be reported to the Transparency Register as required by the law.

The political activities of private individuals or contacts between a political party or an affiliated entity with lobbying targets are not disclosed to the Transparency Register. However, acting in politics does not remove the disclosure obligation if the same person carries out lobbying activities as a representative of an organisation.

39. I contact a lobbying target in order to carry out lobbying. However, my lobbying is expected to remain small-scale (less than five contacts per calendar year), but I cannot be sure of that. When should I register?

Small-scale actors must monitor their lobbying activities and register when their lobbying is no longer small-scale.

Small-scale actors can also register even if their activities remain small-scale. However, in this case, the organisation is obliged to report its lobbying activities even if they are small-scale.

40. We are a member of a lobbying organisation. Are we automatically subject to the disclosure obligation or only if we carry out lobbying?

An organisation must report to the Finnish Transparency Register if it carries out lobbying, i.e. contacts a ministry or Parliament with the aim of influencing the preparation or decision-making in a matter.

Membership in a lobbying organisation does not lead to disclosure obligation if the organisation itself does not contact decision-makers, i.e. does not itself carry out lobbying.

41. If I lobby Finland's Permanent Representation to the EU in a country, should I report this to the Finnish Transparency Register?

Lobbying of embassies is not reported to the Finnish Transparency Register.

42. In order to report our lobbying activities to the Finnish Transparency Register, we must keep our own internal personal data file. Does the NAOF provide instructions for keeping a personal data file?

Instructions on keeping a personal data file and on data protection are provided by the Office of the Data Protection Ombudsman.

43. We participate in a round-table discussion convened by a ministry. Should we report this to the Finnish Transparency Register?

Under the Finnish Transparency Register Act (section 4, subsection 1, paragraph 4), it is not necessary to report participation in working groups set up by the authorities or regulated by law or in advisory boards, other bodies or hearings where the participation is documented. The essential question is whether the round-table discussion has been documented by the authorities. The documentation – and particularly the documentation of hearings – also includes documenting the persons and actors that participated in the event. If the round-table discussion is not documented, it must be reported to the Finnish Transparency Register. In general, round-table discussions seem to be informal events falling within the scope of the disclosure obligation.

44. We meet a decision-maker many times and discuss a subject of lobbying. Should we report every meeting separately?

No, the Finnish Transparency Register is not a meeting journal, i.e. each contact and its date are not reported separately to it.

Lobbying activities are disclosed to the Transparency Register by subject. For each subject, you should disclose the lobbying targets that you have lobbied in relation to the subject. If you have met the decision-maker and discussed only one subject, it is sufficient that the subject is disclosed once. You do not need to disclose for each subject or lobbying target when and how many times you have met the lobbying target in question.

45. We meet a Member of Parliament and discuss several different subjects during the meeting. Should the subjects of the meeting be reported as a whole, or should each subject be reported separately?

All the subjects on which lobbying has been carried out are disclosed to the Finnish Transparency Register. You should therefore disclose all the subjects of the meeting separately and add the lobbying target in question to each subject. For each subject, you should also disclose other lobbying targets you have contacted for lobbying on the same subject.

46. What is considered one contact?

A lobbying-related telephone conversation, meeting or email, for example, is considered one contact. A contact may be directed to one or more lobbying targets.

For example, an email message with multiple lobbying targets as recipients is considered one contact. A meeting with several lobbying targets is also considered one contact if everyone is present and participates in the discussion at the same time.

However, if an email sent for lobbying purposes has been sent separately to different recipients, multiple contacts are concerned, even if the emails had the same content or if they had been sent within the same day.

The number of contacts is counted only when it is assessed whether the limit for small-scale lobbying is exceeded. If there are more than five contacts per year, the actor is obliged to disclose all of its lobbying activities. In this case, all contacts are not disclosed to the Transparency Register, but the lobbying activities are disclosed by subject.

47. I send a meeting invitation to several lobbying targets, but only one attends the meeting. Should the lobbying targets that did not respond to the message or attend the meeting be specified in the disclosure?

Sending an invitation to a lobbying target may be lobbying if you, for example, already try to influence the preparation and decision-making of a matter by the content of the email invitation by promoting a particular interest or objective.

In that case, you should disclose all the lobbying targets to whom you have sent the invitation, regardless of whether they respond or attend the meeting.

48. Should a registered actor file a disclosure of activities if its lobbying has remained small-scale or if it has not carried out any lobbying activities?

Yes, all registered actors must file a disclosure of activities every six months. If the lobbying carried out by your organisation has been of small scale during the first part of the year, it is sufficient to indicate in the disclosure of activities submitted in July–August that the organisation has had “Up to five contacts” for lobbying purposes. If your organisation has not carried out any lobbying activities, you should indicate that the organisation has had “No contacts”.

However, the lobbying activities carried out during the entire calendar year must always be reported in the disclosure of activities submitted in January–February of the following year.

If you estimate that your lobbying will remain small-scale in the future as well, you can submit a deregistration.