Which activities should be disclosed

Lobbying refers to contacts aiming to promote a specific interest or objective directly or indirectly by influencing the preparation and decision-making concerning it. This interest or objective is often a political, business-related or other societal issue, and it is promoted by influencing the content of a regulatory, budgetary, procurement, development or policy measure, for example, or the initiation or termination of a measure. Preparation and decision-making are interpreted in a broad sense: for example, lobbying at an early stage, when an official project has not necessarily been launched or a working group has not necessarily been set up, falls within the scope of the disclosure obligation.

Lobbying-related consultancy (advisory services) provided as a business must also be disclosed to the 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 made with lobbying targets outside a client relationship (public relations activities) must also be reported if their purpose is to establish contacts or exchange information that are useful in lobbying consultancy.

Parliament and the ministries as lobbying targets

All lobbying or lobbying consultancy that targets Parliament or the ministries must be reported to the Finnish Transparency Register.

Lobbying is targeted at Parliament or the ministries if it targets a Member of Parliament, a parliamentary assistant, a member of the staff of parliamentary groups, a minister, a minister's special adviser, 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.

Read more about lobbying targets.

Long-term and systematic lobbying

The purpose of the Finnish Transparency Register is to provide information on all lobbying related to decision-making, regardless of the content, processing stage or form of the matter. However, what is more important than an individual contact made for lobbying purposes is that the lobbying is long-term and systematic.

Networking and creating long-term relationships with policy-makers are essential for successful lobbying. Lobbying, or influencing, often begins before the official decision-making process or project starts and takes place through both official and informal channels.

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

An organisation does not have to register with the Finnish Transparency Register if it does not engage in lobbying or if its lobbying activities are small-scale. Small-scale lobbying activities refer to lobbying activities where the communications during a calendar year include no more than five individual contacts in total with one or more lobbying targets.

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 the method of communication and who initiated the communication, lobbying must be reported to the Finnish Transparency Register if it targets Parliament or the ministries. The lobbying does not have to be reciprocal.

It is always the actors engaged in lobbying or lobbying consultancy that are subject to the disclosure obligation. The Finnish Transparency Register does not create obligations on or require measures from lobbying targets.

Disclosing the subject of lobbying

Lobbying and lobbying consultancy activities are reported to the Finnish Transparency Register according to the subject of lobbying. All subjects on which lobbying has been carried out are disclosed to the Register. The subject may be related to, for example, a policy or legislative project or a budgetary or development measure in any administrative sector. The subject should be disclosed as descriptively as possible and in sufficient detail.

The subject is disclosed in a free format, and the number of characters in the disclosure is limited (50–600 characters). The subject of lobbying should be described briefly and clearly. However, the description should state as accurately as possible the project, legislation, budget or other similar matter that was targeted by the lobbying. You can find examples of good descriptions on the Government's Hankeikkuna website, which is the ministries' project management service. If the lobbying has been targeted at an official project, you can refer directly to it using the project number on the Hankeikkuna website. The subject must be reported in Finnish or Swedish.

The purpose of the subject is to open up lobbying activities carried out by the discloser to the public. With the help of information obtained from the Register, those interested in the subject may contact the actors involved in order to obtain further information. All persons lobbied on the same subject and all methods of communication are disclosed in the same disclosure. It is not disclosed for each subject when and how many times the lobbying targets have been met.

The subject should also be disclosed in cases where you support a client's lobbying activities but are not yourself in direct contact with Parliament or the ministries. In this case, it should be stated in the description of the subject of lobbying how this consultancy has been related to your client's lobbying activities. An example of this is an influencing plan drawn up for the client with the aim of promoting certain matters in Parliament or in the ministries.

Which activities are not disclosed

Not all lobbying activities have to be disclosed to the Finnish Transparency Register. The obligation to disclose activities to the Transparency Register depends on whether the activities aim to promote a particular interest or objective by influencing the preparation or decision-making of Parliament or the ministries.

Situations not disclosed to the Transparency Register:

• Small-scale lobbying activities.

  Small-scale lobbying activities refer to communication that includes no more than five individual contacts with lobbying targets during a calendar year. A contact is, for example, a telephone conversation or an email message. An individual contact may be directed to more than one recipient. For example, an email sent to multiple recipients is considered one contact.

• Ordinary dealings with government agencies.

  Ordinary dealings with government agencies include, for example, taking care of various permit or benefit matters, participation in procurement or an agency's guidance and advice activities. As a rule, enquiries of technical and neutral nature can be regarded as ordinary dealings. On the other hand, ordinary dealings are not considered to refer, for example, to a situation where an actor subject to the disclosure obligation contacts the authorities and provides its views or information produced by it to support the decision-making and preparation in a matter.

• Performing statutory obligations.

  If lobbying or lobbying consultancy is a statutory task specifically laid down for the organisation in the law, the organisation does not have to disclose these activities to the Finnish Transparency Register. Activities falling outside statutory tasks must, however, be disclosed to the Transparency Register.

  Read more about actors with lobbying tasks specifically laid down in the law.

• Data collection for journalistic purposes.

  When assessing whether a journalistic task is concerned, particular attention must be paid to compliance with the guidelines for journalists. For example, lobbying carried out by media groups must be distinguished from their journalistic activities and disclosed to the Finnish Transparency Register.

• Participation in working groups set up by the authorities or regulated by law, in advisory boards or similar multi-member bodies set up for a public task, and participation in documented hearings organised by Parliament or the ministries.

  Opinions issued by the parliamentary committees, opinions issued to the ministries or participation in an impact assessment, which are also documented by the government agency, are not disclosed to the Finnish Transparency Register. On the other hand, unofficial contacts, i.e. different forms of cooperation not included in the preparatory documents, are disclosed to the Register.

• Public appearance at public meetings and events

  Participation of a representative of an organisation as a speaker or as a member of the public in such events including discussions and talks that are open to all is not disclosed to the Transparency Register. Examples of participation as a speaker include giving a speech or presentation or participating in a panel discussion. Such activities do not have to be disclosed to the Register even if lobbying targets had also been invited to the same event as speakers or members of the audience. However, if closed meetings are also organised for a smaller group during a public and open event and lobbying is carried out in them, they must be disclosed to the Transparency Register.

• Mass communication, sending of newsletters or customer letters

  Mass communication refers to the distribution of information, opinions and other messages to a large group of recipients, which may also include lobbying targets. A key feature of mass communications is the publicity of the message. Public debates in traditional and social media or various customer letters or newsletters intended for a large group or similar, mainly unidirectional messages are not disclosed to the Transparency Register. However, if the mass communication leads to such closer communication between an actor subject to the disclosure obligation and a lobbying target that is considered to be lobbying, such closer communication must be disclosed to the Transparency Register.

• Communication that is part of central government ownership steering.

  Meetings of a board of directors or a supervisory board and other official contacts related to ownership steering do not have to be disclosed to the Transparency Register. On the other hand, contacts related to other topics than ownership steering must be reported to the Transparency Register even if they were directed at the same actors that deal with matters related to ownership steering. For example, an attempt to directly influence matters outside the company is considered an issue falling outside ownership steering.

• Communication in the name of entity affiliated to a political party with the same party's MPs, assistants of MPs, ministers, special advisers to ministers and state secretaries appointed for ministers' term of office.

  An entity affiliated to a political party refers to an entity or foundation, or a trust of an entity or foundation, that a political party, with the consent of the entity or foundation in question, reports to the National Audit Office as its affiliated entity.

• Lobbying consultancy provided to public-sector actors.

  Lobbying consultancy provided to public sector actors is not disclosed to the Transparency Register.

• Communication the disclosure of which may endanger public or national security

  The Transparency Register does not change the principle of openness in matters of public and national security. Activities that could reveal information that is to be kept secret under the secrecy provisions of the Act on the Openness of Government Activities are not disclosed to the Transparency Register.

• Acting as a rapporteur appointed by a public authority. A rapporteur's contacts with a ministry during an investigation are not disclosed to the Transparency Register. Lobbying targeted at rapporteurs must be reported to the Transparency Register.