Lobbying in UK politics

The current UK Parliament defines lobbying as:

When an individual or group tries to persuade someone in Parliament to support a particular policy or campaign. Lobbying can be done in person, by sending emails or via social media.

Lobbying refers to a relationship of influence between the person being lobbied (who is often a public office holder) and the lobbyist (who can be anyone, but often are “professional lobbyists”, trade unions, think tanks and non-governmental organisations).

Benefits and drawbacks of lobbying

Lobbying is generally considered to be good for democracy: it can introduce diverse (possibly overlooked) perspectives to policymakers, ensure that policies are well-informed, limit unintended consequences, and demonstrate the breadth and intensity of opposition or support for a measure.

However, it can also be problematic. For example, it may allow people with privileged access to policymakers to pursue their own ends at the expense of the public. Some people therefore consider that lobbying undermines public confidence in democratic outcomes.

Internal regulation of lobbying

People in public office are expected to adhere to the Committee on Standards in Public Life’s Seven Principles of Public Life (commonly referred to as the Nolan Principles): selflessness, integrity, objectivity, accountability, openness, honesty, and leadership.

There are further codes of conduct specifically for civil servants, MPs, Lords and ministers.

Civil service 

The Civil Service Code outlines four “core principles” as:

1. Integrity: putting the obligations of public service above personal interest.
2. Honesty: being truthful and open.
3. Objectivity: basing advice and decisions on rigorous analysis of the evidence.
4. Impartiality: acting solely according to the merits of the case and serving governments of different political parties equally well.

This approach expects civil servants to interact with lobbyists within the bounds of the “core principles” of the code of conduct, and the wider Nolan Principles.

MPs

Guidance for MPs is contained in the House of Commons Code of Conduct. The rules forbid MPs taking payment in return for advocacy in the House (such as speaking, voting or approaching ministers). Likewise, MPs cannot seek to confer financial benefits on anyone they have received or expect to receive financial benefits from.

However, these rules do not prevent an MP from engaging in proceedings which relate to matters in which they have a financial interest. In these instances, rules on registration and declaration of interests apply.

Lords

Lords are bound by the Code of Conduct for Members of the House of Lords, which states that they should always base their actions on a consideration of the public interest (which should always outweigh their personal interests). Like MPs, they are therefore prohibited from acting as paid advocates in any proceeding of the House.

Members of the House of Lords are expected to have outside interests and expertise to inform their work in the House and to contribute to the debates which are relevant to their interests (as long as these are properly declared).

Ministers

Ministers are bound by the Ministerial Code, which says that “ministers are appointed to serve the public and must ensure that no conflict arises, or could reasonably be perceived to arise between their public duties and their private interests, financial or otherwise”. Each minister must therefore judge for themselves about actual or perceived conflicts of interest, in conjunction with their permanent secretary and the Independent Adviser on Ministerial Standards.

New ministers must provide their permanent secretary with a full declaration of private interests which could give rise to conflicts, and they must keep this up to date.

The code also says that “decisions should not be influenced by the hope or expectation of future employment with, or rewards from, a particular firm or organisation”.

The Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014

The primary piece of legislation which regulates lobbying is the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014, also known as the Lobbying Act.

The act is intended to increase transparency. The Leader of the House at the time, Andrew Lansley, said “the public should be able to see how third parties seek to influence the political system”.

The act legislates that anyone “consultant lobbying” be registered on the register of consultant lobbyists. The act defines a consultant lobbyist as someone who is paid to make communications:

• personally, to a UK Government minister or permanent secretary
• about government policy, legislation, the award of contracts, grants, licenses or similar
• about benefits, or the exercise of any other government function such as the exercise of the prerogative
• on behalf of another person.

The register of consultant lobbyists is maintained by the Registrar of Consultant Lobbyists, who is (currently) appointed by the Minister for the Constitution. The registrar must not have been a minister, permanent secretary, or lobbyist in the five years before their appointment.

Criticism of the act

The Commons Political and Constitutional Reform Committee criticised the bill at the time, and recommended that the bill’s definitions of lobbyist and lobbying should be broader (for example, to include lobbying senior civil servants and special advisers).

In 2024, the Public Administration and Constitutional Affairs Select Committee published post-legislative scrutiny of the act, which recommended more frequent releases of transparency data, on an integrated platform for the whole of government, including special advisers in transparency rules, and extending disclosure rules to WhatsApp and other non-corporate communication channels. However, the government prior to the review ruled out making any legislative changes as a result of it and the general election happened before an official response was forthcoming.

Academics have also criticised the act, with one arguing that “lobbying regulation in the UK is among the very weakest of countries that have developed lobbying disclosure laws” and that “less than 4% of groups disclosed in ministerial meetings records appear in the lobbying register”.

Lobbying reviews after Greensill collapsed

The UK’s lobbying system received significant media attention after the collapse of Greensill Capital in March 2021 and former Prime Minister Lord Cameron’s approaches to government on its behalf, although no laws were broken.

This led to three inquiries addressing lobbying in the UK:

• The first, conducted by Nigel Boardman in 2021, recommended strengthening transparency reporting and expanding it to cover all non-public dialogues (such as messaging apps). It also suggested including special advisers and more junior civil servants in transparency releases and consulting on the defition of ‘lobbyist’.
• The second, conducted by the Treasury Select Committee in 2021, considered the fact that Lord Cameron did not break any rules reflected poorly on the rules themselves and called for reform. It recommended that the Treasury instigate improved means by which informal lobbying approaches are triaged and managed.
• The third, conducted by the Public Administration and Constitutional Affairs Select Committee in 2022, focused instead on business appointment rules given the committee was also conducting post-legislative scrutiny of the 2014 lobbying act.

Lobbying and recall petitions

There have been three incidences since the passage of the Recall of MPs Act 2015 in which lobbying activity met the requirements to trigger a recall petition (where voters can sign a petition to call a by-election):

• Ian Paisley (DUP): the recall petition did not meet the required 10% threshold to trigger a by-election.
• Scott Benton (Conservative): Mr Benton resigned as an MP 13 days into the signing period, which terminated the recall petition.
• Owen Paterson (Conservative): Mr Paterson resigned as an MP prior to the parliamentary vote on the motion to sanction him, meaning that no vote was taken.

Lobbying in other countries

18 countries currently have dedicated legislation addressing lobbying.

Academics have also developed a “robustness score” that ranks legislation based on eight criteria: the definition of lobbyist, individual registration, individual spending disclosure, employer spending disclosure, electronic filing, public access to a register, revolving door provisions, enforcement. 

The UK is ranked as having a “low robustness” score of 28 which places it higher than the European Parliament (15) and Germany (17), but lower than the USA (62), Canada (50) and France (42).