Talking to governments about policy is legitimate, but many jurisdictions require lobbyists to register and disclose. The UK registers only consultant lobbyists, the US federal system registers lobbyists and separately agents of foreign principals, Germany and France run broad registers with fines or criminal penalties, and the EU makes registration a condition for meetings with senior officials. Foreign companies should check these rules before hiring advisers or meeting officials.
Who has to register
The UK register is narrow: it covers organisations that communicate with ministers or permanent secretaries on behalf of paying clients, and only VAT-registered organisations can join. In-house lobbying is outside it. Registrants file quarterly returns within two weeks of each quarter end, and the Registrar can impose civil penalties of up to £7,500 or refer cases for prosecution.
The US federal Lobbying Disclosure Act requires registration with the Secretary of the Senate and the Clerk of the House within 45 days of the first lobbying contact or retention, with a single registration for an organisation's in-house lobbyists. A separate law, the Foreign Agents Registration Act, requires anyone acting in the US as an agent of a foreign principal, for example in political activities, to register within 10 days of agreeing to act. Lobbyists registered under the LDA are exempt from FARA unless they act for a foreign government or political party, and wilful FARA breaches can bring up to five years' imprisonment.
Germany's Bundestag lobby register, as tightened on 1 March 2024, applies from 30 contacts within three months and covers contacts with officials down to heads of division, with fines up to EUR 50,000. France requires registration with the HATVP where influencing public decisions is a principal or regular activity, recorded here from an older secondary source.1234567
The EU register and public consultations
The European Parliament, Council and Commission run a joint transparency register under a 2021 interinstitutional agreement. Registration is a precondition for meetings with Commissioners, their cabinets and Directors-General, for meetings with the Council's senior officials and for a long-term Parliament access pass, although the register is not enforceable legislation and the main sanction is removal.
Formal consultations are the other channel. UK government departments are asked to consult while policy is at a formative stage and to publish responses within 12 weeks, although the principles are not legally binding. Responding in writing to consultations creates a public record and does not usually trigger lobbying registration.8910
| Jurisdiction | Register | Who must register | Sanction | Source |
|---|---|---|---|---|
| United Kingdom | Register of Consultant Lobbyists | Consultant lobbyists contacting ministers or permanent secretaries for clients; VAT-registered | Civil penalty up to £7,500 or prosecution | ORCL FAQs |
| United States (federal) | Lobbying Disclosure Act | Lobbyists, within 45 days of first contact; in-house teams file one registration | Not confirmed | Cornell LII, 2 USC 1603 |
| United States (federal) | Foreign Agents Registration Act | Agents of foreign principals, within 10 days and before acting | Up to 5 years' imprisonment, USD 250,000 fine | DOJ FARA FAQ |
| European Union | Transparency Register | Precondition for meetings with senior Commission and Council officials and Parliament passes | Removal from register | European Court of Auditors |
| Germany | Bundestag lobby register | 30 contacts within three months (from March 2024) | Fine up to EUR 50,000 | Heuking (secondary) |
| France | HATVP register | Principal or regular activity of influencing public decisions | One year and EUR 15,000 (to be confirmed) | Fieldfisher 2017 (research draft) |
Decisions to make
- Will the company lobby through its own staff or through paid advisers?13The UK register covers consultant lobbyists but not in-house lobbying, while the US LDA covers both.
- Is the client or parent a foreign government, state-owned entity or political party?5The LDA exemption from FARA does not apply to work for a foreign government or political party.
- Which officials will be contacted, and how often?69German registration turns on the number of contacts and the officials' level, and EU meetings with senior officials need prior registration.
- Is a formal consultation open that would be a better channel?10Consultation responses are public and expected; UK departments should consult while policy is still at a formative stage.
Documents usually needed
- Register of government contacts: official, date, topic and who attended
- Engagement letters with public affairs advisers stating registration responsibilities
- Lobbying register entries and periodic returns
- Written consultation responses and position papers
- Policy on gifts and hospitality to public officials (see the risk centre)
Common mistakes
- Assuming that because the UK register does not cover in-house teams, other jurisdictions do not either
- Starting US activities for a foreign state-linked client before checking FARA
- Losing count of German contacts across business units
- Arranging a meeting with a Commission Director-General without a register entry
- Treating consultation responses as confidential when they are usually published
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- Current US LDA inflation-adjusted registration thresholds and LDA penalties were not confirmed.
- The French HATVP rules come from a 2017 secondary source and are a research draft.
- The consolidated German Lobbyregistergesetz text could not yet be checked.
- The European Commission's Have Your Say consultation periods could not be confirmed.
- Lobbying and consultation rules in India, the UAE, Saudi Arabia and Singapore were not researched; none of these has a comparable statutory register identified.
- US state lobbying laws were not covered.
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
An organisation that communicates with a UK government minister or permanent secretary on behalf of a paying client (consultant lobbying) must be on the statutory Register of Consultant Lobbyists, and only VAT-registered organisations can join; in-house lobbying on an organisation's own behalf is outside the register. Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014, Part 1. Communications with Members of Parliament, devolved administrations or local government are not covered.
Registered consultant lobbyists must file a quarterly information return within two weeks of each quarter end naming the clients for whom they lobbied, and the Registrar can impose a civil penalty of up to £7,500 or refer unregistered lobbying or late or inaccurate returns for possible prosecution. Nil returns are required for quarters without consultant lobbying.
Under the federal Lobbying Disclosure Act, a lobbyist must be registered with the Secretary of the Senate and the Clerk of the House no later than 45 days after first making a lobbying contact or being retained to make one, and an organisation with in-house lobbyists files a single registration. Federal (2 USC 1603). Registration is not required where a lobbying firm's income from a client, or an organisation's own lobbying expenses, stay below statutory amounts (originally USD 2,500 and USD 10,000 per quarter) that are adjusted for inflation every four years. State and local lobbying laws are separate.
Statutory text read on the Cornell reproduction of the US Code. The current inflation-adjusted thresholds were not confirmed.
A person acting in the United States as an agent of a foreign principal, for example by engaging in political activities or representing the principal before US officials, must register under the Foreign Agents Registration Act within 10 days of agreeing to act and before starting the activities. Federal; administered by the Department of Justice National Security Division FARA Unit.
An agent registered under the Lobbying Disclosure Act is exempt from FARA registration for lobbying that is not on behalf of a foreign government or foreign political party, and wilful FARA violations are punishable by up to five years' imprisonment, a fine of up to USD 250,000, or both. Federal; exemption at 22 USC 613(h).
Since 1 March 2024 an interest representative must register in the Bundestag lobby register once it has 30 contacts within three months, contacts with Bundestag staff and federal heads of division (Referatsleiter) count, and lobbying with missing or incorrect information can be fined up to EUR 50,000. Lobbyregistergesetz as amended with effect from 1 March 2024. Registrants must name the federal or EU regulatory projects they lobby on, list main funding sources and report annual lobbying expenditure in EUR 10,000 bands.
Secondary source; the consolidated Lobbyregistergesetz text could not yet be checked. Other registration triggers (regular, long-term or commercial representation) were not confirmed.
In France a person or organisation whose principal or regular activity is to influence public decisions, regular meaning at least ten initiated contacts with covered officials over twelve months, must register in the HATVP register of interest representatives and report its activities annually within three months of its financial year end. Sapin II law no. 2016-1691 of 9 December 2016 and decree no. 2017-867 of 9 May 2017. Covered officials include ministers and their cabinets, members of Parliament and their staff, and senior officials of independent authorities. Failure to declare is punishable by one year's imprisonment and a EUR 15,000 fine.
Research draft: the only source read is a 2017 law-firm summary. Thresholds, reporting periods and penalties must be confirmed on current HATVP guidance (hatvp.fr), which could not yet be checked.
The European Parliament, the Council and the Commission operate a joint transparency register for interest representatives under the Interinstitutional Agreement of 20 May 2021, which entered into force on 1 July 2021. EU institutions. Covers activities aimed at influencing EU policy and decision-making.
Only the title and metadata were readable; the articles could not yet be checked.
Registration in the EU Transparency Register is a precondition for meetings with Commission members, their cabinets and senior staff including Directors-General, for meetings with the Council's Secretary-General and Directors-General, and for a long-term access pass to the European Parliament, but the register is not enforceable legislation and the main sanction is removal. Individual meetings with Members of the European Parliament and their staff were not covered by a registration requirement when the audit was carried out. The interinstitutional agreement was due for review by July 2025.
Audit report published in 2024; any changes after the 2025 review were not checked.
UK government Consultation Principles ask departments to consult while policy is at a formative stage, to publish consultations on GOV.UK, and to publish responses within 12 weeks or explain why not; the principles are not legally binding. Central government guidance. Consultation length is to be proportionate rather than fixed. Statutory consultation duties in particular laws apply separately.
Page marked updated 19 March 2018.
Questions on this topic
10 statements on engaging regulators and lobbying rules, 1 not yet checked against a source
