This chapter highlights the challenges that Chile must meet in order to improve the transparency of the information disclosed on lobbying activities. First, the chapter suggests ways to ensure that comprehensive and pertinent information on who is lobbying, on what issues and how, is disclosed. The sharing of responsibilities for transparency between lobbyists and public officials is also discussed. The chapter also discusses how to provide a convenient electronic registration and report-filing system for both public officials and lobbyists and suggests ways to improve the content and granularity of the information declared through common technical specifications, guidance and assistance provided throughout the disclosure process as well as easy-to-fill sections connected to relevant databases. Lastly, the chapter provides recommendations on centralising lobbying information to enable stakeholders to easily grasp the scope and depth of these activities.
The Regulation of Lobbying and Influence in Chile
3. Enabling effective transparency on lobbying in Chile
Abstract
3.1. Introduction
A critical element for enhancing transparency in public decision-making is to provide mechanisms through which public officials, business and civil society can obtain sufficient information regarding who has had access to public decision-making processes and on what issues. Such mechanisms should ensure that sufficient, pertinent information on key aspects of lobbying activities is disclosed in a timely manner, with the ultimate aim of enabling public scrutiny (OECD, 2010[1])
Transparency can be ensured by various means which can be complementary (Table 3.1). The transparency measures introduced by OECD countries generally assign the burden of disclosure to lobbyists through a lobbying registry. Chile has chosen an alternative approach and assigns this responsibility to public officials targeted by lobbying activities, requiring them to disclose information about their meetings with lobbyists (i.e., lobbyists and managers of private interests as defined in the Lobbying Act), through a registry, even if lobbyists are still required to register online in order to request these meetings.
To ensure the effectiveness of lobbying transparency frameworks, a second critical element is to facilitate the disclosure of lobbying information through convenient electronic registration and report-filing systems. This includes designing tools and mechanisms for the collection and management of information on lobbying practices, building the technical capacities underlying the registers and maximising the use of information technology to reduce the administrative burden of registration.
In Chile, the disclosure regime is specified in Title II of the Act (“On public registers”). The Lobbying Act specifies that lobbying information must be disclosed in “public agenda registers”, which are defined in Article 2 §3 as registers of a public nature, in which passive subjects must enter the information set out in in the Act:
Public registers must be created and kept by the body or service to which passive subjects in Article 3 (central state administration), Article 4 §1 (regional and communal administration), Article 4-4 (armed forces and public order and security forces) and Article 4 §7 (members of special Councils and expert panels) belong (Article 7 §1). The regulation for the publication of these registers was established by the SEGPRES (Decreto 71 – Regula el lobby y las gestiones que representen intereses particulares ante las autoridades y funcionarios de la administración del estado) (Library of the National Congress of Chile, 2014[3]). The information contained in all the registers must be published and updated, at least once a month according to the provisions specified in Article 7 of Law No. 20.285 on access to public information.
The Office of the Comptroller General of the Republic, the Central Bank, the Parliamentary Ethics and Transparency Commissions of the National Congress, the Public Prosecutor’s Office and the Administrative Corporation of the Judiciary must establish their own regulation for the publication of their public agenda register. These regulations also clarify the information that they will transmit to the Transparency Council for the establishment of a list of lobbyists and managers of private interests (Articles 9 and10). The information from these registers is published on the electronic websites established in the rules of active transparency that govern them (Article 9). In particular:
The Office of the Comptroller General of the Republic keeps a public register for activities targeting the Comptroller General and Deputy Comptroller General (Article 7 §2). The regulation for this register was approved by resolution of the Comptroller General and published in the Official Gazette.
The Central Bank keeps a public register for activities targeting its President, Vice-President and Directors (Article 7 §3). The rules governing this register were established by means of a resolution of its Council, published in the Official Gazette.
Two registers, each created and kept by the respective Parliamentary Ethics and Transparency Commissions, in which the information must be entered by passive subjects in the Chamber of Deputies and the Senate (Article 7 §4). The rules governing the registers of the National Congress were approved by the Chamber of Deputies and the Senate, at the proposal of their respective Ethics and Parliamentary Transparency Commissions.
A register to be kept by the Public Prosecutor's Office for activities targeting the National Prosecutor and regional prosecutors (Article 7 §5). The regulation for this register was approved by resolution of the National Prosecutor of the Public Prosecutor's Office and published in the Official Gazette.
A register to be kept by the Administrative Corporation of the Judiciary, in which the information must be entered by its Director (Article 7 §6). The rules governing this register were adopted by the High Council of the Judiciary.
Concretely, to meet public officials, lobbyists and managers of private interests must register through the six platforms listed above, each of which has its own technical specifications. In particular, the regulation of each of these six registers specifies the information to be included in the register, the date of updating, the manner of publication, the background information required to request hearings and meetings and other aspects necessary for the operation and publication of the registers (Article 10). Decree 71, which governs the register of the central state administration, the regional and communal administration, the armed forces and public order and security forces, and members of special Councils and expert panels, indicates that passive subjects must respond within a maximum period of three business days to requests submitted by active subjects (Decree 71, Article 10). They can accept and schedule the meeting, reject their demand, or pass the request to another passive subject. Passive subjects must then disclose information on the register and update the information on the first business day of each month (Decree 71, Article 9). The Office of the Comptroller General of the Republic, the Central Bank, the Parliamentary Ethics and Transparency Commissions of the National Congress, the Public Prosecutor’s Office and the Administrative Corporation of the Judiciary have established their own rules for the publication of information in their registers.
In addition to their Public Agenda Registers, the SEGPRES, the Office of the Comptroller General of the Republic, the Central Bank, the Parliamentary Ethics and Transparency Commissions of the National Congress, the Public Prosecutor’s Office and the Administrative Corporation of the Judiciary must also establish their Public Register of Lobbyists and Managers of Private Interests (Article 13). The information in these registers is generated automatically from the requests filed by lobbyists and managers of private interests, and thus do not require any additional disclosures from them. The above-mentioned regulations establish the procedures, deadlines, background information and information required for entries in the public register of lobbyists and managers of private interests.
The Transparency Council then centralises the information from the public agenda registers and makes them available to the public on a single online platform www.infolobby.cl (Central Register of hearings, travels and gifts). In particular, on a quarterly basis, the Transparency Council must make available to the public a register containing a systematised list of persons, natural or legal, Chilean or foreign, who in that period have held meetings and hearings with the passive subjects listed in Article 3 (central state administration), Article 4 §1 (regional and communal administration), Article 4 §4 (Armed Forces and Public Order and Security Forces) and Article 4 §7 (Members of special Councils and expert panels), the purpose of which is lobbying or the management of private interests with respect to the decisions referred to in Article 5 (“List of Lobbyists”). This list must identify the person, organisation or entity with which the passive subject held the hearing or meeting, stating:
On behalf of whom the private interests were managed.
The individualisation of the attendees or persons present.
Whether remuneration was received for such management.
The place, date and time of each meeting or hearing held.
The specific subject matter dealt with.
The passive subjects of the regulated authorities listed in numbers §2, §3, §5, §6 and §8 of Article 4 must send to the Transparency Council the information agreed in the agreements they enter into, for the purposes of publishing it on the Central Register of hearings, travels and gifts and the List of lobbyists.
While these elements are comprehensive and provide a strong level of transparency on the official meetings held between active subjects and public officials, the disclosure regime currently only covers meetings and hearings between public officials and active subjects, leaving an important part of lobbying in the shadows. As a result, not all activities covered by the definition of “lobbying” and “management of private interests” provided in the Lobbying Act are covered by transparency requirements. In addition, while public officials have the prime responsibility to demonstrate and ensure the transparency of the decision-making process, the proposed approach in this law may result unbalanced as it lays on them all the responsibility of recording lobbying activities. Lobbyists and their clients also share an obligation to ensure that they avoid exercising illicit influence and comply with professional standards in their relations with public officials, with other lobbyists and their clients, and with the public (OECD, 2010[1]).
Lastly, the absence of a unique one-stop-shop registration and transparency platform for lobbying has emerged as one of the law's biggest challenges. For example, several private sector representatives met for the purpose of this report highlighted the absence of a single online form with harmonised registration forms for requesting hearings and meetings, which increases online procedures and thus the burden of compliance for lobbyists. In addition, information on the functioning of the law is accessible on several websites (for example, SEGPRES' www.LeyLobby.gob.cl does not cover autonomous bodies), which does not facilitate the overall understanding of the system by citizens, public officials and lobbyists.
As such, to improve transparency of lobbying activities and facilitate disclosure of lobbying information, this chapter provides recommendations on the following core themes:
Providing sufficient and pertinent information on who is lobbying, on what issues, and how.
The disclosure regime for lobbyists and public officials through convenient electronic registration and report-filing systems.
The content of disclosures and innovative tools to enhance their quality.
The transparency portal to make publicly available online, in an open data format, that is reusable for public scrutiny and allows for cross-checking with other relevant databases, information on lobbying activities disclosed in the registers.
3.2. Providing comprehensive and pertinent information on who is lobbying, on what issues and how
3.2.1. Disclosure obligations for public authorities and officials could be expanded beyond meetings that occurred to cover all meetings that were requested, so as to fully reflect the lobbying and influence taking place in practice
According to Article 8 of the Lobbying Act, the public agenda registers must include the following information:
Hearings and meetings held for the purpose of lobbying or the management for private interests in respect of the decisions referred to in Article 5. The information must indicate:
the person, organisation or entity with whom the hearing or meeting was held
on whose behalf the particular interests are pursued
the identity of the attendees or persons present at the hearing or meeting
whether any remuneration is received for such representations
the place and date of such representations
the specific subject matter discussed.
Trips made by any of the passive subjects established in the law, in the exercise of their functions. The information must indicate:
the destination of the trip
its purpose
the total cost
the legal or natural person who financed it.
Official and protocol donations, and those authorised by custom as manifestations of courtesy and good manners, received by the passive subjects established in the law, on the occasion of the exercise of their functions. The registers must identify:
the gift or donation received
the date and occasion of its receipt
the individualisation of the natural or legal person from whom it was received.
Each public institution referred to in Article 3, Article 4 §1, 4 §4 and 4 §7 with passive subjects have a dedicated lobbying institutional webpage. The technical specifications are the same for each institutional webpage as they are all hosted on the platform “Plataforma Ley del Lobby” www.leylobby.gob.cl developed by SEGPRES (Figure 3.1). In this platform, each institutional body must nominate an “institutional administrator” in charge of creating accounts for designated public officials, publishing and updating the list of the body’s designated public officials, assigning disclosure permissions, correcting and validating disclosures made by designated public officials, and co-ordinating trainings on the lobbying regulation for public officials. These public officials also have the possibility to designate “technical assistants” to respond to requests on their behalf and register information in the portal.
Figure 3.1. Standardised lobbying institutional webpages in Chile
Notes: the screen shot displays the standardised lobbying webpage and registration portals used in Chile. It includes the following sections: (i) designated public officials (“passive subjects” / “sujetos pasivos”), which links to a list of designated public officials and an online form for newly elected or nominated designated public officials to request their inclusion in the list; (ii) lobbyists (“lobbistas y gestores de intereses particulares”), which includes a form for lobbyists to register, which is a pre-requisite in order to solicit a meeting with a designated public official, and a list of lobbyists; (iii) audiences and meetings (“audiencias y reuniones”), which links to the register of audiences and meetings, and forms for lobbyists to solicit an audience/meeting; (iv) registers of travels and gifts (“viajes”, “donativos”); (v) information on the law.
Source: Lobbying institutional webpage of the Health Ministry in Chile
This two-level approach can facilitate the disclosure of meetings, as institutional bodies are better placed to manage and update their list of designated public officials, track and centralise their communications and meetings with lobbyists, and ensure that these communications are registered properly and on time. The administrator can also ensure that specific meetings or communications are not published twice in the register. For example, if a specific meeting attended by more than one passive subject is disclosed several times, the administrator can ensure that the information is centralised and published in a coherent way, avoiding duplications.
As such, the current system of publication of hearings and meetings is a good practice and should be maintained but could be generalised to all the passive subjects referred to in Article 3 and 4. Enabling such a change will require assigning responsibilities for administering the Registers to an independent body. This will be further discussed in Chapter 5.
In addition, Article 9 of the Lobbying Act could be amended so that the information disclosed is extended to unplanned communications with lobbyists, such as written communications (email exchanges, WhatsApp messages), meetings and hearings requested by lobbyists that were rejected, as well as meetings requested by passive subjects with active subjects and in which lobbying activities occurred. These additional registration requirements will enable the register to fully reflect the lobbying and influence actually taking place, as the action of requesting a meeting is in itself an act of lobbying, even if the meeting was refused or did not happen in the end. Currently, the registers only include hearings and meetings that were accepted and that occurred. In addition, this additional layer of transparency would enable greater public scrutiny on the principle of equity enshrined in Article 11 of the Lobbying Act. According to this principle, passive subjects must treat all meeting requests with equity, and cannot refuse a meeting with an interest group on a specific subject if they accepted a meeting on the same topic with another interest group. Enabling transparency on meetings that were refused will enable citizens and other interested stakeholders to make comparisons between accepted requests and rejected requests, allowing for the detection of possible violations of Article 11.
Lastly, the Commission for Public Integrity and Transparency is of the opinion that meetings between public authorities should also be published. To that end, the Commission has made proposals to establish a duty to publish meetings between high-level State authorities, such as ministers, deputies and senators, and ministers of the High Courts of Justice.
While this proposal is in line with best practices in OECD countries, however, it should be noted that meetings between public authorities do not constitute lobbying, and this should be clearly indicated and differentiated from meetings and hearings that do constitute lobbying. This aspect is further explained in the following section.
3.2.2. Information in the public agenda registers could be further clarified to clearly differentiate activities that are strictly related to lobbying and influence from other information related to passive subjects’ official agendas, travels and gifts
In transparency platforms, it is crucial to clearly differentiate activities that are related to lobbying and influence activities from other information that are not related to lobbying. For example, information disclosed regarding travels and gifts could be clarified. Indeed, the registers currently include trips made by any of the passive subjects in the exercise of their functions, as well as official and protocol donations, and those authorised by custom as manifestations of courtesy and good manners, in the exercise of their functions. While this information is useful for general transparency purposes, official travel and protocol gifts do not constitute lobbying and as such may not be as relevant to understand lobbying and influence practices taking place. Municipal representatives interviewed for this report confirmed that the register of travels and donations may contain information that is not as useful and that does not relate to any lobbying activity, such as technical trips and protocol donations.
Instead, the registers could be refocused on gifts, invitations, hospitalities and other benefits offered and paid for by active subjects, including by “professionals and researchers from non-profit associations, corporations, foundations, universities, study centres and any other similar entity” specified in Article 6 §6. These could include for example invitations to participate in a conference organised by a research centre or corporation, paid travel and other benefits provided by these entities.
Protocol gifts and trips that are carried out in the exercise of public functions could instead be registered in different platforms in the context of the broader integrity system for certain categories of public officials, and through a specific regulation, or in other sections of the registers. Such platforms could host, for example:
The public agendas of certain senior public officials covering their meetings where lobbying and influence activities are not involved. This would include, for example, meetings with other public authorities, meetings with external individuals (journalists), as well as official engagements and trips.
A register of protocol and customary gifts above a certain threshold, in line with either a gift policy enshrined in the legal framework or the specific gift policies of governments institutions.
A register of official travels, which would include official trips made by certain categories of public officials as part of their duties.
The declarations of assets and interests of certain categories of public officials, where applicable and in line with the relevant regulation.
In any case, regardless of the approach chosen, it should be clearly differentiated whether a gift comes from an active subject, or whether it is a protocol gift offered by another public authority. Similarly, the information published would make it clear whether a trip was offered and covered for by an active subject, or whether it was a travel undertaken as part of a public official’s official duties.
3.2.3. The public agenda registers could be complemented by a Register of Lobbyists where registration could be a pre-requisite to conducting lobbying activities and requesting meetings, and in which active subjects would face additional disclosure requirements
As emphasised throughout this report, the focus of the current legal framework is on the public official. This aspect is also one of the most recurrent criticisms of Law No. 20.730, as active subjects currently have limited disclosure obligations, with the exception of registering online to request hearings and meetings. Consequently, there is a lack of information about and from lobbyists beyond the information they disclose when requesting a meeting or hearing. In addition, the fact that the law only provides for the transparency of meetings and hearings means that there is a very large section of lobbying activities for which there is no information available.
As such, the current lobbying framework could also be complemented by a Register of Lobbyists, in which active subjects covered by the Law would be required to register all the activities covered by the Lobbying Act’s definition of “lobbying” and “management of private interests”. Registration could be made a pre-requisite for engaging in lobbying activities, including for requesting official hearings and meetings with passive subjects. This implies that entities and individuals wishing to engage in lobbying activities would register at the stage of intending to engage in such activities, and not after they have done so, or within a limited time frame after having conducted a lobbying activity. For example, registration could be made mandatory no later than ten days after the day on which the lobbyist begins to conduct lobbying activities. While this allows more flexibility for lobbyists, careful consideration should be given to the length of the registration deadline, to ensure it does not become an obstacle to the objective of transparency and timely access to lobbying information, or a source of confusion for some passive subjects who may wish to verify a lobbyist's registration before entering into communication with him or her.
In addition, lobbyists could be required to submit information regularly on the lobbying activities they conducted in practice. By providing an additional avenue for transparency through a separate mechanism to report all influence efforts, this register would be a complementary tool to the existing framework and also address the inherent weakness of the Act. Several OECD countries have adopted this approach with disclosure obligations for both public officials and lobbyists, including Slovenia and Lithuania (OECD, 2021[2]).
In countries that combine both approaches, cross-checking of lobbying agendas and registers provides an opportunity to cross-check information and analyse who tried to influence public officials and how. In the United Kingdom, for example, the Office of the Registrar of Consultant Lobbyists regularly cross-checks registered lobbyists with Ministerial open agendas (that are limited to the meetings of Ministers with external organisations), to monitor and enforce compliance with the requirements set out in the Transparency of Lobbying, Non-party Campaigning and Trade Union Administration Act 2014 (OECD, 2021[2]).
The rationale behind this additional layer of disclosures is that there are certain lobbying activities that can only be registered by the lobbyists themselves, and not public officials. Indeed, as emphasised in Section 2.2.3, a key feature of the 21st century lobbying context is that lobbyists increasingly engage in indirect forms of influence, including influence activities with clear strategies to hide the origin of the influence, in the absence of any regulatory framework to make these activities transparent. As such, only lobbyists would be able to disclose, for example, social media campaigns conducted in favour or against a specific bill being discussed in Parliament or partnering with a think tank or a research centre to produce studies and evidence supporting or opposing a specific position, as passive subjects would not be aware that such influence practices are taking place.
Good practice from other countries has found that requiring regular disclosures by lobbyists on their lobbying activities can strengthen transparency. To that end, the proposed Register of Lobbyists could require lobbyists to disclose their activities on a quarterly or semestrial basis, as in Ireland or the United States (Table 3.2).
Table 3.2. Frequency of lobbying disclosures by lobbyists in the United States and Ireland
Source: (OECD, 2021[2])
While it is generally assumed that professional lobbyists oppose the creation of lobbying registers and the public disclosure of their lobbying activities, none of the private sector representatives interviewed in Chile for this report opposed the proposal to create a complementary “Register of Lobbyists”. Some even expressed strong support for this proposal. In general, the OECD's interviews with various stakeholders revealed a consensus on the need to supplement the information currently reported in the registry, particularly on the targets of lobbying and their objective. This is line with OECD findings from a survey conducted in 2020, in which lobbyists expressed a willingness to participate in a mandatory lobbying registry, and many felt that this was necessary to protect the integrity of the profession (Figure 3.2). The same lobbyists surveyed by the OECD in 2020 were 57% of the opinion that the policy, piece of legislation targeted by the lobbying action should be made transparent by lobbyists. These attitudes reflect a commitment to integrity in public decision making and the importance of maintaining public trust.
Figure 3.2. Best means for regulating lobbying, according to lobbyists
Respondents were asked the following question: “In your opinion, which is the best means for regulating lobbying activities?”
Source: OECD 2020 Survey on Lobbying, in (OECD, 2021[2])
3.2.4. The Lobbying Act could include clear criteria for withholding the disclosure of information related to national security or protected commercial information
In Chile, exceptions to transparency obligations including meetings, hearings and trips are included in the Lobbying Act when their publicity would compromise the general interest of the Nation or national security (Article 8). To that end, an annual account of these must be submitted, in a confidential manner, to the Office of the Comptroller General of the Republic, for passive subjects referred to in Article 3 and in Article 4 §1, §2, §4 and §7. For other passive subjects, the report must be submitted to the person with the power to impose penalties, in accordance with the rules of Title III, discussed in Chapter 5.
While the reasoning behind exempting this type of information is sound, and a similar provision can be found in many lobbying regulations, the Lobbying Act or its related regulations could provide clearer criteria to guide the Office of the Comptroller General of the Republic’s determination for when to withhold certain information and on what grounds.
In addition, the provision could be strengthened to add the possibility for lobbyists to request the withholding of the disclosure of certain information related to sensitive commercial information. Such requests could be made to an independent oversight entity, with clear criteria to guide determination.
3.3. Providing a convenient electronic registration and report-filing system for both public officials and lobbyists
3.3.1. While remaining separate, the two proposed registers – for lobbyists and for public officials – could be hosted on a single central registration and disclosure portal so as to facilitate registration and enable greater public scrutiny through cross-checking of information
To facilitate disclosures, the OECD recommends avoiding a “distributed” form of lobbying registers – e.g., every institution having its own register hosted on different platforms with different technical specifications – which can undermine interoperability and reliability.
To that end, the registration and disclosure platform of all registers – for public officials and active subjects – could be hosted on the same platform. This will enable greater interoperability between both registers. For example, lobbyists and managers of private interests disclosing information would be able to select passive subjects from a list based on the list of passive subjects kept up to date in the current public agenda registers by public authorities. Similarly, public officials disclosing their relevant communications in the public agenda registers could be able to select the names of active subjects from a search bar connected to the list of lobbyists and managers of private interests registered in the Register of Lobbyists.
3.3.2. The technical specifications of the registration system developed by SEGPRES for the public agenda registers could be used and generalised to all government entities
Given that most of the passive subjects defined in the Law belong to the central state administration and the regional and communal administration, the majority of the lobbying registrations published by the Transparency Council on the centralised transparency platform “InfoLobby” www.infolobby.cl come from the lobbying registration platform designed and managed by SEPGRES. As described in Section 3.2.1, this system of a unique lobbying registration portal – “Plataforma Ley del Lobby” www.leylobby.gob.cl – leading the user to different institutional webpages with the same technical specifications is a good practice that could be maintained. Over 700 government organisations – including ministries, undersecretaries, public services, regional governments, presidential delegations, municipalities, municipal corporations, among others – currently use the system to manage and consolidate the lobbying information that is then transferred to InfoLobby for publication and visualisation.
Thus, the registration system currently developed by SEGPRES could in the future be used to build a unique registration platform that would be used by all passive subjects referred to in Articles 3 and 4 of the Lobbying Act.
3.3.3. The Register of Lobbyists could place the obligation to register on entities through a unique identifier and a collaborative space per organisation, while clarifying the responsibilities of designated individuals in the registration of information
To facilitate disclosures, and later to make it easier to find accurate information about entities in the Register of Lobbyists, the Lobbying Act could focus the framework on corporate and institutional accountability, and place the registration requirement on entities rather than on individuals, as entities are the ultimate beneficiaries of lobbying activities. Currently, when searching the list of registered lobbyists generated automatically, the pieces of information that appear most clearly are natural persons conducting lobbying, even though these natural persons are usually employed by the entity which they represent, or work within a professional lobbying firm. Very few entities appear in the list of active subjects. In addition, no further information other than the name of the person or entity, whether they are lobbyists or managers of interest, a natural and legal person, appear in the list of lobbyists (for legal persons, the national identifier of the legal entity is also visible). This makes it difficult to understand which interests are the ones being represented.
It is therefore recommended that the proposed Register of Lobbyists places the obligation to register on entities – through a unique identifier – instead of individuals. Concretely, the Register of Lobbyists would display clearly:
The name of the legal entities who conduct lobbying on their own behalf (i.e., companies, civil society organisations, etc. with in-house lobbyists).
The name of the legal entities who conduct lobbying on behalf of clients (i.e., lobbying firms, law firms), and the list of their clients.
The name of self-employed lobbyists (natural persons) who conduct lobbying on behalf of clients, and the list of their clients.
To register, entities that are lobbying would be able to designate one or more registrars to register the entity, as well as to consolidate, harmonise and report on the lobbying activities of the entity. When requesting meetings with passive subjects, the entity would still be required to disclose the names of the individual lobbyists who would attend the meeting. Similarly, when disclosing lobbying activities, entities would be required to disclose the names of all individuals employed in the entity who have engaged in lobbying activities.
In Quebec for example, each entity has its own “Collective space”, which contains all the lobbying activities conducted by the entity by one or several lobbyists. Lobbyists who have been tasked by the entity to register information in that “Collective Space” can create their own individual professional account and connect this account to the Collective space of the entity. Similarly, in France, the online registration portal is designed as a workspace for legal entities, each of which has a “collaborative space”, which enables them to communicate lobbying information to the High Authority for transparency in public life (HATVP) in the best possible conditions. Individual lobbyists lobbying on behalf of a legal entity can create their own individual accounts and ask to join the collaborative space of that entity. The collaborative space is managed by an “operational contact” designated by the entity; he or she manages the rights of every individual registered in the collaborative space (Table 3.3).
Table 3.3. Responsibilities to register lobbying information in Ireland, France and Quebec (Canada)
Source: www.lobbying.ie (Ireland); Registering in Carrefour Lobby Québec, https://lobbyisme.quebec/en/lobbyists-registry/registering-in-the-registry/ (Quebec, Canada); HATVP (2023) Répertoire des représentants d’intérêts, Bilan des déclarations d’activités 2022, https://www.hatvp.fr/wordpress/wp-content/uploads/2023/07/HATVP_BILAN_RRI-2022_VF.pdf (France)
A similar system could be implemented in Chile, in which every entity – whether lobbying on its own behalf or on behalf of clients – would be required to register as an entity with a “collaborative space” in the registration portal. One or several representatives of this entity would be designated as the registrar(s) and manager(s) of this collaborative space and assign responsibilities to individuals for the registration of lobbying activities. The registrar and any person designated by the registrar to register information would have their own individual accounts and contribute to the collaborative space.
Such a system has several advantages. First, assigning clear disclosure responsibilities to certain individuals can help these entities to track and centralise internally their lobbying activities. Second, it also ensures that the lobbying information is published in a harmonised and therefore more coherent and intelligible way, as designated individuals are already trained to use the disclosure platform. Lastly, placing the responsibility for registration on entities and not individuals can help avoid the stigmatisation of individual lobbyists while also allow an entity to be held accountable for potential breaches of the Lobbying Act.
3.4. Enhancing the quality of the information disclosed by active and passive subjects
3.4.1. The centralised lobbying registration and disclosure portal could serve as a one-stop-shop for lobbyists and public officials on how to register and disclose information
To ensure compliance with registration requirements, and to deter and detect breaches, the lobbying oversight function should raise awareness of expected rules and standards and enhance skills and understanding of how to apply them (OECD, 2010[1]).
The Commission for Public Integrity and Transparency has made available on the portal www.leylobby.gob.cl information and guidance documents, but the latter are limited to a citizen handbook and a legal handbook on the Lobbying Act. In addition, the Commission provides technical assistance and trainings to passive subjects referred to in Article 3, Article 4 §1, 4 §4 and 4 §7. It relies on an internal “Register of technical assistance” in order to monitor needs of technical assistance by public officials. Information is then published in a report on “Monitoring, reporting and support reports”, made available online.
In the future, in the event that broader disclosure obligations for both public officials and active subjects are put in place, the guidance and assistance provided to lobbyists / managers of private interests and public officials could be strengthened. Local elected representatives interviewed for this report particularly insisted on the need for more guidance, guidelines and manuals on the Lobbying Act due to a lack of knowledge and awareness of the law at the local level. This aspect was further confirmed by the Transparency Council, which pointed that some mayors believed that every hearing and meeting with an external actor constituted lobbying, and therefore tended to register meetings that did not constitute lobbying. Based on international best practices, guidance and assistance may include, among others:
A step-by-step questionnaire on whether to register as a lobbyist or whether a request for a meeting constitutes lobbying. While definitions in the Lobbying Act should be robust, comprehensive and sufficiently explicit to avoid misinterpretation and to prevent loopholes (OECD, 2010[1]), some individuals or interest groups may have doubts on whether their activities qualify as lobbying under the Act. A short online questionnaire can help remove any doubt. For example, the Irish lobbying portal www.lobbying.ie includes a simple Three-Step Test – “Are you one of the following?”, “Are you communicating about a relevant matter?”, “Are you communicating either directly or indirectly with a Designated Public Official?” – to allow potential registrants to determine whether they are or will be carrying out lobbying activities and are required to register. Once they decide to register, all new registrations are reviewed by the Commission for Standards in Public Life to ensure that the person is indeed required to register and that they have done so correctly (Irish Standards in Public Office Commission, 2016[4]). The French portal also includes a similar online test (HATVP, n.d.[5]), with questions also available in English (HATVP, n.d.[6]) (Figure 3.3).
Figure 3.3. Step-by-step questionnaire on whether to register as a lobbyist in Ireland (top) and France (bottom)
Technical guidelines on managing accounts. When registering, it is possible that lobbyists and public officials may at first struggle on how to set up an account, how to authenticate themselves and manage their passwords. It may therefore be useful to provide technical guidelines to support them in the first steps of their registration. For example, the Irish lobbying portal provides guidelines on “How to Manage your Account” (https://www.lobbying.ie/help-resources/information-for-lobbyists/new-user-how-to-section/how-to-manage-your-account/), which is part of a “New User - How to section”.
Regular email correspondence and automatic reminders sent to lobbyists and public officials to improve compliance with reporting requirements. Sending reminders to lobbyists and public officials about mandatory reporting obligations can help mitigate the risk of non-compliance (Box 3.1). Newly registered lobbyists and public officials can also be sent a letter or email highlighting their reporting obligations and deadlines, as well as best practices for account administration and details of enforcement provisions in the event of non-compliance, as is the case currently in Ireland (Irish Standards in Public Office Commission, 2022[7]).
Box 3.1. Automatic alerts to raise awareness of disclosure deadlines
Australia
Registered organisations and lobbyists receive reminders about mandatory reporting obligations in biannual e-mails. Registered lobbyists are reminded that they must advise of any changes to their registration details within 10 business days of the change, and confirm their details within 10 business days beginning 1 February and 1 July each year.
France
Lobbyists receive an e-mail 15 days before the deadline for submitting annual activity reports.
Germany
If no updates are received for more than a year, lobbyists receive an electronic notification requesting them to update the entry. If the information is not updated in three weeks, their file is marked “not updated”.
Ireland
Registered lobbyists receive automatic alerts at the end of each of the three relevant periods, as well as deadline reminder e-mails. Return deadlines are also displayed on the main webpage of the Register of Lobbying.
United States
The Office of the Clerk of the House of Representatives provides an electronic notification service for all registered lobbyists. The service gives e-mail notice of future filing deadlines or relevant information on disclosure filing procedures. Reminders on filing deadlines are also displayed on the Lobbying Disclosure website of the House of Representatives.
Source: (OECD, 2021[2])
Online guidelines, videos and handbooks clarifying certain aspects of the law, including definitions and what to register. For example, the HATVP published a detailed handbook entitled “Register of interest representatives: Guidelines”, which clarifies the provisions of the law, available both in English and in French (HATVP, 2019[8]). The guidelines are updated on a regular basis. The HATVP lobbying web portal also includes a downloadable “Presentation kit”, which includes explanatory videos, an awareness-raising brochure and posters, as well as the guidelines, practical sheets and a video tutorial on the use of the registration portal. All guidance is available on a one-stop-shop dashboard (https://www.hatvp.fr/espacedeclarant/representation-dinterets/) (Figure 3.4). Similarly, the Irish lobbying portal www.lobbying.ie includes a series of webpages with guidelines for lobbyists, including targeted guidelines for specific interest groups (e.g., “Top ten things Charities need to know about Lobbying”), as well as a document “Regulation of Lobbying Act 2015: Guidance for people carrying on lobbying activities”, updated on a regular basis (Irish Standards in Public Office Commission, 2019[9]).
Figure 3.4. One-stop-shop Lobbying dashboard with online guidelines in France
Guidelines for lobbyists on how to track and monitor internally their lobbying activities. Such guidelines, in the form of monitoring guidance, can help promote compliance and registration. The example of France is provided in (Box 3.2).
Box 3.2. “How to track your lobbying activities” tool developed by the HATVP in France
In France, lobbyists are required to disclose to the HATVP details of the activities carried out over the year within three months of the close of their accounting period. This annual declaration takes the form of a consolidated report by subject and declared in the form of returns on the disclosure platform.
1. Designate a “referent” / “administrator” responsible for consolidating, harmonising and declaring the lobbying activity returns in the portal.
2. Identify all persons likely to be qualified as “persons responsible for interest representation activities” (i.e., lobbying).
Identify a priori the persons likely to fall within the scope, on the basis of job titles and the tasks generally carried out, ask all identified persons to trace their communications with public officials and register them in the registration portal.
3. Implement an internal reporting tool to consolidate all the information that should be included in the annual disclosure of lobbying activities, in particular:
Guidelines on how to register initial information and submit regular returns / activity reports. In addition to guidelines on clarifying definitions and creating accounts, lobbyists and public officials also need detailed guidelines on how to register in the portal and submit the information requested. For example, the Irish lobbying portal includes a “New User – How to section” with step-by-step guidance on “How to register as a lobbyist” and “How to submit a return”, including a “Sample Return Form”.
Live help tools such as pop-ups, instructions on how to fill a section, calling a specific hotline or calling / e-mailing a dedicated contact. For example, the HATVP has a dedicated hotline that lobbyists and public officials can reach when registering information, available Monday to Friday from 9:00 to 12:30 and from 14:00 to 17:00. A dedicated help function called “Registration assistance” is available directly on the registration portal (Figure 3.5). Similarly, the Quebec platform includes an “intelligent” chatbot where citizens and lobbyists can ask questions or raise doubts (Figure 3.6).
Figure 3.5. Dedicated lobbying hotline to assist lobbying registration in France
Figure 3.6. Lobbying chatbot available on Quebec’s “Carrefour Lobby Quebec” platform
Mandatory induction trainings on the Lobbying Act and the registration process. For example, the New York State Lobbying Act provides for a continuing education regime for all registered lobbyists (Box 3.3).
Box 3.3. Trainings for lobbyists in the State of New York
The New York State Commission on Ethics and Lobbying in Government (COELIG), which administers the Lobbying Act, provides a mandatory online training course for individuals registered as lobbyists. Subject matters include information provided in the Lobbying Act, relevant regulations and advisory opinions, as well as reporting obligations and ethical standards. The training also includes best practices for meeting the various statutory requirements.
Each person registered as a lobbyist must complete this training course within 60 days of initial registration and at least once in any three-year period during which they are registered as a lobbyist.
Source: New York State Commission on Ethics and Lobbying in Government, “Information on the Mandated Ethics Training Requirement for Lobbyists and Clients”, https://ethics.ny.gov/information-mandated-ethics-training-requirement-lobbyists-and-clients
3.4.2. The registration portals could include clear and easy-to-fill sections, connected to relevant databases so as to facilitate registration and ease the burden of compliance for lobbyists and public officials
When designing registration portals, particular attention should be given to innovative solutions that could help ease the burden of compliance, for example connecting certain sections to relevant databases and enabling lobbyists and public officials to choose from a drop-down menu. For example, if a lobbyist intends to lobby on a specific bill, he or she would be able to choose the name of the specific bill from a drop-down menu connected to the database of legislative bills of the Parliament. This system is for example in place in Quebec (Canada), and also avoids the caveat of having a same bill being referenced or formulated in different ways by lobbyists.
The following two tables contain examples of the specific sections that could be included in the initial registration form for lobbyists and managers of private interests (Table 3.4) and the form to request a meeting/hearing (Table 3.5), including the type of disclosures and interoperability with relevant databases. The proposals are based on SEGPRES’s existing form to request an audience (Formulario Solicitud Audiencia Ley No. 20.730), as well as international best practices from Canada, Ireland and France. In particular, the registration forms for lobbyists could require lobbyists to state any type of existing or past relationship with decision makers or their advisors, so as to clarify any potential conflict of interest.
Table 3.4. Proposals for sections to be included in the initial registration for active subjects (pre-requisite to conduct lobbying activities and request meetings with public officials)
Source: author’s contribution, based on (OECD, 2021[2]) and (OECD, 2023[10])
Table 3.5. Proposals to strengthen SEPGRES’s existing form to request meetings and hearings with passive subjects for lobbyists / managers of private interests
Source: author’s contribution, based on SEGPRES’s existing registration form (Formulario Solicitud Audiencia Ley No. 20.730), (OECD, 2021[2]) and (OECD, 2023[10])
The sections in the form to disclose subsequent information on lobbying activities – on a quarterly or semestral basis – would be similar to the ones specified in Table 3.5 on who lobbied, who was the target, and what matters were lobbied about. These disclosures could take the form of “activity reports” filed for each objective pursued, and would specify all lobbying activities undertaken (for example all activities undertaken to “modify article X of Bill Y in direction Z”) and the type of lobbying activities undertaken (e.g., written communications, commissioning of research, meetings with public officials, social media campaigns, etc.) for that specific objective. To that end, an additional section on “HOW was the lobbying carried out?” would include a drop-down menu with the type of communication tool used (including for example written communication, telephone, meeting, grassroots lobbying / mass communications, other) and an open box to describe the communications used (e.g., “5 written communications by email with Parliamentary X”, “social media campaign advocating for a change in law Y”). For example, where social media is chosen as the activity type, lobbyists could indicate if it was via twitter/Facebook/etc. as well as an estimate of the volume of posts. Lobbyists would also specify policy and position papers, amendments, opinion polls and surveys, open letters and other communication or information material that were sent to passive subjects in writing, or presented to them during a meeting.
Similar sections could be proposed for public officials when disclosing their lobbying meetings and communications with lobbyists, as indicated in Table 3.6.
Table 3.6. Proposals for sections to be included in the registration portal for public officials
Source: author’s contribution, based on (OECD, 2021[2]), (OECD, 2023[10]) and the Lobbying Act
As illustrated in the tables above, the sections should be clear and enable lobbyists to file information on the specific purpose of lobbying activities (“WHAT”), how lobbying activities were carried (“HOW”), who carried the lobbying activities and who were the targets of the lobbying activities (“WHO”). The Registration portals should also include a possibility to save a draft and return later. Good practice examples of clear categorisation and visual identity in Ireland are provided in Figure 3.7.
Figure 3.7. Selected sections to be filled by lobbyists in the Irish registration portal
Source: Standards in Public Office Commission, Guidance on how to submit a return, https://www.lobbying.ie/help-resources/information-for-lobbyists/new-user-how-to-section/how-to-submit-a-return#:~:text=Submitting%20a%20Return,return%20of%20lobbying%20activities%E2%80%9D%20screen.
3.4.3. The registration portals could provide guidance on filling sections with open text and use data analytics tools to enhance the quality of information disclosed in these fields
The quality of information disclosed in boxes with open text may vary and lobbyists may not always understand what is expected of them when disclosing information in these fields. For example, open boxes where lobbyists must explain the objective pursued and the intended results should in theory include words such as “modify”, “propose” “prevent the adoption of”, “influence the preparation of”, “push for the enactment of”, “obtain the grant of” / “obtain financial aid”, “prohibit the practice of”, “promote the use of”, but this might not always be the case in practice. Experience from other countries has found that the section describing the objective pursued by lobbying activities was often used to report on general events, activities or dates of specific meetings (e.g., “meeting with a senator to discuss 5G technology”, “defending my company’s interests”, “discussion on the COVID-19 crisis”). Chile faces similar challenges. The Commission for Public Integrity and Transparency noted, for example, that the information disclosed in open boxes that refer to the topics that are to be covered in meetings and hearings (“materias que desea abordar en la Audiencia”) are usually low in quality, which makes it difficult to understand the real reason and purpose of the meeting or hearing.
To enhance the quality of information declared in activity reports, practical guidance explaining how sections on lobbying activities should be completed could be provided for both lobbyists and public officials who have to report information. Good practice from Ireland (Box 3.4) and France (Table 3.7) can serve as examples.
Box 3.4. Guidance provided by the Standards in Public Office Commission in Ireland on how to fill a return
Intended Results:
In this text box, insert sufficient detail on the results you were seeking to secure through your lobbying activity. The intended result should be meaningful, should relate directly to the relevant matter you have cited above, and should identify what it is you are actually seeking. Is it more funding? A regulatory change? It is not sufficient to say that you are seeking “to raise matters of interest to our organisation”. To be a “relevant matter” that must be reported, you must be communicating about:
the development, initiation or modification of any public policy, programme or legislation
the award of any public funding (grants, bursaries, contracts, etc.), or
zoning or development.
Examples:
To ensure greater fines/penalties for persons convicted of illegal dumping.
To increase the maximum allowable speed at which passenger vehicles may operate on Irish motorway.
To improve efficiency of border security processes when travelling between European countries.
To demonstrate the benefits of our community program in order to seek continued/additional funding.
To rezone a tract of land adjacent to my business from residential to commercial.
Source: Standards in Public Office Commission, https://www.lobbying.ie/media/6044/sample-return-form-march-2016.pdf
Table 3.7. Guidance provided by the HATVP on filling the open box “objective pursued” in France
Source: High Authority for Transparency in public life, Guidance note “How to fill the ‘object’ section of an activity sheet?”, https://www.hatvp.fr/wordpress/wp-content/uploads/2018/09/fiche-pratique-objet-sept-18.pdf
Second, using data analytics to strengthen the quality of the input has also proven useful in other OECD countries. For example, the HATVP established an algorithm based on artificial intelligence to detect potential defects upon validation of the activity report, including incomplete or misleading declarations. Concretely, when completing the “objective pursued” section of an activity report, lobbyists are nudged to provide specific details, including the subject on which the lobbying action bore, the expected results – using at least on positioned verb (“request”, “promote”, “oppose”, “reduce”) – and the public decision(s) targeted by the activities concerned (Figure 3.8). If the return they submit does not meet the established criteria of the algorithm, lobbyists are notified through a pop-up window indicating that that the information entered does not meet the established criteria. It also provides guidance and good practice examples. Lobbyists then have the possibility to modify the information disclosed in the section.
Figure 3.8. Using data analytics to improve the quality of lobbying disclosures in France
Public display on the dedicated disclosure service at the time of entry
Note: The screen shot shows examples of good responses that would be accepted by the system (for example: “include in the law or by regulation the possibility for a user to freely choose his or her car expert following an accident”, “lowering the VAT rate to 2.1% for the online press in the 2018 Finance Bill”, “apply the reduced VAT rate of 5.5% to nappies for infants”) and vague responses that would not be accepted by the system” (e.g. “alerting to the risks of the withholding tax”).
Source: Information provided by the High Authority for Transparency in Public Life
3.5. Centralising lobbying information in a unique and intuitive online Lobbying Transparency Portal
3.5.1. Information from all lobbying registers could be combined in a unique Lobbying Transparency Portal, with information available in an open data format
Once registration and disclosure platforms are in place, the information disclosed must be centralised and disclosed in a unique database enabling stakeholders – including civil society organisations, businesses, the media and the general public – to fully grasp the scope and depth of these activities (OECD, 2010[1]). While they may take various forms, online lobbying platforms should ease access to and understanding of large volumes of data collected through registries. As a general rule, lobbying transparency portals should avoid monolithic statements or lists of lobbyists that do not give any relevant information for citizens to understand the state of play of lobbying activities and their concrete impact on decision-making processes.
As such, for lobbying transparency portals to be useful and provide relevant information, they should be viewed as an information ecosystem shared between citizens, lobbyists and designated public office holders on matters related to lobbying, with the objective to maximise the data disclosed in the registration portals. Going beyond the availability of lobbying data, transparency portals can also be used as the one-stop-shop with guidelines for lobbyists, information for citizens, factsheets and analysis of the information contained in the registers. In Ireland for example, in addition to housing the online register, the website www.lobbying.ie includes all the information related and guidance tools explaining the registration and return processes.
In that respect, Chile currently has one of the best practices among OECD countries. The portal InfoLobby – although hosted on a different platform than LeyLobby – includes data visualisation tools and enables filtering information by category (Figure 3.9).
Figure 3.9. Lobbying transparency portal in Chile
Source: https://www.infolobby.cl/
In the future, and in the event that more comprehensive disclosure requirements are established for both lobbyists (active subjects) and public officials through the two complementary registers proposed in this report, information driven from these registers could be combined and made available in a unique Lobbying Transparency platform (and hosted within the proposed single central registration and disclosure portal), with relevant filters enabling searches by lobbying entities, public policy areas, passive subjects, or specific public decisions. In particular, aggregating data on a single website will allow cross-checking of data sources and also optimises the potential for transparency.
3.5.2. The Lobbying Act could include provisions on preparing a public decision-making footprint for specific decision-making processes, to be included in the Lobbying Transparency Portal
The proposed Lobbying Transparency Portal could also feature thematic analysis of data contained in the registers and prepared by the institution who will have responsibilities to administer the Portal. As such, the Lobbying Act could include a provision assigning responsibilities to compile and disclose a “public decision-making” footprint on specific decision-making processes, including for example legislation, government policies or programmes, and high-risk or high-dollar value contracts or concessions. In determining what specific public decisions should be accompanied by a public decision-making footprint, a risk-based approach could be considered. The information disclosed can be in the form of a table or a document listing the identity of the stakeholders contacted, the public officials involved, the purpose and outcome of their meetings, and an assessment of how the inputs received from external stakeholders was taken into account in the final decision.
By enabling stakeholders to get an overview of the lobbyists involved in a specific public decision, for example a legislative initiative, as well as an assessment of how the input received was factored into the final decision, the public decision-making footprint is a useful tool to shed light on the practical reality of lobbying. In France for example, the obligation to declare the objective of lobbying activities makes it possible for the HATVP to trace the influence communications disclosed on a specific bill or decision and compile the information into thematic reports published on the centralised platform https://www.hatvp.fr/lobbying/. The HATVP has already published two reports summarising all declared lobbying activities on specific bills, which shed light on the practical reality of lobbying.
Proposals for action
In order to enable effective transparency on lobbying in Chile, and to be as consistent as possible with OECD standards and international best practices in this area, the OECD recommends that the Government of Chile considers the following proposals.
Provide comprehensive and pertinent information on who is lobbying, on what issues and how
Maintain the current system of registration of hearings and meetings established by SEGPRES and generalise it to all the passive subjects referred to in Article 3 and 4, so as to harmonise registration forms and provide a unique registration platform to request meetings and disclose information on these meetings.
Amend Article 9 of the Lobbying Act to expand disclosure obligations for public authorities and officials beyond meetings that occurred to cover all meetings that were requested, so as to fully reflect the lobbying and influence taking place.
Clearly differentiate in the information disclosed by public officials in the public agenda registers the activities that are strictly related to lobbying and influence from other information related to passive subjects’ official agendas, travels and protocol gifts.
To complement the current public agenda registers, introduce a Register of Lobbyists with disclosure obligations for entities – rather than individuals – conducting lobbying activities. Initial registration in this Register could be made a pre-requisite for engaging in lobbying activities, including for requesting official hearings and meetings with passive subjects. Active subjects would then be required to file additional information on their lobbying activities on a quarterly or semestrial basis (public decisions targeted, types of lobbying activities conducted, objective pursued).
Establish clear criteria for withholding the disclosure of information related to national security or protected commercial information.
Add a possibility for lobbyists to request the withholding of the disclosure of certain information related to sensitive commercial information. Such requests could be made to an independent oversight entity, with clear criteria to guide determination.
Provide a convenient electronic registration and report-filing system for both public officials and lobbyists
Host on a single central registration and disclosure portal the two proposed registers for lobbyists and for public officials – while keeping them separate – so as to facilitate registration and enable greater public scrutiny through cross-checking of information.
For active subjects, place the obligation to register on entities through a unique identifier and a collaborative space per organisation, with individual responsibilities of designated individuals in the registration of information.
Enhance the quality of the information disclosed by active and passive subjects
Establish the centralised lobbying registration and disclosure portal as a one-stop-shop for lobbyists and public officials on how to register and disclose information.
Include in the registration and disclosure portals clear and easy-to-fill sections, with guidance explaining how to fill sections with open text, and connected to relevant databases so as to facilitate registration and ease the burden of compliance for lobbyists and public officials.
Centralise lobbying information in a unique and intuitive online Lobbying Transparency Portal
Publish all information from the lobbying registers on a unique Lobbying Transparency Portal, with information available in an open data format, enabling cross-checking of information, and including relevant filters allowing searches by lobbying entities, public policy areas, passive subjects, or specific public decisions.
Include provisions in the Lobbying Act on preparing a decision-making footprint from information driven by the registers, to be published in the Lobbying Transparency Portal.
References
[8] HATVP (2019), Register of Representatives: Guidelines, https://www.hatvp.fr/wordpress/wp-content/uploads/2019/03/Guidelines-February-2019.pdf.
[5] HATVP (n.d.), Êtes-vous un représentant d’intérêts?, https://www.hatvp.fr/espacedeclarant/representation-dinterets/etes-vous-un-representant-dinterets/#post_7419.
[6] HATVP (n.d.), Who is a lobbyist, https://www.hatvp.fr/en/high-authority/regulation-of-lobbying/list/#resources-ri.
[7] Irish Standards in Public Office Commission (2022), Regulation of Lobbying Annual Report 2021, https://www.lobbying.ie/media/6308/lobbying-annual-report-2021.pdf.
[9] Irish Standards in Public Office Commission (2019), Regulation of Lobbying Act 2015: Guidance for people carrying on lobbying activities, https://www.lobbying.ie/media/6243/guidelines-for-lobbyists.pdf.
[4] Irish Standards in Public Office Commission (2016), Take the Three Step Test, https://www.lobbying.ie/media/6045/three-step-test-april-2016.pdf.
[3] Library of the National Congress of Chile (2014), Decreto 71 – Regula el lobby y las gestiones que representen intereses particulares ante las autoridades y funcionarios de la administración del estado, https://www.bcn.cl/leychile/navegar?idNorma=1065874&idParte=0.
[10] OECD (2023), Public Integrity in Malta: Improving the Integrity and Transparency Framework for Elected and Appointed Officials, OECD Publishing, Paris, https://doi.org/10.1787/0ecc469e-en.
[2] OECD (2021), Lobbying in the 21st Century: Transparency, Integrity and Access, OECD Publishing, Paris, https://doi.org/10.1787/c6d8eff8-en.
[1] OECD (2010), “OECD Recommendation for Transparency and Integrity in Lobbying and Influence”, OECD Legal Instruments, OECD/LEGAL/0379, OECD, Paris, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0379.