Summary Report Public Consultation Transparency Register

Analysis of responses to the
Open Public Consultation

on the proposal for a mandatory
Transparency Register
(Specific Contract SG/B4/R1-2015/1
implementing Framework Contract
ENTR/172/PP/2012-FC Lot 3)
Final Report
prepared for
Secretariat-General
July 2016
Analysis of responses to the Open Public Consultation
on the proposal for a mandatory
(Specific Contract SG/B4/R1-2015/1 implementing

Framework Contract ENTR/172/PP/2012-FC Lot 3)
July 2016
Final Report
Quality Assurance
Project reference / title J908 SecGen Transparency Register
Report status Final Report
Dr Peter Floyd, RPA

Teresa Fenn, RPA
Main Authors
Shaun da Costa, RPA
Hannah Collins, RPA
Approved for issue by Dr Peter Floyd, RPA
Date of issue 28 July 2016
Document Change Record
Report Version Date Change details
Draft Final As submitted 27 June 2016
Report revised following feedback

Final As submitted 7 July 2016
on the Draft Final Report
Further minor revisions to improve

Final V2 28 July 2016
presentation
Disclaimer
The content of this report does not necessarily reflect the official opinion of the
European Commission as an institution. The European Commission does not
guarantee the complete accuracy of the assessment presented herein. Neither
the Commission nor any person acting on its behalf is responsible for the use
which might be made of the following information. Responsibility for the
information and views expressed therein lies entirely with the authors.
Recommended citation
RPA (2016): Analysis of responses to the Open Public Consultation on the

proposal for a mandatory Transparency Register, Final Report, report for
Secretariat-General, European Commission, July 2016, Loddon, Norfolk, UK
Executive Summary
The Commission held an open public consultation on a proposal for a mandatory Transparency
Register covering the European Parliament, the Council of the European Union and the European
Commission from 1 March 2016 to 1 June 2016.
The objectives of the open public consultation were twofold:
(1) to gather views on the functioning of the current Transparency Register; and
(2) to receive input for the design of the future mandatory regime of registration announced in
President Juncker's Political Guidelines1.
With 975 valid responses from individuals and 783 valid responses from organisations (including 620
from ‘registered’ organisations) and responses from all EU-28 Member States as well as from non-EU
countries, the consultation is considered to have been a success in reaching interested stakeholders.
Within these 1758 responses, there were some co-ordinated campaigns. The larger campaigns were
from sub-national authorities in Austria and Germany and from individuals and organisations
supporting the ALTER-EU campaign. For the Austrian and German sub-national authorities, the
overarching theme is that local and regional authorities act on behalf of, and are directly
accountable to, the people they represent. As such, they (and their associations) should be excluded
from the Transparency Register. On the other hand, the ALTER-EU campaign considers that the
Transparency Register needs to be expanded and strengthened.
Once the 106 campaign responses had been carefully considered, attention was focused on the
remaining 1652 responses.
There was widespread agreement across all respondents that ethical and transparent lobbying helps
policy development and that the Register represents a useful tool for regulating lobbying. Although
respondents from registered and unregistered organisations generally considered that European
institutions as public institutions are ‘relatively transparent’, this view was not shared by all
individuals.
There was widespread support for the current definition of activities covered by the Register.
However, there was a sharp divergence between individuals, most of whom wanted to broaden the
scope of the Register, and unregistered organisations, most of whom wanted to exclude particular
types of organisations. Responses from registered organisations were between these two extremes.
The current (voluntary) Register represents an online database of interest representatives.

Registered organisations were generally most positive about the website while individuals were least
positive. The highest rated aspects were the website’s ‘design and structure’ and ‘ease of search
function’. The two lowest rated aspects related to ‘accessibility’ and ‘access via mobile phones’
although most respondents (over 50% in each stakeholder group) offered ‘no opinion’ on these
aspects.
More detailed questions addressed various operational aspects of the Register and these were
answered, mainly, by registered organisations. Registered organisations did not generally encounter
any difficulties with the categorisation of organisations by section and sub-section on the Register.
However, a substantial portion of unregistered organisations claimed to have encountered
difficulties. Various suggestions were provided to rationalise and refine some of the categorisations.
1
http://ec.europa.eu/priorities/publications/president-junckers-political-guidelines_en
Analysis of responses to the Open Public Consultation on the proposal for a mandatory Transparency Register
RPA | i
In general terms, there was broad satisfaction with the existing situation relating to data disclosure
and quality and the variation in responses was similar across the different stakeholder groups.
However, further examination indicated that, although most registered organisations are content
with the status quo, there are views that too little information is being requested particularly
amongst NGOs whilst at the other end, there are many who think that too much information is being
requested particularly amongst business actors, trade associations and sub-national authorities.
Furthermore, some respondents were very critical of the data quality.
In any event, there were calls for more guidance to assist registrants to provide the right information
as well as extra checks (manual or automatic) to improve the quality of the data being entered onto
the Register. It was considered that such measures would reduce inadvertent mistakes. There were
also calls for varying levels of information to be provided depending upon the nature and extent of
the organisation’s lobbying activities. Some respondents acknowledged that further resources for
the Register’s secretariat would be required to better monitor the Register content.
While there is general support for the existing code of conduct and procedure for dealing with alerts
and complaints, there is strong support for publishing names of suspended organisations
(particularly amongst individual respondents). Further analysis of the results for registered
organisations indicated that there was some opposition to such publication amongst all sections of
the Register with least opposition from NGOs.
Respondents were asked about the ease of using the Register website. Although most registered
organisations indicated that the processes were straightforward, more than a third thought they
were ‘satisfactory but can be improved’. Similar figures emerged from the other main stakeholder
groups.
The European Parliament and the European Commission currently offer certain practical advantages
(incentives) linked to being on the Register. In relation to the European Parliament, respondents
identified the most important advantage of registration to be associated with the opportunity to
gain access to Parliament buildings.
In relation to the Commission, respondents identified the most important advantage of registration
to be associated with the opportunity to hold meetings with Commissioners, Cabinet members and
Directors-General. The second most important advantage was seen as the ability to be appointed to
expert groups.
For the future, there was general support for further interactions between the EU institutions and
interest groups to be conditional upon prior registration and strong support for the Commission's
view that the Council of the EU should participate in the new Interinstitutional Agreement on a
mandatory register.
RPA | ii
Table of contents
Executive Summary ……………………………………………………………………………………………………………… i
1 Introduction ......................................................................................................................... 1
2 Number and Type of Responses Received.............................................................................. 2

2.1 Reponses received .......................................................................................................................... 2
2.2 Responses from individuals ............................................................................................................ 3
2.3 Responses from organisations........................................................................................................ 3
2.4 Responses by language ................................................................................................................... 4
3 Methodology of the Study .................................................................................................... 6

3.1 Introduction .................................................................................................................................... 6
3.2 Step 1: Obtain raw data ................................................................................................................. 6
3.3 Step 2: Data cleaning ..................................................................................................................... 6
3.4 Step 3: Identify and segregate major campaigns........................................................................... 9
3.5 Step 4: Analysis of closed questions ............................................................................................10
3.6 Step 5: Analysis of open questions ..............................................................................................11
3.7 Step 6: Reporting ..........................................................................................................................13
4 Campaigns.......................................................................................................................... 14
4.1 Overview .......................................................................................................................................14
4.2 Campaigns 1 and 2 ........................................................................................................................14
4.3 Campaign 3 – Part A questions .....................................................................................................16
4.4 Campaign 3 – Part B questions .....................................................................................................18
5 Analysis of Part A Questions ............................................................................................... 21

5.1 Introduction ..................................................................................................................................21
5.2 Transparency and the EU (Qns 1.1a, 1.1b, 1.1c, 1.2)....................................................................21
5.3 Scope of the Register (Qns 2.1, 2.2)..............................................................................................40
5.4 Register website (Qns 3.1) ............................................................................................................49
5.5 Additional comments (Qn 4 and additional files) .........................................................................53
RPA | iii
6 Analysis of Part B Questions................................................................................................ 59
6.1 Introduction ..................................................................................................................................59
6.2 Structure of the Register (Qn B1.1)...............................................................................................59
6.3 Data disclosure and quality (Qns B2.1, B2.2, B2.3, B2.4)..............................................................63
6.4 Code of conduct and procedure for alerts and complaints (Qns B3.1, B3.2a, B3.2b) ..................75
6.5 Register website – registration and updating (Qn B4.1)...............................................................83
6.6 Current advantages linked to registration (Qn B5.1)....................................................................86
6.7 Features of a future mandatory system (Qns B6.1, B6.2) ............................................................90
6.8 Looking beyond Brussels (Qn B7.1)...............................................................................................97
6.9 Additional comments..................................................................................................................101
Annex 1: The Questionnaire

Annex 2: Summary of Campaign Responses
RPA | iv
1 Introduction
The Commission held an open public consultation on a proposal for a mandatory Transparency
Register covering the European Parliament, the Council of the European Union and the European
Commission from 1 March 2016 to 1 June 2016.2
Following a series of questions to characterise the respondent, this open public consultation
comprised two parts: Part A General and Part B Specific. Part A was mandatory for all respondents
and contained seven questions while Part B was optional and contained 13 questions. All questions
involved both a ‘closed’ element (answered by ticking a box) and, optionally, an ‘open’ text box to
provide further comments3. The full questionnaire is presented in Annex 1.
The objectives of the open public consultation were twofold:
(1) to gather views on the functioning of the current Transparency Register; and
(2) to receive input for the design of the future mandatory regime of registration announced in
President Juncker's Political Guidelines4.
The Commission therefore essentially aimed to assess and understand what has worked well so far,
and what can be improved and how, in order to ensure that the Register fulfils its full potential as a
meaningful tool governing relations between the EU institutions and interest representatives.
The Commission contracted Risk & Policy Analysts to provide support for this open public
consultation exercise with particular regard to the analysis of the results.
2
Accessible via the dedicated webpage:
http://ec.europa.eu/transparency/civil_society/public_consultation_en.htm as well as via the portal Your
Voice in Europe: http://ec.europa.eu/yourvoice/index_en.htm
3
Each open text box had a 3,000 character limit which is equivalent to about 500 words or a page of A4
typed text.
4
http://ec.europa.eu/priorities/publications/president-junckers-political-guidelines_en
Analysis of responses to the OPC on the proposal for a mandatory Transparency Register
RPA | 1
2 Number and Type of Responses Received
2.1 Reponses received
During the course of this open public consultation (OPC), the Commission monitored the rate of
responses by main stakeholder group (citizens, organisations registered on the Transparency
Register and organisations not registered on the Transparency Register5) and the results are
summarised in Figure 2-1. It is apparent that there were two phases in the responses with a large
number of responses being received in the first few weeks with a second burst of activity starting in
Week 9 (week commencing 2 May 2016). This was probably due to the publicity for and interest in a
public debate event organised by the European Parliament and the Commission which was held in
Brussels on 2 May 20166.
1800
1600
1400
Number of responses
1200
1000
800
600
400
200
0
0 1 2 3 4 5 6 7 8 9 10 11 12 13
Week
TOTAL Citizens
Registered organisations Unregistered organisations
Figure 2-1: Numbers of responses received by week (from 1 March to 1 June 2016)
With over 1,750 responses received from across the EU-28 and a few from further afield, the
consultation is considered to have been a success in reaching interested stakeholders7.
5
In this report, these are referred to as ‘registered’ and ‘unregistered’ organisations respectively
6
http://ec.europa.eu/transparencyregister/public/staticPage/displayStaticPage.do?reference=
NEWS&locale=en
7
Of note is that many OPCs run by the Commission typically attract a few hundred responses so this OPC has
attracted particular interest amongst stakeholders
RPA | 2
2.2 Responses from individuals
Individual respondents were asked to nominate their country of residence. 961 responses were
received from across all EU-28 Member States as well as a further 14 from other countries.
Table 2-1: Responses from individuals by country of residence

Country Number* % Total
Austria 33 3.4%
Belgium 92 9.4%
Bulgaria 8 0.8%
Croatia 3 0.3%
Cyprus 5 0.5%
Czech Republic 3 0.3%
Denmark 17 1.7%
Estonia 2 0.2%
Finland 5 0.5%
France 128 13.1%
Germany 186 19.1%
Greece 27 2.8%
Hungary 3 0.3%
Ireland 26 2.7%
Italy 84 8.6%
Latvia 3 0.3%
Lithuania 4 0.4%
Luxembourg 6 0.6%
Malta 1 0.1%
Netherlands 76 7.8%
Poland 32 3.3%
Portugal 17 1.7%
Romania 10 1.0%
Slovak Republic 3 0.3%
Slovenia 5 0.5%
Spain 49 5.0%
Sweden 21 2.2%
United Kingdom 112 11.5%
Other country 14 1.4%
Totals 975 100%
* Note that these are the numbers of respondents after a few entries had been removed during data cleaning
as described in the next section
2.3 Responses from organisations

For responses from organisations, respondents were asked to nominate where their organisation
was based. 748 responses were received from across all EU-28 Member States (except Lithuania
and Malta) as well as a further 35 from other countries.
RPA | 3
Table 2-2: Responses from organisations by country
Country Number* % Total
Austria 54 5.5%
Belgium 189 19.4%
Bulgaria 2 0.2%
Croatia 6 0.6%
Cyprus 1 0.1%
Czech Republic 7 0.7%
Denmark 14 1.4%
Estonia 2 0.2%
Finland 4 0.4%
France 73 7.5%
Germany 161 16.5%
Greece 4 0.4%
Hungary 2 0.2%
Ireland 7 0.7%
Italy 48 4.9%
Latvia 1 0.1%
Lithuania 0 0.0%
Luxembourg 6 0.6%
Malta 0 0.0%
Netherlands 26 2.7%
Poland 5 0.5%
Portugal 10 1.0%
Romania 14 1.4%
Slovak Republic 3 0.3%
Slovenia 4 0.4%
Spain 54 5.5%
Sweden 8 0.8%
United Kingdom 43 4.4%
Other country 35 3.6%
Totals 783 100.0%
2.4 Responses by language

The questionnaire was offered in all official EU languages. Although 60% of respondents opted for
the English version, respondents used the questionnaires in another 19 languages as listed in Table
2-3. It is worth noting that some respondents provided responses to the open text questions in a
different language from that of the questionnaire.
RPA | 4
Table 2-3: Responses by language of questionnaire
Language Number* % Total
English 1067 60.7%
German 321 18.3%
French 163 9.3%
Italian 64 3.6%
Spanish 46 2.6%
Polish 29 1.6%
Dutch 15 0.9%
Portuguese 9 0.5%
Slovenian 7 0.4%
Greek 6 0.3%
Danish 5 0.3%
Finnish 5 0.3%
Romanian 5 0.3%
Bulgarian 4 0.2%
Czech 4 0.2%
Croatian 2 0.1%
Slovak 2 0.1%
Swedish 2 0.1%
Hungarian 1 0.1%
Latvian 1 0.1%
Totals 1758 100.0%
RPA | 5
3 Methodology of the Study
3.1 Introduction
The work involved six main steps:
 Step 1: Obtain raw data

 Step 2: Data cleaning
 Step 3: Identify and segregate major campaigns
 Step 4: Analysis of closed questions
 Step 5: Analysis of open questions
 Step 6: Reporting
3.2 Step 1: Obtain raw data
After the closure of the consultation the Commission provided the consultants with a complete set
of responses in a single Excel data file.
3.3 Step 2: Data cleaning

3.3.1 Unique identifiers
Every record was given a unique identifier from 5 (the earliest submission) to 1770 (the most recent
submission) to match the row numbers on the original Excel data file.
3.3.2 Removal of late submissions

The creation dates on the records were checked to ensure that all responses were received within
the prescribed timeframe. The first two responses were seen to be final testing submissions prior to
the public launch on 1 June 2016 and were therefore removed from further analysis.
3.3.3 Duplicates
The next step was to check for multiple identical responses across all data fields (except the unique
identifier and creation date). Four duplicates were removed. In each case, there were two
submissions within several minutes of each other suggesting that the respondent had been unsure
as to whether the first submission had been successful.
Further inspection of entries from the same person/organisation was undertaken. Although several
pairs of varying responses from the same email accounts were identified, these could be attributed
to colleagues, partners or friends and were therefore retained. In two cases, entries were identical
except for the last question relating to whether the response could be published. In these cases, the
two earlier submissions were deleted.
RPA | 6
3.3.4 Summary
Overview
The data carried forward for further analysis are summarised in Table 3-1.
Table 3-1: Summary of responses taken forward

I agree to my I do not agree to
contribution my contribution Total
Nature of Respondent being published being published
An individual in my personal capacity 739 236 975
The representative of an organisation
530 90 620
registered in the Transparency Register
The representative of an organisation not
111 52 163
Totals 1380 378 1758
Where the respondent agreed to having their contribution published, it has been published by the
Commission with access from the previously mentioned consultation webpage8.
Of those that did not wish to see their responses published, some provided a reason as summarised
in Table 3-2. A listing of the reasons was provided to the Commission.
Table 3-2: Justification provided for requesting that contributions not be published
I do not agree to % providing
Justification
Nature of Respondent my contribution justification for
provided
being published non-publication
An individual in my personal capacity 236 80 34%
90 19 21%
52 5 10%
Totals 378 104 28%
Individuals
As previously indicated (see Table 2-1), responses were received from 961 individuals resident across
all EU-28 countries and from a further 14 individuals in other countries. Over 60% of the responses
were received from five countries: Germany (19.1%), France (13.1%), United Kingdom (11.5%),
Belgium (9.4%) and Italy (8.6%).
Organisations
In relation to the 783 organisations which responded, they were self-characterised as shown in Table
3-3.
8
http://ec.europa.eu/transparency/civil_society/public_consultation_en.htm
RPA | 7
Table 3-3: Typology of organisations (by Register Section* and whether already registered)
in the not in the
Transparency Transparency Total
Nature of Organisation Register Register
Section I: Professional consultancies/law firms/self-
66 7 73
employed consultants
 Professional consultancies 46 6 52
 Law-firms 8 0 8
 Self-employed consultants 12 1 13
Section II: In-house lobbyists and
333 16 349
trade/business/professional associations
 Companies and groups 85 7 92
 Trade and business associations 159 3 162
 Trade unions and professional associations 74 5 79
 Other organisations 15 1 16
Section III: Non-governmental organisations, platforms,
networks, ad-hoc coalitions, temporary structures and 162 19 181
other similar organisations
Section IV: Think tanks, research and academic
23 3 26
institutions
 Think tanks and research institutions 13 3 16
 Academic institutions 10 0 10
Section V: Organisations representing churches and
6 0 6
religious communities
Section VI: Organisations representing local, regional and
30 118 148
municipal authorities, other public or mixed entities, etc.
 Regional structures 5 11 16
 Other sub-national public authorities 4 94 98
 Transnational associations and networks of public
9 2 11
regional or other sub-national authorities
 Other public or mixed entities, created by law
12 11 23
whose purpose is to act in the public interest
Totals 620 163 783
* Details of membership of the Transparency Register by section may be found here:
http://ec.europa.eu/transparencyregister/public/homePage.do?redir=false&locale=en
As previously indicated (see Table 2-2), responses were received from 748 organisations across 26 of
the EU-28 Member States, as well as from a further 35 organisations in other countries – resulting in
a total of 783 responses. Nearly 20% of the responses (189) were received from organisations
based in Belgium. The next countries with the greatest numbers of responses were Germany (161),
France (73), Spain (54), Austria (54), Italy (48) and the UK (43).
RPA | 8
3.4 Step 3: Identify and segregate major campaigns
3.4.1 Introduction
The next step was to identify ‘campaign’ responses in which identical responses are submitted by
multiple respondents as part of a co-ordinated campaign. By inspection of the Excel sheets, it was
immediately apparent that campaigns were probably present due to similar answers for both closed
and open questions within particular stakeholder groups.
Further work on identifying the campaigns involved three methods:
 web searches to identify any on-line (including social media) campaigns;

 use of STATA to identify duplicate responses to the substantive (closed) questions (i.e. not
including the ‘respondent profile questions’); and
 identification of repeated comments in the ‘open’ (comment) questions (by inspection and/or
use of NVivo software).
3.4.2 Presence of campaigns

Prior to closure of the consultation, RPA undertook some online research to determine whether
there were active campaigns to promote particular sets of responses. Of course, it was noted that
the Commission had also actively promoted participation in the consultation including the public
debate event already referred to (see Section 2.1 above).
The most noticeable campaign was organised by the Alliance for Lobbying Transparency and Ethics
Regulation (ALTER-EU) which provided suggested responses to both closed and open questions9.
A number of other organisations and individuals publicised their responses and encouraged others
to participate including Transport & Environment10, European Movement International11, Democracy
International12 and The Risk Monger13.
3.4.3 Closed questions

Analysis of closed questions in the cleaned data set using STATA revealed two ‘campaigns’, one with
17 responses and one with 14 responses14. In this context, campaigns are defined as those
9
http://alter-eu.org/sites/default/files/documents/ALTER-EU%20EUTR%20TEMPLATE%20FINAL_0.pdf
10
https://www.transportenvironment.org/publications/public-consultation-proposal-mandatory-
transparency-register
11
http://europeanmovement.eu/european-movement-position-on-the-transparency-register/
12
Note that this NGO is different from Transparency International but also supports the Alter-EU campaign,
see: https://www.democracy-international.org/eu-transparency
13
http://risk-monger.blogactiv.eu/2016/04/03/the-risk-mongers-submission-to-the-eu-transparency-
register-consultation/
14
This was done across both Part A responses and all (i.e. Part A and Part B) responses.
RPA | 9
producing 10 or more identical sets of responses across the substantive questions. For over 1750
responses, this represents a campaign threshold of 0.6% of responses.
The identified campaigns both involved local authorities from Austria and Germany which responded
to Part A of the questionnaire. Further examination revealed duplicate entries in many of the open
comments from a further 26 local authorities from Austria and Germany which also had very similar
answers to the closed questions.
In total there were 32 responses from Campaign 1 (involving 28 German and 4 Austrian local
authorities) and 25 responses from Campaign 2 (involving a further 25 Austrian local authorities).
The responses to both campaigns are summarised in Annex 2A. As can be seen from the results, the
positions of both campaigns support the intentions of the Transparency Register but there are areas
requiring refinement – particularly in relation to what kinds of organisations should or should not be
included.
3.4.4 Open questions

Taking some key phrases from the suggested ALTER-EU responses (as well as some more general
searches on NVivo) allowed 49 respondents (37 individuals and 12 organisations) to open questions
to be directly linked to this campaign. It is, however, highly likely that more responses (particularly
amongst individuals) were influenced by this campaign. Key phrases looked for were:
Qn 1.1a ….lobbying is more than just the lobby register….
Qn 1.1b Stopping the privileged access by business interests…
Qn 2.2 There is no rationale for their exclusion…
Qn 4 Further important changes…
Qn 4 Lobby rules should apply also to the European Council
Of the 49 respondents to Part A, 11 organisations and one individual proceeded to Part B.
Sample responses are presented in Annex 2A (Part A) and Annex 2B (Part B). As might be expected,
the ALTER-EU campaign is seeking a stronger Transparency Register.
In summary, these 106 responses were segregated from the main data set and will be reported on
separately. The remaining 1652 responses will be carried forward for further analysis.
3.5 Step 4: Analysis of closed questions

For the closed questions we used basic analysis to provide summary data for all closed questions
against different types of stakeholder:
 individuals vs registered organisations (i.e. organisations on the Transparency Register) vs

unregistered organisations (i.e. organisations not on the Transparency Register); and
 type of organisation (as classified by the six main sections on the existing register).
RPA | 10
3.6 Step 5: Analysis of open questions
3.6.1 Sample size
The table below summarises the numbers of open text responses by question and respondent as
well as the associated sample size based on the expression √N +2, where N = number of open text
responses to a particular question.
(1)
Table 3-4: Summary of samples of text boxes to be read/analysed
(3)
Range in number Range in suggested Total text boxes
Nature of (2)
Text boxes of responses per sample size per to be read/
respondents
text box text box analysed
Part A – 8 open text Individuals 172 to 665 15 to 28 156
boxes Organisations 131 to 371 13 to 21 136
Part B – 14 open Individuals 14 to 39 6 to 8 101
text boxes Organisations 54 to 159 9 to 15 170
Notes:
(1) Note that these are based on the 1652 responses remaining after segregation of the campaign responses
(2) Sample size based on √N +2, so if there were 144 text box responses to a particular question, N = 144 and
√N = 12. As such, the sample size would then 12 + 2 = 14
(3) Actual number of text boxes to read and analysed based on sample sizes for each and every open text box
The total number of text boxes which were read (in the language provided), analysed and recorded
was over 550.
To ensure that a range of informed views were considered, particular attention was given to those
organisations which have been particularly active in the debate around lobbying transparency in the
recent past as well as representing the views of organisations from different sections of the Register.
Such organisations were to be found on the participants list of the joint European Parliament and
Commission EU Lobbying Transparency public event held on 2 May 2016 in Brussels. This led to a list
of 25 entities, most of which followed the public debate, as listed in Table 3-5 (overleaf).
Of these 25 entities (hereafter referred to as ‘Tier 1 organisations’), 24 provided responses to the

online questionnaire while the 25th entity (a European Ombudsman) provided a separate written
submission. By inspection, the Tier 1 organisations provided 10–21 responses (or related comment
in the case of the European Ombudsman) to each text box in Part A and 8–14 responses (or related
comment in the case of the European Ombudsman) to each text box in Part B. To provide a means
to ensure that the range of informed opinions was captured at an early stage, 75% of the samples
(for organisations) were taken from the Tier 1 responses15. The remaining 25% of the sample was
taken from responses from non-Tier 1 organisations.
This sampling led to the generation of a number of themes emerging from the text boxes. This
process was repeated across samples of text box responses from individuals. Although many of the
identified themes were repeated, there were additional themes identified.
15
This is referred to as ‘purposive sampling’.
RPA | 11
Table 3-5: List of 25 Tier 1 organisations (with details taken from OPC responses)
Name of the organisation: Organisation belongs to the following type:
European Public Affairs Consultancies’ Association
(EPACA) Trade and business associations
BUSINESSEUROPE (corresponding to Section II of the Register*)
EuroCommerce A.I.S.B.L.
Society of European Affairs Professionals (SEAP)
Council of Bars and Law Societies of Europe Trade unions and professional associations
(CCBE) (corresponding to Section II of the Register)
European Trade Union Organisation (ETUC)
European Centre of Employers and Enterprises
providing Public Services and Services of General
Interest (CEEP)
Non-governmental organisations, platforms,
Bureau Européen des Unions de Consommateurs
networks, ad-hoc coalitions, temporary structures
(BEUC)
and other similar organisations
Civil Society Europe
(corresponding to Section III of the Register)
Transparency International (TI)
Alliance for Lobbying Transparency and Ethics
Regulation (ALTER-EU)
Anonymous
Think tanks and research institutions
the International Center for Strategic Studies and
(corresponding to Section IV of the Register)
Human Rights
Konferenz Europäischer Kirchen Organisations representing churches and religious
Secretariat of Commission of the Episcopates of communities
the European Community (COMECE) (corresponding to Section V of the Register)
Anonymous Other public or mixed entities, created by law
whose purpose is to act in the public interest
Bayerische Staatsregierung
(corresponding to Section VI of the Register)
Convention of Scottish Local Authorities (COSLA) Other sub-national public authorities
Region Hannover (corresponding to Section VI of the Register)
Scottish Local Government Partnership
Transnational associations and networks of public
Council of European Municipalities and Regions
regional or other sub-national authorities
(CEMR)
(corresponding to Section VI of the Register)
EUROCITIES
European Ombudsman
Greens/EFA group in the European Parliament
Other entities outside the scope of the Register
EP intergroup on Integrity, Transparency,
Corruption and Organised crime (ITCO)
*Organisations on the Register are categorised by Section:
I. Law firms; professional consultancies; self-employed consultants
II. Trade and business associations; trade unions and professional associations
III. Non-governmental organisations, platforms, networks, ad-hoc coalitions, temporary structures and
other similar organisations
IV. Think tanks and research institutions
V. Organisations representing churches and religious communities
VI. Other public or mixed entities, created by law whose purpose is to act in the public interest;
transnational associations and networks of public regional or other sub-national authorities
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3.6.2 NVivo analysis
NVivo was used to check that the sampling process had not missed other key themes. For each of
the main languages for each text box, we:
 undertook a word frequency search to identify the most popular words;

 selected 25 words of interest (based on our work on the most appropriate approach to analysis);
and
 explored the context of the words using text search queries.
NVivo can provide a general, high level overview of all responses based on the connections between
key words and the frequency of words. This can be visualised in several ways including word clouds
and word trees – and an example related to the ALTER-EU campaign is presented below.
Figure 3-1: Example of a word tree highlighting the ALTER-EU campaign
3.6.3 Comment
There is a risk with the sampling that some detailed and, potentially useful, suggestions have been
missed. While the combination of the sampling approach with the NVivo approach should help to
reduce this possibility, there may still be further useful insights to be gleaned from the OPC results.
However, the level of response to this OPC has made it impossible to enable every open-ended
response to be reviewed in detail within the time and resource constraints for this study.
3.7 Step 6: Reporting

The results of the analysis of the campaigns are presented in Section 3 with analysis of the other
responses presented in Section 4 for the Part A questions and in Section 5 for the Part B questions.
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4 Campaigns
4.1 Overview
There were three main campaigns identified amongst the responses to the consultation. In this
context the threshold for a campaign has been set at 10 responses for (near) identical responses
across all ‘closed’ and/or ‘open’ questions. As will become clear, smaller groups of co-ordinated
responses from other stakeholders were also seen but these responses have been considered
alongside the non-campaign responses analysed in Sections 5 and 6.
The three main campaigns are summarised in Table 4-1 and are outlined further below.
Table 4-1: Summary of campaign responses

Number of Number of
Campaign Nature of respondents
responses to Part A responses to Part B
1 – German sub-national
Unregistered Organisations (VI*) 32 0
authorities
2 – Austrian sub-national
Unregistered Organisations (VI*) 25 0
authorities
Individuals 37 0
3 – ALTER-EU Registered Organisations (III*) 11 11
Unregistered Organisations (III*) 1 0
*Organisations on the Register are categorised by Section:
III. Non-governmental organisations, platforms, networks, ad-hoc coalitions, temporary structures and other
similar organisations
VI. Other public or mixed entities, created by law whose purpose is to act in the public interest; transnational
associations and networks of public regional or other sub-national authorities
4.2 Campaigns 1 and 2

4.2.1 Introduction
Over 100 sub-national authorities from Austria and Germany provided responses to the
consultation. Within this group, two similar campaigns were identified and the associated 57
responses are considered here. It is, of course, recognised that many of the other responses from
this group will have been influenced by these campaigns.
The overarching theme is that local and regional authorities act on behalf of, and are directly
accountable to, the people they represent. As such, they (and their associations) should be excluded
from the scope of the Register.
The responses to individual questions are presented in Annex 2 and the main points are briefly
summarised here.
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4.2.2 Transparency and the EU (Qns 1.1a, 1.1b, 1.1c, 1.2)
Both campaigns agreed that ethical and transparent lobbying helps policy development (Qn 1.1a).
Although Campaign 1 (Germany) respondents thought that the Register was somewhat useful for
regulating lobbying, Campaign 2 (Austria) respondents thought that the Register was not useful (Qn
1.2). Both campaigns agreed that European institutions as public institutions are ‘relatively
transparent’ (Qn 1.1c).
After ‘transparency’, Campaign 1 (Germany) respondents thought that ‘integrity’ was important
while Campaign 2 (Austria) respondents thought both ‘integrity’ and ‘equality of access’ were
important (Qn 1.1b).
4.2.3 Scope of the Register (Qns 2.1, 2.2)

Although Campaign 1 (Germany) respondents ‘partially agreed’ with the definition of what activities
should be covered by the Register, Campaign 2 (Austria) respondents ‘disagreed’ (Qn 2.1).
Campaign 1 respondents highlighted the need for a more precise definition but one that should
exclude, for example, MEP campaign events and information events at the Commission. Campaign 2
respondents highlighted the need to focus on those activities where ‘influence’ can be identified.
Both campaigns agreed that the Register should exclude certain types of entities (Qn 2.2) with
particular reference to local and regional authorities and their associations.
4.2.4 Register website (Qns 3.1)

Views from both campaigns are summarised below.
Table 4-2: Main views on the Register website (Qn 3.1)

Aspect of website Campaign 1 (Germany) Campaign 2 (Austria)
Design and structure Average Good
Availability of information / documents Average Average
Ease of search function No opinion No opinion
Accessibility (e.g. features for visually
Good No opinion
impaired persons, ease of reading page)
Access via mobile devices No opinion No opinion
4.2.5 Submitted documents

Six of the Campaign 2 (Austria) respondents submitted additional documents as summarised in the
table below which reiterated their position that local and regional authorities and their associations
should be excluded from the Register.
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Table 4-3: Summary of attached documents from Campaign 2 respondents
Document name Description
Common European Day (European Affairs Committees of the German
Association of Towns and Municipalities and the Austrian community
Ramsau im Zillertal Declaration
nationwide) position on local and regional authorities, 1 page.
(4 submissions)
German Federation of municipal associations: concerns that
Wildschönau Municipalities and their associations should be excluded, 3 pages
(2 submissions)
4.3 Campaign 3 – Part A questions

4.3.1 Introduction
The ALTER-EU campaign published a detailed commentary16 on all questions with the suggestion
that: ‘all participants in the consultation will want to complete all questions according to their own
views and experiences, but hopefully this briefing provides some useful suggestions for input. There
are also links to further information which you might find useful’.
49 responses could be readily associated with this template comprising responses from 37
individuals and 12 non-governmental organisations (11 of which were registered). As for the other
campaigns, it is recognised that other responses will have been influenced by this campaign.
The overarching theme is that the role of the Transparency Register needs to be expanded and
strengthened. The responses to individual questions are presented in Annex 2 and the main points
are briefly summarised here.
4.3.2 Transparency and the EU (Qns 1.1a, 1.1b, 1.1c, 1.2)

Campaign 3 respondents agreed (fully or partially) that ethical and transparent lobbying helps policy
development (Qn 1.1a). Campaign 3 respondents thought that the Register was ‘somewhat useful’
for regulating lobbying (Qn 1.2). Although some respondents considered that European institutions
as public institutions could be seen as ‘relatively transparent’, the majority expressed ‘no opinion’
and five individuals considered that they are ‘not transparent’ (Qn 1.1c).
After ‘transparency’, some Campaign 3 respondents thought that ‘integrity’ and/or ‘equality of
access’ were important (Qn 1.1b). However, most stressed ‘other’ principles including:
 transparent lobbying does not equate to ethical lobbying;

 privileged/unequal access by business lobbies should be limited;
 account must be taken of the imbalance between lobbying resources between private and public
interests;
 public interests must ultimately prevail;
 lobbying on behalf of oppressive regimes should be prevented; and
 no ‘gifts’ from lobbyists to officials.
16
http://alter-eu.org/sites/default/files/documents/ALTER-EU%20EUTR%20TEMPLATE%20FINAL_0.pdf
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4.3.3 Scope of the Register (Qns 2.1, 2.2)
Campaign 3 respondents generally ‘fully agreed’ with the definition of what activities should be
covered by the Register (Qn 2.1).
Campaign 3 respondents would like the Register extended to cover all actors that have an impact on
EU decision-making. As such, many of the current exemptions (churches and religious communities,
political parties, Member States' government services, third countries' governments, international
intergovernmental organisations and their diplomatic missions, regional public authorities and their
representative offices, etc.) should be withdrawn (Qn 2.2).
4.3.4 Register website (Qns 3.1)

Views on the Register website from Campaign respondents are summarised below.
Table 4-4: Main views on the Register website from Campaign 3 respondents (Qn 3.1)
Aspect of website Individuals (n=37) Organisations (n=12)
Average (n=18) Average (n=7)
Design and structure
Good (n=15) Good (n=2)
Availability of information/documents
Good (n=8) Poor (n=4)
Ease of search function
No opinion (n=7) Poor (n=4)
Accessibility (e.g. features for visually No opinion (n=26) No opinion (n=5)
impaired persons, ease of reading page) Average (n=7) Good (n=4)
No opinion (n=30) No opinion (n=7)
Access via mobile devices

One Campaign 3 respondent from a registered organisation attached a document as summarised
below.
Table 4-5: Summary of attached documents from a Campaign 3 respondent

Document name Description
Lobbying a risk or opportunity, Lobbying regulation from the Slovak,
Polish and Czech perspective. In particular, it outlines
Lobbying a risk or an opportunity
recommendations for a register of lobbyists, its regulation and sanctions
for wrong doing, 46 pages.
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4.4 Campaign 3 – Part B questions
4.4.1 Introduction
The 11 registered organisations which responded as part of Campaign 3 proceeded to answer the
Part B questions17.
As for the Part A questions, the recurring theme is that the role of the transparency register needs to
be expanded and strengthened but the responses are tempered by reflections on practical
experiences of using the Register (which is more the focus of the Part B questions).
4.4.2 Structure of the Register (Qn B1.1)

Most of the Campaign 3 respondents have encountered difficulties with the categorisation of
organisations on the Register and call for clearer titles/descriptions.
4.4.3 Data disclosure and quality (Qns B2.1, B2.2, B2.3, B2.4)
While the Campaign 3 respondents agree (fully or partially) that it is easy to provide the information
required (Qn B2.2) and that there should be no simplification as regards the data disclosure
requirements (Qn B2.3), too little information is asked (Qn B2.1) and the overall data quality in the
Register is poor (Qn 2.4).
Detailed suggestions focus on improving the existing system through improved guidance (to reduce
inadvertent mistakes) and improved checking of data (which may require additional staff for the
Register’s secretariat) as well as requesting further detail to be provided on lobbying activities and
associated funding amounts and sources.
4.4.4 Code of conduct and procedure for alerts and complaints (Qns B3.1,
B3.2a, B3.2b)
The Campaign 3 respondents take a very robust position on alerts and complaints. While they
‘partially agree’ that the Code of Conduct is based on a sound set of rules and principles (Qn B3.1),
they ‘disagree’ with the view the present procedure for dealing with alerts and complaints is
adequate (Qn B3.2a) and think that the names of organisations that are suspended under the alerts
and complaints should be made public (Qn B3.2b).
Specific suggestions to improve the Code of Conduct include:
 definition of 'inappropriate behaviour' needs to be clarified;

 should prohibit representation by private firms of regimes in breach of human rights;
 should prohibit representation by private firms of the tobacco industry; and
 effective use should be made of sanctions.
17
One individual also provided responses to Part B along the lines suggested by the ALTER-EU template and
so provide no added information to that provided by the responses from the organisations considered
here.
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4.4.5 Register website – registration and updating (Qn B4.1)
Most Campaign 3 respondents thought that the processes for registration and updating on the
website were ‘satisfactory but can be improved’. It was suggested that the processes might be
enhanced though some additional software to warn of possible errors (for example, by providing a
simple logic check on the data being entered).
4.4.6 Current advantages linked to registration (Qn B5.1)

(incentives) linked to being on the Register.
Respondents were invited to comment which of these advantages were considered important. The
Campaign 3 respondents generally thought that these advantages were very important. The
advantages were ranked as shown below and, for comparison; the results are compared with those
derived from other registered organisations which responded to this question (as discussed in
Section 5.6.1).
Table 4-6: Ranking of the importance of advantages granted to registered organisations based on
responses from Campaign 3 respondents and from other registered organisations
Other registered
Campaign 3
organisations
(n = 11)
Advantage granted to registered organisations (n = 484)
In the European Parliament (EP)
Access to Parliament buildings: long-term access passes to the EP’s
premises are only issued to individuals representing, or working for 1 1
registered organisations
Committee public hearings: guests invited to speak at a hearing
3 2
need to be registered
Patronage: Parliament does not grant its patronage to relevant
2 3
organisations that are not registered
In the European Commission
Meetings: organisations or self-employed individuals engaged in
relevant activities must be registered in order to hold meetings with 1 1
Commissioners, Cabinet members and Directors-General
Expert groups: registration in the Transparency Register is required
in order for members to be appointed (refers to organisations and
2 2
individuals appointed to represent a common interest shared by
stakeholders in a particular policy area)
Public consultations: the Commission sends automatic alerts to
registered entities about consultations in areas of interest indicated
4 3
by them; it differentiates between registered and non-registered
entities when publishing the results
Patronage: Commissioners do not grant their patronage to relevant
3 4
Mailing lists: organisations featuring on any mailing lists set up to
5 5
alert them about certain Commission activities are asked to register
*Note that ranking is based on deriving a score based on a simple rating scale: Very important = 2, Somewhat
important = 1, Not important/ No opinion= 0 multiplied by the number of responses. The advantage with the
highest score was ranked 1, the second highest was ranked 2, etc.
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In relation to the European Parliament, the most important advantage (i.e. ranked number 1) was
seen as having access to Parliament buildings.
In relation to the European Commission, the most important advantage was considered to be
associated with the need to be registered in order to hold meetings with Commissioners, Cabinet
members and Directors-General. The second most important advantage was seen as the ability to
be appointed to expert groups. These views are similar to those from the other registered
organisations (as considered in detail in Section 6).
While Campaign 3 respondents noted that while such incentives may boost the number of
registrations, they do not improve the data quality.
4.4.7 Features of a future mandatory system (Qns B6.1, B6.2)

Campaigns 3 respondents fully support the suggestion for further interactions between the EU
institutions and interest groups to be conditional upon prior registration (Qn B6.1) and the
Commission's view that the Council of the EU should participate in the new Interinstitutional
Agreement on a mandatory Register (Qn B6.2).
Specific suggestions for the mandatory register include:
 registration should be a requirement for access;

 the EC's policy of not meeting unregistered lobbyists should be extended to cover all
Commission officials involved in EU legislation;
 Members of the European Parliament should list their interactions with lobby groups;
 meetings with lobbyists should be published; and
 officials should not attend events organised by non-registered lobbyists.
4.4.8 Looking beyond Brussels (Qn B7.1)

Campaign 3 respondents had no strong view on the Register in comparison to ‘lobby registers’ at
Member State level. Nevertheless, many comments were re-iterated from previous questions.
4.4.9 Additional comments

Final comments from Campaign 3 respondents stressed that further work on developing the
mandatory register should be transparent with specific mention of:
 all interinstitutional agreement preparatory meetings should be open to the public and web-
streamed;
 the draft agreement, proposed changes, agendas and minutes should be available online; and
 all EU institutions should conduct regular reviews of their transparency rules and the way that
they are implemented.
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5 Analysis of Part A Questions
5.1 Introduction
Part A of the questionnaire comprised seven questions which addressed four themes as listed below:
 Transparency and the EU (Qns 1.1a, 1.1b, 1.1c, 1.2)

 Scope of the Register (Qns 2.1, 2.2)
 Register website (Qns 3.1)
 Additional comments (Qn 4 and additional files)
These are considered in turn below.
5.2 Transparency and the EU (Qns 1.1a, 1.1b, 1.1c, 1.2)

5.2.1 Overview
There was widespread agreement that ethical and transparent lobbying helps policy development.
Registered (n=609)
Fully agree
Unregistered (n=105) Partially agree

Disagree
No opinion
Individual (n=938)
0% 20% 40% 60% 80% 100%
Figure 5-1: Qn 1.1a: Do you agree that ethical and transparent lobbying helps policy development?
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It is often said that achieving appropriate lobbying regulation is not just about transparency, i.e.
shedding light on the way in which lobbyists and policy-makers are operating. Respondents were
asked which other principles did they consider important for achieving a sound framework for
relations with interest representatives and the results are summarised below.
Table 5-1: Views on other principles (after transparency) considered important (Qn 1.1b)
Registered Unregistered
Individuals
organisations organisations
(n=938)
Principle (n = 609) (n = 105)
Integrity 83% 75% 71%
Equality of access 76% 65% 78%
Other 22% 31% 26%
No opinion 3% 10% 2%
Note: since more than one answer was possible, columns do not add up to 100%
Although respondents from registered and unregistered organisations generally considered that
European institutions as public institutions are ‘relatively transparent’, this view was not shared by
individuals as shown in the figure below.
Registered (n=609)
Highly transparent
Unregistered (n=105) Relatively transparent

Not transparent
No opinion
Individual (n=938)
0% 20% 40% 60% 80% 100%
Figure 5-2: Qn 1.1c: How transparent are the European institutions as public institutions?
There was also a widely held view that the Register was a useful tool for regulating lobbying.
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Registered (n=609)
Very useful
Individual (n=938) Somewhat useful

Not useful
No opinion
Unregistered (n=105)
0% 20% 40% 60% 80% 100%
Figure 5-3: Qn 1.2: Do you consider the Transparency Register a useful tool for regulating lobbying?
5.2.2 Views on ethical and transparent lobbying (Qn1.1a)

Summary
There were 250 responses from organisations to the open-text box associated with this question. A
total of 18 of the responses are included in the sample18.
There were 374 responses from individuals to the open-text box associated with this question. A
total of 21 of the responses are included in the sample.
Comments from organisations
There were 17 Tier 1 responses received to the open-text box associated with this question. 13 of
these responses are included in the sample. Five further comments were reviewed from other
organisations (to give a total of 18). The table below summarises the key themes that have been
extracted from these responses. The themes have been grouped to combine similar issues, to
highlight positive and negative aspects that have been raised on those issues and to draw in
suggested solutions to the negative issues. In all cases, the section(s) providing the comments is
given to enable a comparison of the responses by different types of organisation.
Table 5-2: Themes in response to Q1.1a; n=18 (By section: I = 0, II = 4, III = 6, IV = 0, V = 1, VI = 5, X =2)
Positive comments Negative comments Suggested solutions
Issue By type* Issue By type* Solution By type*
Ethical and II (3), III (4 + Ethical and transparent III (1)
transparent lobbying 2 org), V (1), lobbying needs to be
are good for policy VI (2), X (2) defined
making
18
The sample size is derived from the expression √N+2. For N = 250, √N + 2 = 15.8 + 2 = 17.8, taken as 18.
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Table 5-2: Themes in response to Q1.1a; n=18 (By section: I = 0, II = 4, III = 6, IV = 0, V = 1, VI = 5, X =2)
Transparency is the III (1) Further transparency III (3) Other EU institutions III (1)
first-step in ensuring V (1) rules are needed should adopt and apply
a level playing field in transparency rules
decision-making
Full minutes or meeting III (1)
reports should be taken
in far more meetings
Transparent lobbying III (1 org) Transparency III (1 org)
does not equate to requirements should
ethical lobbying extend to all 30,000
Commission (and agency
staff)
Lobbying brings in II (1) There should be rules III (1) Checks and balances are VI (1)
technical III (1) on the composition of needed to take account
expertise/specialist expert groups of different interests
knowledge within society
Transparency allows III (1) There needs to be a III (1) Sound independent X (1)
citizens to hold culture of civil dialogue science is fundamental
decision-makers to at all levels
account
Powerful entrenched III (1 + 1 Regulation of lobbying III (2)
interests have org), must consider equality of
unbalanced influence VI (1) opportunities of access
Interested III (1) Measures to tackle X (1)
representatives need to conflicts of interest are
disclose who finances fundamental
them (including indirect
financing)
Public authorities VI (2 + 1
cannot be equated to org)
lobbying or as
stakeholders
Public authorities VI (1) The Committee of the VI (2)
should not be in the Region (CoR) register
same register as private should be used for public
non-democratically bodies
accountable bodies
Key to sections:
III. Non-governmental organisations, platforms, networks, ad-hoc coalitions, temporary structures and other
VI. Other public or mixed entities, created by law whose purpose is to act in the public interest; transnational
X. Tier 1 organisations outside the scope of the Register (with particular reference to: the European
Ombudsman; the Greens/EFA group in the European Parliament; and the EP intergroup on Integrity,
Transparency, Corruption and Organised crime (ITCO) as listed in Table 2-5)
* In this and subsequent tables, III (1 + 1 org), for example, represents the views from one Tier 1 Section III
organisation (1) and one Section III organisation (1 org) from the sample of non-Tier 1 respondents
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Table 5-2 shows that there is cross-section support for ethical and transparent lobbying. However, it
is identified that this needs to be defined. Three NGOs (section III) also consider that further
transparency rules are needed. One section III respondent notes that ‘To be a real transparency
champion, the Commission must extend these rules so as to cover all Commission staff’.
There is a recognition that lobbying allows specialist knowledge to be brought into decision-making
(one II, one III, one X). One section III respondent notes that further transparency rules are needed,
specifically ‘the obligation for Commission officials to meet only registered lobbyists and to record
online lobby meetings should be extended beyond Commissioners, cabinet members and directors-
general to cover all those engaged in policy development’. There are also views (one III, one VI) that
powerful entrenched interests have unbalanced influence and the regulation of lobbying must
consider equality of access (two III).
Two Tier 1 respondents (two VI) note that public authorities should not be equated to lobbying as
stakeholders nor included in the same register as private non-democratically accountable bodies.
One of the additional organisations (one VI) also comments on this theme. The suggested solution is
to use the Committee of the Regions register for public bodies (two VI).
Comments from individuals
A total of 21 of the responses are included in the sample. Table 5-3 summarises the key themes that
have been extracted from these responses. As before, the themes have been grouped to combine
similar issues, to highlight positive and negative aspects that have been raised on those issues and to
draw in suggested solutions to the negative issues.
Table 5-3: Themes* in response to Q1.1a; n=21 (by language: DE=1, EN=16, FR=2 , IT=1, NL=1)
Issue No. Issue No. Solution No.
Full minutes or meeting 2
reports should be taken in
far more meetings
Lobbying brings in 3 Checks and balances are 4
technical expertise/ needed to take account of
specialist knowledge different interests within
society
Powerful entrenched 5
interests have unbalanced
influence
Measures to tackle 1
conflicts of interest are
fundamental
Lobbying is never 3
transparent, makes policy
worse, is bad
Citizens are insufficiently 4
represented
Ban large, “bad”, or 3 Any organisation 1
foreign lobbyists interacting with the EU
must be fully transparent
* Note that where themes differ from those identified above for organisations, these are presented in italics.
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Table 5-3 shows that some individual respondents understand that lobbying brings in technical and
specialist expertise.
However, respondents’ views demonstrate a clear mistrust of lobbying and a strong concern that
powerful, large, ‘bad’ lobbyists have too much say and that citizens’ views are underrepresented. As
one respondent noted: ‘lobbying allows for much too large of a voice for those who have money and
power over the voice of the citizens and general public’.
Further comments
Word lists (excluding common words) were compiled for responses in English (368), German (132)
and French (68) using the NVivo software. These words were checked against those in the themes
mentioned above to see if there were any ‘new’ words which could suggest different themes.
From the English words, exploration of the word ‘representation’ suggested a slightly different
perspective. Specifically, interest representation is seen as an important part of democratic process
(according to several Section II and III organisations) and the context is illustrated in the word tree
overleaf.
From the German, the word ‘Gemeinwohlorientierung‘ (orientation towards the common good)
appeared in responses from German local and regional authorities (Section VI organisations) but,
when read in context, was found to relate to a theme already identified: public authorities cannot
be equated to lobbying or as stakeholders.
Further brief manual inspection of comments from responses in Italian (22) and Spanish (14) did not
reveal any further themes.
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Figure 5-4: A word tree illustrating the importance of ‘representation’ in the democratic process
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5.2.3 Views on other principles after transparency (Qn1.1b)
Summary
There were 19 Tier 1 responses received to the open-text box associated with this question. A total
of 13 of the responses are included in the sample. A further five responses from other organisations
have also been reviewed. Table 5-4 summarises the key themes that have been extracted from
these responses. As before, the themes have been grouped to combine similar issues, to highlight
positive and negative aspects that have been raised on those issues and to draw in suggested
solutions to the negative issues. In all cases, the section(s) providing the comments is given to
enable a comparison of the responses by different types of organisation.
Table 5-4: Themes in response to Q1.1b; n=18 (By section: I = 0, II = 4, III = 6, IV = 0, V = 0, VI = 6, X = 2)

Conflicts of interest can X (1) Integrity of lobbyists X (1)
undermine policy and decision-makers is
development essential
Equality of access II (1) The way decisions are X (1)
should be ensured III (3 + 1 taken is also key
through the whole org)
decision-making process VI (1 org)
X (2)
Further rules and II (1) Codes of conduct are III (1) Decision-makers can II (1)
regulations will further needed within EU choose who they listen
legitimise the work of institutions to, which works as a
stakeholders self-regulatory
mechanism
Account should be II (1 org)
taken of the
competence and
expertise provided by
stakeholders
Steps are needed to III (3) Transparency Register III (1)
further dialogue with could be used as a
civil society directory to identify
relevant stakeholders
Transparency II (1) The EC must promote III (1)
requirements should VI (1) more actively civic
not be used as barrier space at national level
to participation
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Table 5-4: Themes in response to Q1.1b; n=18 (By section: I = 0, II = 4, III = 6, IV = 0, V = 0, VI = 6, X = 2)
Account must be taken III (1 + 2 Policy makers should II (1)
of the imbalance org) differentiate between VI (1)
between lobbying VI (1 + 1 lobbyists that are
resources between org) members of
private and public professional
interests organisations and
those that are not
Privileged/unequal III (2) Public interests must III (1 +
access by business ultimately prevail 2 org)
lobbies should be
limited
Lobbying on behalf of III (1)
oppressive regimes
should be prevented
Rules allow regional VI (1)
chambers of commerce
and public private
partnerships to be
treated as public
institutions
Public bodies are VI (2)
treated in the same way
as commercial lobbyists
(and should not be)
Key to sections:
VII. Law firms; professional consultancies; self-employed consultants
VIII. Trade and business associations; trade unions and professional associations
IX. Non-governmental organisations, platforms, networks, ad-hoc coalitions, temporary structures and other
X. Think tanks and research institutions
XI. Organisations representing churches and religious communities
XII. Other public or mixed entities, created by law whose purpose is to act in the public interest; transnational
X. Tier 1 organisations outside the scope of the Register
* III (3 + 1 org), for example, represents the views from three Tier 1 Section III organisations (3) and one
Section III organisation (1 org) from the sample of non-Tier 1 respondents
Table 5-4 shows that respondents across sections II, III and VI agree that equality of access should be
ensured through the whole decision-making process (one II, four III, one VI, plus two from other
organisations: one III, one VI). NGOs (section III) commented on the need for more dialogue with
civil society (three III) and that privileged/unequal access by business lobbies should be limited (two
III). Trade and business associations (one II) thought that further rules would legitimise the work of
stakeholders. One comment from a section III respondent added ‘Lobbying which occurs in the
context of generous gifts, hospitality, trips, or promises of future employment is…unscrupulous, as is
inappropriate lobbying, such as bullying someone to deliver a specific outcome… lobbying on behalf
of repressive regimes would also fall into this category and should be prevented’.
One respondent from section VI noted that the way that decisions are taken is key, adding ‘This
particularly applies to the European Commission's expert groups and the various agencies'
assessment panels, who have been accused of being overly one-sided and not sufficiently
RPA | 29
independent to ensure that the public interest is at the heart of all decision-making’. This fits with
responses from one Tier 1 section III respondents and two organisations (two III) that public
interests must ultimately prevail.
have been extracted from these responses. The themes have been grouped to combine similar
issues, to highlight positive and negative aspects that have been raised on those issues and to draw
in suggested solutions to the negative issues.
Table 5-5: Themes in response to Q1.1b; n=21 (By language: DE=6, EN=13, ES=1, FR=1)
Equality of access should be 2
ensured through the whole
decision-making process
Decision-makers can choose 1
who they listen to, which
works as a self-regulatory
mechanism
Account must be taken of the 4
imbalance between lobbying
resources between private and
public interests
Privileged/unequal access by 3 Public interests must 5
business lobbies should be ultimately prevail
limited
Public bodies are treated in the 1
same way as commercial
lobbyists (and should not be)
No “gifts” from lobbyists to 1
officials
Ban lobbying, it cannot be 3
transparent
Sometimes equality of access is 1
not ideal. (Bankers should have
no say in legislation of their
industry)
Forbid off-the-record meetings 1
Monitor for and penalise non- 1
compliance
First VW investigation was 1
refused, only media pressure
enabled it.
Publically state the affiliations 2
and financing of lobbyists
Allow longer to develop 1
regulations if this enables all
relevant parties to be involved
Record and make public every 3
meeting between EU and
lobbyists
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Table 5-5 shows many respondents’ concern to maintain equality of access and to find ways of
adjusting to allow for the large imbalance in resources between different organisations, so that
citizens’ views are heard and the public interest prevails. This was expressed by one respondent:
‘My impression is that the proximity between politics and the economy is closer than that between
the politics and people. Understandably, since the economy has fewer different opinions and can pay
for negotiations. Nevertheless, the opinion of the people must be duly considered, and more value
placed upon it (translated).’
One point is interesting: allow longer to develop regulations if this enables all relevant parties to be
involved. The full view is: ‘It may be necessary to allow longer for the processes especially when
regulations may be complex. Regulations should be workable and allow for appropriate lobbying
from the right interested parties not just the NGOs with only political motives.’
Further comments
mentioned above to see if there were any ‘new’ words which could suggest different themes but no
new words were identified.
Further brief manual inspection of comments from responses in Italian (19) and Spanish (15)
revealed one further theme. One individual requested that meetings held with lobbyists should be
limited in number.
5.2.4 Views on transparency of the European institutions (Qn 1.1c)

Summary
total of 20 of the responses are included in the sample
of 14 of the responses are included in the sample. A further five responses were added from other
organisations (referred to as ‘org’ in the table). Table 5-6 summarises the key themes that have
been extracted from these responses.
Table 5-6: Themes in response to Q1.1c; n=19 (By section: I = 0, II = 5, III = 9, IV = 0, V = 2, VI = 1, X = 2)

The Transparency III (1) Loopholes still exist III (1) A legally binding II (1)
register was a step VI (1) register is needed III (2)
forwards in X (1)
increasing
transparency
A code of conduct is III (1)
required
RPA | 31
Table 5-6: Themes in response to Q1.1c; n=19 (By section: I = 0, II = 5, III = 9, IV = 0, V = 2, VI = 1, X = 2)
Level of transparency III (2 + 1 Transparency rules II (1)
varies from one org) should apply equally to III (4)
institution to the next all EU institutions
EU Institutions are III (1) Transparency in the II (1)
transparent in X (1) Council is on the level of III (2)
comparison with the worst performing
Member States Member States
Council of Europe is not III (1 + 2
covered by transparency org)
register VI (1)
Transparency in EU III (1) EU needs to be a III (1)
institutions lags behind transparency champion
best practice
EU institutions need to III (1) There should be public III (1)
regain visibility, trust access to Council VI (1)
and legitimacy working group meetings
The Access to III (1)
Documents Regulation VI (1)
needs to be reformed
Trilogues should be II (1) All submissions III (2)
transparent III (3 + 2 received by the EC VI (1)
org), VI (1) should be made public
Lack of transparency for VI (1) Meetings should be III (1)
meetings with less held on a searchable
senior Commission database
officials and lobbyists of
private sector
companies
EU Ombudsman III (2)
decisions should be
binding
Speeding up EU-law X (1) All stakeholders should II (1)
making has led to be able to get involved
informal decision- at all stages of
making regulation (from
drafting to detailed
provisions)
Draft texts and draft II (1)
impact assessments III (1 org)
should be published VI (1)
before the initiative is
finalised and adopted
All public consultations II (1)
and all new proposals III (1)
should be published VI (1)
immediately after their
adoption
Key (abbreviated) to sections: I: Professional consultancies, etc.; II: In-house lobbyists and associations; III:
Non-governmental organisations, etc.; IV: Research and academic institutions; V: Organisations representing
churches etc.; VI: Sub-national authorities and X: Tier 1 organisation outside scope of Register
* III (1 + 2 org), for example, represents the views from one Tier 1 Section III organisation (1) and two Section
III organisations (2 org) in the sample of non-Tier 1 respondents
RPA | 32
The Transparency Register is noted (one III) as a step forward in increasing transparency, but one
respondent from section III and one from section VI both note that loopholes still exist. There are
also concerns (two III plus one other organisation, III) that transparency varies from one EU
institution to the next, with two respondents from Tier 1 (one III, one VI) and two other
organisations (two III) noting that the Council of Europe is not covered by the Transparency Register.
Three respondents (one II, two III) state that the Council is on a level in terms of transparency with
the worst performing Member States. One section III respondent adds that ‘EU institutions often lag
behind what is already done in some member states and also behind international best practice.
Particularly in the US and Canada, the rules governing lobbying, access to documents, stakeholder
meetings and the work of Parliament in general lead to far greater transparency. We also see that
several member states are currently putting in place mandatory lobby registers or are otherwise
increasing transparency and the EU needs to make substantial progress in order not to fall further
behind’. One other organisation (section III) notes that there is ‘Room for improvement especially in
the timely publication of documents, compliance with even communicated deadlines, the drafting of
impact assessments or the transparent selection of the cast of expert groups. The same applies to the
allocation of resources by the EU Commission’.
Five Tier 1 respondents (one II, four III) plus one other organisation (III) identify that transparency
rules should apply equally to all EU institutions. There are also suggestions for a legally binding
register (one II, two III, one X) and for a code of conduct (one III). One section III respondent notes
that ‘The scope of application of the Register lacks coherence: while Commissioners, their members
of cabinet and European Commission’s Directors-General must log in all the meetings they attend
and organize, no such obligation applies for members of the European Parliament’. One section X
respondent notes that ‘the institutions should work towards legislation underpinning the
Transparency Register, as a real mandatory register should be legally binding on interest
representatives, unlike an Interinstitutional Agreement, which is only binding on the institutions that
participate in it’.
Five Tier 1 respondents (one II, three III, one VI) and two other organisations (both III) identified that
trilogues need to be made transparent. One section III respondent commented that ‘Legislative
"practices" such as delegated acts and trilogue negotiations keep lagging behind in terms of
transparency, being negotiated behind closed doors’. A second section III respondent adds on
trilogues that ‘These informal inter-institutional meetings… have become an established feature of
EU decision-making, but often undermine accountability and transparency of the EU legislative
process. Very little information is available to the public because these meetings take place behind
closed doors and only well-resourced and/ or well-connected lobbies have access to trilogue
documents’.
There were also requests for the EU to public draft texts and draft impact assessment before an
initiative is finalised and adopted (one II, one VI from Tier 1 and one III from other organisations),
and for all public consultations and new proposals to be published immediately after their adoption
(one II, one III, one VI from Tier 1).
RPA | 33
Table 5-7: Themes* in response to Q1.1c; n=20 (By language: DE=4, EN=13, FR=2, NL=1)
A legally binding register is 1
needed
Level of transparency varies 2 Transparency rules should 2
from one institution to the next apply equally to all EU
institutions
Council of Europe is not 2
covered by transparency
register
There should be public access 1
to Council working group
meetings
Trilogues should be 1 All submissions received by 2
transparent the EC should be made public
Meetings should be held on a 3
searchable database
EU Ombudsman decisions 1
should be binding
Negotiations like TTIP are done 2
in secret
Transparency at present is only 1 Make more effort/ 6

for those with the resources to communication to help the
gather and assess the data public to access info on
policies, lobbies and
representatives
Little transparency about the 1
use of public funds
Big business/aggressive 2
lobbyists control the rules
Meetings with non-registered 1
lobbyists happen: therefore it
isn’t transparent.
Regarding the need for greater communication to help the public and smaller organisations obtain
information, one respondent observes: ‘They don't seem transparent, but that's also because we
don't have any popular pan European news shows/newspapers. The closest thing to the latter are the
Guardian and the Economist in my opinion and those are still specifically British and not European. I
think I'd really like a European news organization like the BBC.’
Another respondent sums up many views: ‘The EU institutions have introduced some important
transparency measures although transparency varies between them. There is much that could be
improved across the EU institutions to boost transparency. In fact, there should be a legally-binding
register to all organisations and entities addressing the European institutions, with comprehensive
disclosure requirements, and active monitoring, enforcement and sanction capacities, which cover
lobbying in all the EU institutions and executive agencies. All EU institutions should only meet with
registered lobbyists, lists of meetings should be pro-actively published by Commission officials and
reports of lobby meetings held by EU officials should be kept and should be releasable under access
to documents. On-line lists of meetings should be held in a centralised, searchable database for each
institution. Another aspect is the trilogues which have become an established feature of EU decision-
RPA | 34
making, but often undermine accountability and transparency of the EU legislative process. Very little
information is available to the public because these meetings take place behind closed doors and
only well-resourced lobbies have access to trilogue documents. The publication of all documents
should be required and in a timely and systematic manner. Furthermore, there should be public
access to meetings, and access to any reports or notes discussed over the course of the process, in
line with the procedures for normal Parliament committee meetings. More importantly, all European
Ombudsman decisions on transparency should be binding for EU institutions.’
Further comments
mentioned above to see if there were any ‘new’ words which could suggest different themes but no
new words were identified. Further brief manual inspection of comments from responses in Italian
(11) and Spanish (17) revealed no further themes.
5.2.5 Views on the Transparency Register as a useful tool for regulating

lobbying (Qn 1.2)
Summary
of 13 of the responses are included in the sample. A further five responses have been added from
other organisations (referred to as ‘org’ in the table). Table 5-8 summarises the key themes that
have been extracted from these responses.
Table 5-8: Themes in response to Q1-2; n=18 (By section: I = 0, II = 4, III = 8, IV = 0, V = 1, VI = 3, X = 2)

Transparency register is II (2) Transparency register X (1) Enforcement/ III (3 + 2
a useful tool III (2 org) creates no obligation of sanctions are needed org)
V (1) transparency on to achieve X (1)
VI (2 + 2 decision-makers transparency
org)
X (2)
Transparency register is II (1) Transparency system X (1)
currently somewhat III (1) does not show what
useful influence lobbyists have
on decision-making
No provisions to ensure X (1) Information about II (1)
equality of access to meetings should be on
decision-makers the transparency
website
RPA | 35
Table 5-8: Themes in response to Q1-2; n=18 (By section: I = 0, II = 4, III = 8, IV = 0, V = 1, VI = 3, X = 2)
Lobby register places X (1) Onus of transparency X (1)
onus of transparency on should be on public
outside actors officials
Registrations by third X (1) Meaningful oversight III (1)
parties cannot be mechanisms are
coupled with effective needed
monitoring
Present register is highly III (1) Independent body III (1)
flawed should be established
to decide upon
violations
The Register contains VI (1 org) Clearer guidelines are VI (1 org)
requirements that can needed
lead to misperceptions
Comparability VI (1 org)
between stakeholders
is needed
Most lobby contacts X (1) Lobby register should III (4 + 1
remain unregistered be mandatory org)
Unregistered lobbyists III (1 + 1
should not be able to org)
meet with EU officials
Data quality on the III (1) Register should be III (1)
Register is poor X (1) central hub of lobby
transparency
Register must cover all III (1)
lobbyists
Register contains over- II (1) Balance is needed III (1)
bureaucratic provisions between transparency V (1)
and unnecessary
bureaucracy
Lack of proactive III (1) Improved register III (1)
measures to address could lead to proactive
imbalance between use
corporate and public
interest
Civil society expertise is III (1)
underused for hearings
and advice
Member States' specific III (1) The Council of Europe III (1 + 1
lobbying regulations are should join the org)
inadequate transparency register
* II (1), for example, represents the views from one Tier 1 Section II organisation (1) while VI (1 org)
represents the views of a Section VI organisation (1 org) in the sample of non-Tier 1 respondents
Eleven respondents consider the Transparency Register to be a useful tool (two II, one, V, two VI,
two X, plus four other organisations: two III, two VI) or somewhat useful (one II, one III). Six
respondents (three III, one VI, plus two other organisations: two III) suggest that enforcement and
RPA | 36
sanctions are necessary to achieve transparency. A section X respondent adds that ‘European
Commission has consistently argued that there is no legal basis for effective sanctions, raising
questions about whether or not this type of system will ever achieve the transparency that's required
to ensure independence, impartiality and equality in access to the decision-making process. It must
be mentioned, however, that other legal studies have found specific legal bases’. A section III
respondent comments that they ‘wish to see a commitment to start negotiating a legally-binding
lobby register in place by 2017’. They believe that this would ‘give the authorities the opportunity to
levy fines or other real sanctions on those who refuse to register. Such legislation could also bestow
proper enforcement mechanisms on the authorities so that they can take tough action against those
who post inaccurate information or who otherwise break the rules’. There are then four section III
Tier 1 respondents and one other organisation (also section III) who suggest that the lobby register
should be made mandatory.
Coverage of the Transparency Register is reported as being ‘75% of business related organisations
and 60% of NGOs active in lobbying the EU institutions is registered in the TR. This means that there
is still a big grey zone where the influences on the EU decision making might not be made in a fair
and transparent way’ according to one section III respondent. Another section III respondent notes
though that ‘While the register is based on a sound definition of lobbying and now includes
information on over 9,000 registered organisations, the poor data quality of the register seriously
reduces its usefulness as a monitoring tool’. They suggest that the Register ‘should be upgraded to
include other information, such as members of expert groups, organisations’ answers to public
consultations, and lists of lobby meetings at the Commission, among others’.
Two respondents (one III and one V from Tier 1) note that a balance is needed between
transparency and unnecessary bureaucracy, adding that ‘While transparency is a must for "decision-
makers" who are to be held accountable for the choices made, we believe that some leniency should
be left for the technical level. We fear that unnecessary requirements at technical level – if every
policy officer working for the institutions has to log in work meetings, for instance – will only lead to
inefficiency and paralysis in the decision-making process’.
Three additional themes were added based on comments from other organisations. This includes a
comment that the Register contains requirements that can lead to misperceptions (section VI). This
is clarified as because ‘the EU Transparency Register is not the right tool to provide an accurate
overview of the aggregated amount spent in a whole sector for lobbying activities…this may lead to
misinterpretations and undue controversies’. A second section VI respondent calls for clearer
guidelines covering the number of persons involved in advocacy, and the calculation of membership
fees.
Table 5-9: Themes in response to Q1-2; n=20 (By language: DE=5, EN=10, FR=2, NL=1, PT=2)
Transparency register is a 2 Enforcement/ sanctions are 1
useful tool needed to achieve
transparency
RPA | 37
Table 5-9: Themes in response to Q1-2; n=20 (By language: DE=5, EN=10, FR=2, NL=1, PT=2)
Transparency register is 4
currently somewhat useful
Register may give too much 2 Information about meetings 1
prior info to officials, better should be on the
to update the Register after transparency website
visit.
Present register is highly 1
flawed
Most lobby contacts remain 2 Lobby register should be 6
unregistered mandatory
Unregistered lobbyists 1
should not be able to meet
with EU officials
Data quality on the Register 4
is poor
Register should be 1
independently run, by people
with the power to clean data
NGOs and conflicts of interest 1
(see commentary)
Who intervenes if lobbying 1
becomes unethical, needs
supervision
Clearer communication to 1
the public through the press
and media
Ban lobbying 2
Regarding the Register’s data quality, one respondent expands: ‘Looking up […], I find only
information given by the firm itself. 2 people registered! Are you serious? This register needs to be
run by an independent organisation with full access to all relevant information and sufficient power
to get the information from the targeted organisations. For example TTIP negotiations are not
included. What about the EFSA and glyphosate? We know the problems, why are you not changing
the system? Democracy means including people in decision making processes.’
Another respondent19 develops the discussion about NGO corporate models and conflicts of
interest: ‘The basis of a conflict of interest needs to be broadened. As it is now, the general
interpretation is that if a person or organisation stands to profit from the results of their involvement
in a decision-making process, this entity has a conflict of interest. Profit is translated as financial
gain so most NGOs don’t feel that their engagements with their organisations entail a conflict of
interest (they are non-profits).
19
Note this respondent appears several times in the summaries because the responses are detailed and
pertinent and they are identifiable by the “Action point” at the end. It is important to stress that a
different group of respondents was selected at random for each question. However, when there are
relatively few comments and one respondent replies to many questions at length, it is unsurprising that
their responses will appear several times.
RPA | 38
But NGOs sell their access and influence to foundations, trusts and large funders. The more they can
enter into a debate and spread their influence, the easier it is to raise funds. Some like […] have a
corporate expansion model – to grow the organisation by 10-15% per year via fundraising (which
now consumes a third of the NGO’s budget). But when NGO’s enter into debates or have their
experts on panels or working groups, they generate market value among donors and this added
influence can be valued in the hundreds of millions of euros. This is similar to companies with
financial profit motives, but the NGOs do not believe they have a conflict of interest when they bring
their positions and biases to a privileged position. If industry experts and scientists are to be
excluded from participating in panels, working groups, committees and platforms, under the same
measures, so too should the NGOs who are not impartial and have attached a value to the influence
they can exert.
Ideally, it should be agreed upon that all actors involved in public debates have interests that they try
to express and all should be allowed to participate (many NGOs receive public money so that they
can participate), and I wish the European Union would be more mature about this. Note that it is only
the NGOs that holler and moan about industry being involved and work to restrict dialogue and true
stakeholder engagement. They even formed an organisation called […] with over 200 civil society
members trying to stop industry from engaging in public dialogue. It is in their interest, and helps
them to gain influence by excluding stakeholders they disagree with.
Action point: Either allow all actors to fully engage in the process (regardless of conflicts of interest)
or define a conflict of influence that the civil society organisations benefit from and apply the same
exclusionary procedures to NGO members from EU working groups, panels, advisory boards,
committees … as that applied to individuals with ties to industry.’
Further comments
mentioned above to see if there were any ‘new’ words. Although several new words were
identified, on further examination of the context, it was seen that the associated themes had already
been identified.
Further brief manual inspection of comments from responses in Italian (15) and Spanish (10)
revealed a concern from an individual that the general public is not sufficiently informed about
transparency measures.
RPA | 39
5.3 Scope of the Register (Qns 2.1, 2.2)
5.3.1 Overview
There was widespread support for the definition of what activities should be covered by the
Register.
Registered (n=609)
Fully agree
Unregistered (n=105) Partially agree

Disagree
No opinion
Individual (n=938)
0% 20% 40% 60% 80% 100%
Figure 5-5: Qn 2.1: Activities covered by the Register include lobbying, interest representation and
advocacy. It covers all activities carried out to influence - directly or indirectly - policymaking, policy
implementation and decision-making in the European Parliament and the European Commission, no matter
where they are carried out or which channel or method of communication is used. This definition is
appropriate
The Register does not apply to certain entities, for example, churches and religious communities,
intergovernmental organisations and their diplomatic missions. Regional public authorities and their
representative offices do not have to register but can register if they wish to do so. On the other
hand, the Register applies to local, municipal authorities and cities as well as to associations and
networks created to represent them.
Respondents were asked whether the scope of the Register should be changed to exclude or include
particular types of organisations. There was a sharp divergence between individuals, most of whom
wanted to broaden the scope of the Register and unregistered organisations, most of whom wanted
to exclude particular types of organisations. Responses from registered organisations were between
the two as illustrated in Figure 5-6 (overleaf).
RPA | 40
Unregistered (n=105)
Exclude certain entities
Registered (n=609) As current

Include certain entities
No opinion
Individual (n=938)
0% 20% 40% 60% 80% 100%
Figure 5-6: Qn 2.2: The scope of the Register should be…
However, the desire for exclusion amongst unregistered organisations comes from sub-national
authorities (Section VI) as illustrated below.
I: Professional consultancies etc (n=7)
II: In-house lobbyists and associations

(n=16)
Exclude certain entities
III: Non-governmental organisations, As current
etc (n=18)
Include certain entities
IV: Research and academic No opinion

institutions (n=3)
VI: Sub-national authorities (n=61)
0% 20% 40% 60% 80% 100%
Figure 5-7: Responses from unregistered organisation by type of organisation to Qn 2.2: The scope of the
Register should be…
RPA | 41
5.3.2 Views on the definition of lobbying activities (Qn 2.1)
Summary
of 11 of the responses are included in the sample. A further four responses have been added from
other organisations (referred to as ‘org’ in the table). Table 5-10 summarises the key themes that
Table 5-10: Themes in response to Q2.1; n=15 (By section: I = 0, II = 1, III = 7, IV = 0, V = 1, VI = 3, X = 3)

Support for a broad II (1) Definition seems III (1) Activities covered in III (1)
definition III (3 + 1 unreasonably extensive the Registry should
org), V (1) focus on contacts in
VI (1 + 1 which decision-makers
org), X (1) are actively engaged
Such a wide definition III (1) The focus of the III (1)
would result in a Register should be on
tremendous workload information on EU
decision-making not
just lobbying
Not true to say that II (1) Important to have II (1)
definition covers all precise definitions VI (1)
activities carried out to
influence
There is still uncertainty II (1) Current wording is VI (1)
as to what constitutes III (1 org) rather abstract
lobbying
Catch-all use of directly III (1 org) Preparation, approval V (1)
and indirectly is lazy and implementation
phases need to be
included
The Transparency X (1) Definition should be X (1)
Register should give a adjusted to that in
comprehensive picture current IIA, including
of how an organisation all institutions
tried to wield influence
There appears to be a VI (1) Clause is needed to X(1)
tendency to overlook prohibit unregistered
lawyers as potential lobbyists entrance to
lobbyists at the national its premises
level
RPA | 42
Register does not VI (1) Register should VI (1)
distinguish lobbying exclude all local,
from intergovernmental regional authorities
negotiations and their official
bodies
Third country III (1)
embassies should be
included in the list of
organisations
Council of EU should III (1)
be covered by
* VI (1 + 1 org), for example, represents the views from one Tier 1 Section VI organisation (1) and the views of
a Section VI organisation (1 org) in the sample of non-Tier 1 respondents
Nine of the fifteen respondents provide broad support for the suggested definition (one II, three III,
one V, one VI, one X plus two from the other organisation: one III, one VI). One of the section III
respondents notes that ‘the definition of lobbying/interest representation in the lobby register is one
of the strongest elements of the present set-up’. However, another section III respondent considers
that the definition is unreasonably extensive commenting that ‘We do not believe that sending a
position paper by email could be reasonably considered as a lobbying activity. Also, the definition
leaves much room to interpretation: would, for instance, a speech given at a conference organized by
a third-party organisation and attended by a Commission representative be considered as a lobbying
activity covered by the Transparency Register’. A section VI respondent also considers the current
wording to be rather abstract, adding that ‘activities such as information events that are organised
by the European Commission would, in principle, fall within the scope of the current rules, meaning
all that participants of such events should be called upon to register’. One additional comment from
another organisation (section III) states that ‘The catch-all use of "directly or indirectly" is lazy and
can be used to raise incorrect suspicions or make flawed accusations’.
One section III respondent requests that activities covered in the Registry should focus on contacts
in which decision-makers are actively engaged, adding that ‘The element of content and the
exchanges of views should be the key elements, differentiating lobbying from networking/contacting.
Such a differentiation will lead to less contacts being reported, but with additional in-depth and more
meaningful information’. One section II respondent though suggests that it is not true to say that
definition covers all activities carried out to influence. They highlight that ‘such activities are also
carried out by the Commission to Parliament and Council, by Parliament to Commission and Council,
and by the Council to Commission and Parliament as well as the other public sector bodies not
covered by the TR’.
One section X respondent notes that ‘the Transparency Register should constitute the central
transparency hub, with other registers…linking to it. It should be possible…to get a comprehensive
picture of how exactly a particular organisation tried to wield influence’.
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There is also a comment from a section X respondent that the ‘the legal profession often plays a
significant role in assisting interest groups to make their case to policy makers…Even though law
firms are obliged to declare their clients if they are lobbying for them under the Transparency
Register, a “grey” area…exists…where legal advice ends and lobbying…begins’.
A total of 16 of the responses are included in the sample. Table 5-11 summarises the key themes
that have been extracted from these responses. The themes have been grouped to combine similar
Table 5-11: Themes in response to Q2.1; n=16 (By language: DE=2, EN=9, FR=2, NL=1, PT=2)
Support for a broad 6 Theoretically appropriate, 2 The definition must evolve 1
definition but unenforced and as people circumvent it
hidden
Not true to say that 1
definition covers all
activities carried out to
influence
There is still uncertainty 1
as to what constitutes
lobbying
There appears to be a 1
tendency to overlook
lawyers as potential
lobbyists at the national
level
Define lobbying: what are 1
academics? (see
commentary)
All communication 1
methods, direct, indirect,
electronic, should be
recorded
Where are the bribes 1 Ban lobbying 2
registered?
One respondent explains the difficulty of defining who is a lobbyist: ‘We saw that in the first round
when think tanks and law firms did not consider themselves as lobbyists. What about academics? In
my case, I lecture in universities and conduct training courses (sometimes in EU institutions) – that is
not lobbying, but what about when I speak at EU oriented events – is that lobbying? Clear definitions
are needed so I can know if and what I need to register.
Other academics are clearly lobbying but think they are protected by their university titles. For
example, … none of these people or their institutions are in the Transparency Register, but they are
clearly lobbyists receiving money to influence the debate and coming to the European Parliament or
Commission to “share their expertise” without declaring their funding.
RPA | 44
Action point: Define clearly what types of activities are considered as required to open a dossier in
the Transparency Register, including what types of activities academics and scientists do that fall
under the category of lobbying and advocacy.’
Further comments
mentioned above to see if there were any ‘new’ words. Although several new words were
identified, on further examination of the context, it was seen that the associated themes had already
been identified. By way of example, several section II respondents (lobbyists) called for the ‘scope’
of the Register to be more explicit – but this is a rewording of the theme: important to have precise
definitions.
Further brief manual inspection of comments from responses in Spanish (11) revealed no further
themes.
5.3.3 Views on exclusions (Qn 2.2)

Summary
of 15 of the responses are included in the sample. A further six responses are added from other

Changes to the exclusion III (1) The introduction of a III (1)
regime need to be 'representativity
implemented criterion' could be a
solution
Direct representatives of III (1)
local authorities should VI (3)
be exempted of
registering in the
All interest II (2) Umbrella organisations III (1)
representatives that III (2 + 1 whose primary purpose is V (1)
undertake lobbying org) to lobby EU institutions
activities should be IV (1) should be registered
registered V (1 org)
X (1)
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EU institutions need to III (1) Transparency register III (1)
reinforce efforts to ensure should cover all actors
all organisations who that have an impact on
should sign up do so EU decision-making
Embassies and third III (2)
countries should be
covered by the Register
Churches and religious II (1 org)
communities should be
included in the Register
Potential lobbying III (1 + 1
influence from Member org)
States' service at
national, regional or local
level should be captured
where national registers
are missing
The register should II (1) Mandatory registration is III (1)
capture even more III (1) required IV (1)
entities
Regional public VI (1) The Committee of the VI (1)
authorities and local, X (1) Regions register should
municipal authorities and be used for regional and
cities should be treated local authority
equally organisations
Activities carried out II (1)
under social dialogue
should continue to be
excluded from the scope
of the Register
Activities where EU II (1) Registration should III (1)
Institutions demand data depend on the nature of V (1)
or where organisations the activity and not the
are invited to events type of entity
should be excluded from
the scope of the Register
* X (1), for example, represents the views from one Tier 1 Section X organisation (1) while V (1 org)
represents the views of a Section V organisation (1 org) in the sample of non-Tier 1 respondents
Six of the Tier 1 respondents (two II, one III, one IV and two X), plus two other organisations (one III,
one V) think that all interest representatives that undertake lobbying activities should be registered.
These include examples such as:
 ‘all churches and religious communities, political parties, and regional public authorities and their
representative offices should register if they are undertaking lobbying/representing their own
interests’
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 ‘all churches and religious communities, political parties, Member States' government services,
third countries' governments, international intergovernmental organisations and their diplomatic
missions, regional public authorities and their representative offices’.
There is considerable disagreement though on who should be registered, with four respondents
(one III and three VI) commenting that direct representatives of local authorities should be
exempted. In this regard, there is a comment that ‘the Register is incoherent in its approach in that
“regional public authorities and their representative offices” have the choice as to whether or not
they register whereas “local, municipal authorities and cities as well as to associations and networks
created to represent them” are obliged to register. Both types of entities should be treated equally
and therefore excluded from the scope of the register’. One section VI respondent notes that ‘the
use of front groups is a particular concern and should be made subject to greater public scrutiny’.
Two Tier 1 respondents (one III, one V) note that registration should depend on the nature of the
activity and not the type of entity. One section III respondent suggests the use of a ‘“representativity
criterion” as a solution making the Transparency Register compulsory for any organisation having
members in 2 or more different Member States’.
Two respondents (two III) suggest that embassies and third countries should be covered by the
Register. This is justified by comments such as ‘they often represent the interests of their business
community or individual companies (“national champions”). Their influence on EU decision and law-
making should be made transparent in the same way as the influence of NGOs, companies or trade
unions’ and ‘Of particular concern are the firms working for some of the world’s most autocratic
regimes and human rights-abusing governments. Too many European PR firms and lobby
consultancies are being paid to whitewash repressive regimes' images, smear dissidents and
opponents, run their elections, hide their abuses, and lobby for lucrative investment, trade, aid, and
political support from the EU institutions. The US has strict reporting requirements for
representatives of foreign agents and the EU should follow suit’.
that have been extracted from these responses.
Table 5-13: Themes in response to Q2.2; n=28 (By language: DE=5, EN=13, ES=1, FR=6, IT=2, PL=1)
All interest representatives 16
that undertake lobbying
activities should be
registered
Embassies and third 7
countries should be covered
by the Register
Churches and religious 14
communities should be
included in the Register
Regional public authorities 1
and local, municipal
authorities and cities should
be treated equally
RPA | 47
Table 5-13: Themes in response to Q2.2; n=28 (By language: DE=5, EN=13, ES=1, FR=6, IT=2, PL=1)
Include political parties 6
from third countries and
international organisations
in the Register
Include political parties 7
within the member states
Include government 3
departments of member
states
Half of the respondents specifically stated that religious organisations should be included and many
also mentioned embassies, third countries, political parties and international organisations. This
respondent expresses the views of many:
‘Not clear why churches, government or political parties are not covered by the legislation in a
transparent way. This opens the floodgates for almost any form of influence, let slip the "real
lobbyists in church/partisan clothes." I find it downright incomprehensible to thwart a transparency
regime like this. Absolutely each influencing organization is to register without exception’ (translated
from German).
Further comments
Word lists (excluding common words) were compiled for responses in English (656), German (170),
French (108) and Italian (36) using the NVivo software. These words were checked against those in
the themes mentioned above to see if there were any ‘new’ words. Although several new words
were identified, on further examination of the context, it was seen that the associated themes had
already been identified.
Further brief manual inspection of comments from responses in Spanish (21) and Dutch (11)
revealed no further themes.
RPA | 48
5.4 Register website (Qns 3.1)
5.4.1 Overview
Respondents were asked for their views on the Register website20. Their views are summarised in
the table below.
Table 5-14: Views on the Register website (Qn 3.1)

Individuals Score*
Organisations Organisations
(n=938) (Rank)
Aspect of website (n=609) (n=105)
52% Good 39% Good 32% Good
Design and structure 39% Average 39% Average 39% Average 1.03 (1)
5% Poor 5% Poor 12% Poor
Ease of search function 33% Average 30% Average 32% Average 0.93 (2)
Availability of information / documents 37% Average 47% Average 36% Average 0.72 (3)
Accessibility (e.g. features for visually
22% Average 22% Average 18% Average 0.34 (4)
impaired persons, ease of reading page)
Access via mobile devices 22% Average 28% Average 18% Average 0.26 (5)
*Note that overall score based on a simple rating scale: Good =1, Average = 0, Poor = -1 multiplied by %
responses and summed across all three stakeholder groups
‘No opinion’ responses have not been presented in this table
In general terms, registered organisations were most positive while individuals were least positive.
The highest rated aspects were the website’s ‘design and structure’ and ‘ease of search function’.
The two lowest rated aspects related to ‘accessibility’ and ‘access via mobile phones’ although most
respondents (over 50% in each stakeholder group) offered ‘no opinion’ on these aspects.
5.4.2 Views on the website (Qn 3.1)

Summary
20
http://ec.europa.eu/transparencyregister/public/homePage.do
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of 9 of the responses are included in the sample (this is because one comment was ‘not applicable’).
A further five responses are added from other organisations (referred to as ‘org’ in the table).
Table 5-15 summarises the key themes that have been extracted from these responses.

End user's perspective III (1) The Transparency III (1 + 1
needs to be considered Register should be org)
improved by adding X (1)
information from
other databases
Greater information on VI (1 org) Lists of meetings of II (1)
the lobbying activities of high-level Commission III (2)
lobbyists is needed officials with lobbyists X (1)
should be included
Membership of EU II (1)
Structures and III (1)
platforms should be
included
EU institutions II (1)
themselves should III (1 org)
develop an integrated,
accurate database
The 100 most recent III (1)
registrants should be
included
There is no information X (1)
on sanctions
News listing should be III (1) All news postings III (1)
more prominent should be notified to
those registered
The search function III (3) Search function should III (1)
needs to be improved X (1) be prominent on the
main page of the
Register
Website is clear and III (1 + The difficulty is access VI (1 org)
easy to navigate + 1 org) to it from the EC or
parliament websites
The Register should be X (1)
more accessible to VI (1 org)
those with hearing,
reading or other
difficulties
The data should be X (1) Data should be made III (1)
machine readable available in API format
Quality of data is not III (2) Clearer guidance and III (2)
good additional information X (1)
on the questionnaire is
needed
There should be access III (1)
to historic data
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IT system is unstable so II (1)
updates are complex
and lead to
administrative burden
The technical team III (1)
should be open to
suggestions by outside
users
Membership of II (1)
organisations should be III (1 org)
included
* III (1 + 1 org), for example, represents the views from one Tier 1 Section III organisation (1) and the views of
a Section III organisation (1 org) in the sample of non-Tier 1 respondents
Respondents to question 3.1 have a number of suggestions for changes to the Register website.
These include four respondents (three III and one VI) who think the search function should be
improved. Specific suggestions include:
 'The need for the search function to be prominent on the main page of the Register (section III)'
 ‘It would be good to be able also to search according to the areas of lobbying in order to use also
the register to fostering consultation and stakeholders' involvement and ensure more
participation of organisations promoting the public interest’ (section III)
 ‘search function also does not allow for ranking of the various registrations by different criteria,
e.g. spending, even if you specifically search for that criteria. It is also difficult for third parties to
effectively access the data in bulk. It should also be possible to compare the differences in various
entries over time’ (section VI)
 ‘The search function should be improved and sensitised’ (section III)
Four respondents (one II, two III and one VI) request that lists of meetings of high-level Commission
officials with lobbyists should be included. One respondent from section III notes that ‘Information
on Commission meetings with lobbyists is currently scattered over 98 different webpages. Also, the
meetings are not linked to the registrations of lobbyists despite the fact that the link already exists in
the Commissions internal systems’. Another respondent (section VI) also asks for ‘information about
the Commission's various expert groups, and the participation of these lobbyists also on agencies'
expert panels. Documents submitted by lobbyists could be uploaded to the register as well’.
Comments are also made on the quality of the data with two respondents (two III) stating that the
quality is not good. One section III respondent expands on this by adding ‘the lack of guidance on
how to properly fill the data leads to incoherent data being filled in, impacting the efficiency and the
usefulness of the Register website’. Two respondents (two III) suggest that clearer guidance and
additional information on the questionnaire is needed. One recommends that ‘introduction of
automatic plausibility checks would avoid common mistakes, such as confusing turnover with lobby
budgets, and reduce the administrative burden for the JTRS’. One other section III respondent
comments on issues with ‘financial data where we believe a lot of confusion persists amongst
stakeholders’. Associated with this is a response from section II that the IT system is unstable so
updates are complex and lead to administrative burden. This is qualified with ‘Several of our
RPA | 51
members experience difficulties during the yearly update. And since we as consultancies have to fill in
a lot more information than other categories, this presents us with an unnecessary administrative
burden. We have also experienced that information has changed during the year without us having
made changes’.
that have been extracted from these responses. The themes have been grouped to combine similar
Table 5-16: Themes in response to Q3.1; n=15 (By language: DE=1, EN=10, FR=2, IT=2)
The search function needs 4 After searching, you should 1
to be improved be able to download the
filtered results
Website is clear and easy to 1 Design is out of date 1
navigate
Quality of data is not good 1
Minor CSS bugs using 1
Android 4.2 browser on
phone.
Extend lobbyist pages about 1
themselves
Translate the names of 1
organisations
Email notifications should 1
have direct links to
documents
Register gives legitimacy to 1
undemocratic lobbyists,
should be banned
One respondent made several points about the website, which are included in the table and added:
‘I would mainly recommend extending the pages of each lobbyists group to include what are the
main points they argued upon regarding what policies, and what are their usual arguments and
public positions. That would allow somebody to familiarize themselves more easily with the various
lobbying groups and get a better picture of what is going on.’
Further comments
mentioned above to see if there were any ‘new’ words. Review of the words ‘link’ led to the theme:
that related information needs to be better hyperlinked (from a diverse range of respondents). Also,
the word ‘ausgaben’ (expenditure) led to several co-ordinated responses from major German
companies with the common theme that: estimated costs for EU advocacy repeatedly overstate the
lobbying expenditures, lead users astray and undermine transparency. Further brief manual
RPA | 52
inspection of comments from responses in Italian (10) revealed a further request (from an
individual) that all pages of the site should be made available in all EU languages.
5.5 Additional comments (Qn 4 and additional files)

5.5.1 Overview
There were 131 responses from organisations providing additional comments. A total of 13 of the
responses are included in the sample
There were 172 responses from individuals providing additional comments. A total of 15 of the
responses are included in the sample.
5.5.2 Comments from Organisations

There were 10 Tier 1 responses received to the open-text box associated with this question. All 10
of the responses are included in the sample. A further three responses have been added from other
Table 5-17: Themes in response to Q4; n=13 (By section: I = 0, II = 1, III = 6, IV = 0, V = 1, VI = 3, X = 2)

The Transparency VI (1) Dramatic overhaul of X (1)
register is an important Transparency register is
element in making EU required
decision making more
transparent
The balance achieved V (1)
since 2011 is
satisfactory and does
not require extensive
intervention
Good to see the lobby III (1 org) The Inter-Institutional III (1) The negotiations on the III (1)
issue is being addressed Agreement is a unique IIA should be as open
opportunity for reform and transparent as
possible
Non-binding TR II (1) The IIA should mention X (1)
resulting from the right to complain to
interinstitutional the European
agreements is Ombudsman
unsatisfactory
Need to use all III (1) Unregistered lobby III (3)
incentives to have a X (1) groups should no longer
system that is as be able to meet officials,
mandatory as possible organise events or
participate in hearings or
expert groups
Register must be made II (1)
mandatory III (3)
A legal basis is required II (1)
to make the TR legally
obligatory
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Table 5-17: Themes in response to Q4; n=13 (By section: I = 0, II = 1, III = 6, IV = 0, V = 1, VI = 3, X = 2)
More information is III (2) Registrants should III (2)
needed on lobbying X (1) specify third party
expenditure organisations that they
pay and how much they
pay
All EU institutions III (3)
should be included in X (1)
the revised
Trilogue process needs VI (1)
to become more
transparent
Quality of data in III (3) Systematic checks on at III (3)
register need to be least 20% of declarations
improved are needed annually
There should be III (1)
incentives to comply
with the Register
Better monitoring of III (2) Updates should be III (1)
data entered into the compulsory and twice
registry per year
Sanctions must be in III (4)
place for inaccurate or
misleading information
Suspended lobby groups III (3)
should be placed on a
public list
All individuals lobbying III (2)
on behalf of a registrant
should be listed
Separation is needed V (1)
between authentic
lobbyists and other
entities
Public authorities VI (1) The Committee of the VI (1)
cannot be equated to Region (CoR) register
lobbying or as should be used for public
stakeholders bodies
A balance is needed in VI (1)
expert groups between
business/corporate
concerns and non-
business related entities
An effective complaint III (2)
system is needed
* III (1), for example, represents the views from one Tier 1 Section III organisation (1) while III (1 org)
represents the views of a Section III organisation (1 org) in the sample of non-Tier 1 respondents
RPA | 54
Many of the comments on question 4 reiterate views that have been expressed in responses to
previous questions. Also, three of the responses from section III are very similar, all noting the need
to improve the quality of the data in the Register with suggestions to undertake checks on 20% of
declarations on an annual basis, the need for the Register to be mandatory, for unregistered lobby
groups to no longer be able to meet with EU officials and for suspended lobby groups to be placed
on a public register. Some additional information is given, for example, ‘Lobby turnover should be
disclosed to the nearest 10,000 euros and not according to the present system of wide brackets’ and
‘All lobby consultancies and law firms should be required to list, alongside the specific lobby revenue
received from each client, the precise issues upon which they lobby and / or advise each client’.
Three respondents (one V, one VI, and one VI from other organisations) provided positive comments
in relation to the current Transparency Register, although both of the Tier 1 respondents added
points on how it could be further improved. One section VI respondent included the need for
‘ensuring a balance in expert groups between those representing business/corporate concerns and
those representing non-business-related entities, including the public sector’. The section V
respondent noted that ‘The “lobbying”/“interest representation” terminology is often associated
with terms like “business”, “clients”, “profits”; is historically linked to economic interests… The
questionnaire for the present consultation also refers in various passages to the lobbying/interest
representation terminology as if fitting all entities concerned…It would also be opportune to have an
element of separation and distinction between authentic lobbyists/interest representatives; and
entities that do not belong to that ambit’.
One section X respondent highlights the use of complaints to the European Ombudsman to ‘address
concerns…about the fact that the JTRS21 administers the Register and, at the same time, is
responsible for investigating complaints and deciding on the appropriate sanctions’.
5.5.3 Comments from Individuals

total of 15 of the responses are included in the sample. Table 5-18 summarises the key themes that
Table 5-18: Themes in response to Q4; n=15 (By language: DE=5, EN=7, FR=1, IT=1, NL=1)
Register must be made 3
mandatory
All EU institutions should be 2
included in the revised
There should be incentives to 1
comply with the Register
Sanctions must be in place for 2
inaccurate or misleading
information
Media does not reflect the 1 Clearer communication about 2
actions of lobbyists public consultations
Improve transparency of 2
member states
21
The Commission’s Joint Transparency Register Secretariat
RPA | 55
Table 5-18: Themes in response to Q4; n=15 (By language: DE=5, EN=7, FR=1, IT=1, NL=1)
As well as IIA, should be a 1
lobbying directive, giving legal
framework and all definitions
Public should be able to 1
comment on position papers
Citizens must have greater 1 Publish calendar of meetings 1
input on Register so public can
attend
Strict conditions on access to 2
politicians by lobbyists
Allow access to answers in 1
this consultation, the best
ideas will emerge
Many of the comments on question 4 reiterate views that have been expressed in responses to
previous questions. This respondent voices the views of many; ‘I am a firm supporter of the
European Union and I think especially nowadays it's imperative to show citizens how policy is made
in the EU and how much big spenders are pumping into lobbying. A lot of people […] view the
lobbying system as highly corrupt. 20,000 lobbyists, of which 70% or more come from big industries
is just not right. I want the EU to be a political, social and, yes, economical Union, but I don't want
the governing forces to be financial.’
Another respondent makes a specific point about access: ‘[The lobbying system] seems to be widely
abused by lobbyists to promote their own interests, which are not necessarily those of the public. […]
One solution is that lobbyists must not approach politicians directly. Instead, politicians should ask a
central data source for information on lobbyists that have offered their advice on a topic. Then
politicians could pick and choose which lobbyists to consult’ (translated from German).
Further detail about a possible legal framework for lobbying is given by one respondent: ‘The Inter-
Institutional Agreement with regards to the Transparency Register and the Code of Conduct attached
is not enough for EU. EU needs a lobbying directive which would fundament the lobby activity in the
EP, EC and in all other European institutions. This directive should create a legal framework for
national lobbying legislation of the EU member countries. It should include specific terms with
regards to what is a lobbying action and what is not a lobbying action (which one should be declared
and which one is illegal). It should trace a verge between lobbying and corruption, between lobbying
and political consultancy, between lobbying and donations to political parties, between lobbying and
presents done to MPs, Commissioners and other EU and EU member state officials. It should also
limit the possibility of doing lobbying for those companies that are providers of goods and services
for EU and national institutions (according to public acquisition contracts), because these companies
could be places in a privileged position in comparison to other lobbyists.
It is clear that the interest of the EU citizens is above the interests of EU lobbyists. Thus, the Register
should render the possibility to act against the actions of lobbyists (ex. if a position paper of a
lobbyist creates a major dissatisfaction to the EU citizens they should have the possibility to comment
upon it and make the decision factors take into consideration also their opinion - that is why the
position papers have to be accessible not only to officials, but to the whole public).’
RPA | 56
33 respondents attached position papers or similar documents, of which seven were associated with
campaigns. The remaining 26 papers were briefly reviewed and 23 are summarised in the table
below (three respondents did not wish their contributions to be published). Several documents
from unregistered section VI organisations (Austrian local and regional authorities) have already
been considered with reference to the associated campaign – and are not repeated here.
Table 5-19: Summary of attached documents (from publishable contributions)

Format
ID Type* Document name Description
(Lang)
There can be no democracy
Word General paper on the importance of transparency, 6
a) 0 in the EU without
(EN) pages
transparency
Circular economy and our life O3 makes Free Consultants, paper on Circular
b) U-II PDF (EN)
style Economy and Life Style, 11 pages
Brief written by a student in the Netherlands:
Transparency Register, the way forward. Puts
c) 0 Policy brief Anca Stoica PDF (EN) forward the concept of a points system for
categorising organisations according to the
completeness of their entries, 6 pages.
European Movement International: Citizens
Democracy_Policy_Position_
d) R-III PDF (EN) participation and transparency: closing the gap, 2
ADOPTED
pages.
Council of European Municipalities and Regions:
2015_offener_brief_rgre__bv
open letter about the Transparency Register saying
e) U-VI _schreiben_transparenzregist PDF (EN)
they have concerns, but these are not listed in this
er_-_timmermans
document, 2 pages.
Comments from Jukka S. Rannila, individual from
Jukka_RANNILA_Mandatory_
f) 0 PDF (DE) Finland. Detailed technical discussion about the
Transparency_Register
Register’s operation, 12 pages.
Comprehensive response to the open-text questions
g) 0 Amnesty International PDF (EN)
in Section A, 6 pages.
AK Wien (Austrian Federal Chamber of Labour)
PDF (DE
h) R-II Lobbying in Brussels Lobbying in Brussels: breaking the excessive power
& EN)
of corporations, 40 page report
PDF (DE Bavarian State Government Further development of
i) U-VI Position paper Bayer
& EN) the European Transparency Register, 4 pages
European Anti Poverty Network: info for an election
EAPN 22 mai 2014 EP PDF (NL)
in 2014, 3 pages
European Anti Poverty Network: Report of the 2015
PDF PEP (People Experiencing Poverty) conference, the
EAPN PEP report
j) R-III (EN) process preparing the meeting and the evaluation of
EAPN Netherlands, 4 pages
European Anti Poverty Network: Together looking
EAPN PDF (NL) for change, A guide for clients WWB (Participation
Act) with, Directions applying for benefits, 17 pages
Bonn offener brief PDF As Campaign 2 document (see Table 4-3)
k) U-VI
Bonn to Timmermans (DE) As e) - above
ITCO European Parliament Intergroup: Input for the
public consultation on the Inter-institutional
l) U-III ITCO declaration TR PDF (EN)
Agreement on a Mandatory Transparency Register,
1 page, six key themes
RPA | 57
Table 5-19: Summary of attached documents (from publishable contributions)
Format
ID Type* Document name Description
(Lang)
Rural Education & Agriculture development
m) U-III READO PDF (EN) Organisation (Somalia/Somaliland) profile about the
organisation, 9 pages
Convention of Scottish Local Authorities (COSLA)
Letter about status of Local Authorities and their
n) U-VI COSLA PDF (EN)
associations – argues that associations of local
authorities should not have to register, 3 pages
CCRE CEMR ( Council of European Municipalities and
Better Regulation CEMR
o) R-VI PDF (EN) Regions) Position paper on Better Regulation for
position
Better Results, 11 pages
German Industry and Commerce: Consultation of
p) R-II DIHK Triloge PDF (DE) the European Ombudsman on the transparency of
trilogy, paper, 6 pages
q) U-VI Lombardia testo non ufficiale PDF (IT) Completed questionnaire
Insurance Europe response to
r) R-VI PDF (EN) Insurance Europe: completed questionnaire
PC
National Bar Council (France) : opinion on French
s) U-II CNB contribution PDF (FR)
lawyers and lobbying, 33 pages
The role of lobbying in
t) 0 PDF (EN) A chapter of a book, 11 pages
modern democracy A. Bitonti
European Centre of Employers and Enterprises
providing Public Services: Three key themes in
CEEP response Transparency addition to the questionnaire, in order: sort out
u) R-III PDF (EN)
Register issues with the Register first (guidance, monitoring,
sanctions), make it mandatory, enable everyone to
access it, 2 pages.
BNP Paribas Group: Charter for responsible
BNPP Charter for responsible
PDF (EN) representation with respect to the public
Representation
authorities, 3 pages
Transparency International: Reporting Guide
v) R-II
lobbying expenses. The National Assembly is the
Guide des dépenses TI PDF (FR) only French institution to ask lobbyists to report
their budgets devoted to parliamentary lobbying:
details how this operates, 4 pages.
ALTER-EU: Lobbying Law Firms, Unfinished Business.
Lobby Control study law firms PDF (EN) Details nine law firms that ALTER-EU believes are
lobbying but are not on the Register, 9 pages.
Reply from Juncker Letter to ALTER-EU explaining the EC response to
PDF (EN)
w) R-III Timmermans nov 2015 three themes important to ALTER-EU, 3 pages.
ALTER-EU Who is meeting who? The lobby
meetings of the new European Commission,
who is meeting whom PDF (EN)
detailed look at how many meetings DGs hold with
business v citizen groups, 10 pages
* Type of respondent: 0 = individual; U-II = unregistered section II organisation, etc.; and R-III = registered
section III organisation, etc.
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6 Analysis of Part B Questions
6.1 Introduction
Part B of the questionnaire comprised 13 questions which addressed eight themes as listed below:
 Structure of the Register (Qn B1.1)

 Data disclosure and quality (Qns B2.1, B2.2, B2.3, B2.4)
 Code of conduct and procedure for alerts and complaints (Qns B3.1, B3.2a, B3.2b)
 Register website – registration and updating (Qn B4.1)
 Current advantages linked to registration (Qn B5.1)
 Features of a future mandatory system (Qns B6.1, B6.2)
 Looking beyond Brussels (Qn B7.1)
 Additional comments
The Part B questions were answered by 763 respondents with nearly 500 respondents representing
organisations registered on the Transparency Register
Table 6-1: Summary of respondents to Part B questions

% respondents
Part A Part B*
Nature of Respondent proceeding to Part B
An individual in my personal capacity 975 246 25%
620 495 80%
163 22 13%
Totals 1758 763 43%
* Note that of these 763 respondents who proceeded to Part B, 12 were part of the campaigns considered
earlier. As a consequence, the analysis which follows is based on 751 responses to Part B questions
The responses by theme are summarised below.
6.2 Structure of the Register (Qn B1.1)

6.2.1 Overview
Organisations registered on the Register did not generally encounter any difficulties with this
categorisation. However, as illustrated in the figure below, a substantial portion of unregistered
organisations claimed to have encountered difficulties.
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Unregistered (n=22)
Yes
Individual (n=245)
No
No opinion
Registered (n=484)
0% 20% 40% 60% 80% 100%
Figure 6-1: Qn B1.1: The Register invites organisations to sign up under a particular section, for example,
professional consultancies, NGOs, trade associations, etc. (Annex I of the Interinstitutional Agreement).
Have you encountered any difficulties with this categorisation?
6.2.2 Views on categorisation (Qn B1.1)

Summary
There were 31 responses from individuals to the open-text box associated with this question. A total
of 8 of the responses are included in the sample.
of 7 of the responses are included in the sample. A further three responses have been added from
other organisations. Table 6-2 summarises the key themes that have been extracted from these
responses.
Table 6-2: Themes in response to QB1.1; n=10 (By section: I = 0, II = 4, III = 4, IV = 0, V = 1, VI = 1, X = 0)

The homogeneity of V (1) The category NGO is too III (1)
section V should be broad
preserved
The representativeness II (1)
of NGOs should be III (1 org)
examined in the same
way as for social
partners
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Guidelines should be III (1) A separation of II (1 + 1
clearer with examples V (1) associations would org)
help III (1 org)
Trade unions and II (1)
professional
associations should be
replaced by social
partners
European Social II (1)
Partners should be III (1 org)
distinct from other
interest
representatives
A number of III (1 + 1
organisations categorise org)
themselves wrongly
There should be no VI (1)
difference between
regional and local
authorities
‘org’ refers to views from a non-Tier 1 respondent
Specific issues are raised with most categorisations:
 Section II: ‘A separation of associations as follows would help: associations mostly representing
commercial members; associations mostly representing non-commercial members; associations
representing a profession; and trade unions’ and ‘Only strictly not for profit associations which
are advocating for non-commercial, nonprofessional interests should be under the category
NGOs’
 Section III: ‘We suggest to separate NGOs from Foundations…NGOs and Foundations are both
not for profit organisations, but foundations have a grant making role’ and ‘it should be
considered to clearly separate corporate from non-commercial interests by moving the
subsection ‘Trade Unions and Professional Associations’ either into its own category or
integrating it into ‘III. Non-Governmental organisations’.
 Section V: ‘A quotation from paragraph 13 of the relevant 2014 interinstitutional agreement

(“The register does not apply to churches and religious communities. However, the
representative offices or legal entities, offices and networks created to represent churches and
religious communities in their dealings with the EU institutions, as well as their associations, are
expected to register”) could be inserted as the heading of Section V of the Register, so that it is
visualised…every time the Section is opened’.
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 Section VI: ‘Section 2.2…inappropriately recognises that “Regional public authorities and their
representative offices do not have to register but can register if they wish to do so… we
specifically request that the IIA on the Transparency Register and the Guidelines specifically say
that “Representations of national, regional and local governments and their associations should
not fall under the EU transparency register, as they are part of the EU’s multi-level system of
governance”’
Table 6-3: Themes in response to QB1.1; n=8 (By language: DE=3, EN=5)
The category NGO is too broad 2
The representativeness of NGOs 1
should be examined in the same
way as for social partners
European Social Partners 1
should be distinct from other
interest representatives
Organisations with multiple roles 1
cannot categorise themselves
Transparency must cover all 1
organisations supporting
lobbying
Definitions are bloated and 1
complex
Definitions must evolve over 1
time
Organisations should not register 1
themselves, they can cheat, there
is no-one checking their accuracy
There are a range of issues relating to categorisation: concerns about the NGO category and the
European Social Partners are the only issues that occur more than once.
Further comments
Word lists (excluding common words) were compiled for responses in English (68) using NVivo.
These words were checked against those in the themes mentioned above to see if there were any
‘new’ words. One word was reported several times but, on closer inspection, was found to refer to
a commercial company, the name of which had been repeated many times within a single
submission. A further brief manual inspection of comments from responses in German (13) did not
reveal any further themes.
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6.3 Data disclosure and quality (Qns B2.1, B2.2, B2.3, B2.4)
6.3.1 Overview
Entities joining the Register are asked to provide certain information (contact details, goals and
remit of the organisation, legislative dossiers followed, fields of interest, membership, financial data,
etc.) in order to identify the profile, the capacity of the entity and the interest represented (Annex I
of the Interinstitutional Agreement). Respondents were asked to rate various aspects of this. The
results are summarised in the table below.
Table 6-4: Views on data disclosure and quality by respondent group

(Note that responses of ‘no opinion’ have not been presented in this table)
Individuals
(n=245)
Aspect of Register being considered: (n = 484) (n = 22)
The right type of information is required 66% fully agree 55% fully agree 58% fully agree
from the registrant: 21% too much 23% too much 7% too much
10% too little 9% too little 27% too little
It is easy to provide the information 49% fully agree 45% fully agree 41% fully agree
required: 42% partially agree 27% partially agree 31% partially agree
7% disagree 14% disagree 4% disagree
Do you see any room for simplification as 37% yes 27% yes 27% yes
regards the data disclosure requirements? 34% no 36% no 37% no
What is your impression of the overall data 42% good 41% good 27% good
quality in the Register? 35% average 27% average 44% average
11% poor 14% poor 16% poor
Note: Since responses of ‘no opinion’ have not been included, the % figures for each aspect add up to less than
100%
In general terms, there was broad satisfaction with the existing situation and the variation in
responses was similar across the different stakeholder groups. However, further attention was given
to responses from registered organisations with respect to whether the right type of information is
required to see of responses varied by section of the Register. The responses are illustrated below.
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III: Non-governmental
organisations, etc (n=109)
IV: Research and academic
institutions (n=19)
I: Professional consultancies Too much
etc (n=53)
Fully agree
II: In-house lobbyists and
Too little
associations (n=279)
VI: Sub-national authorities No opnion
(n=19)
V: Organisations representing
churches etc (n=5)
0% 20% 40% 60% 80% 100%
Figure 6-2: Qn B2.1: Is the right type of information required from the registrant? (Responses from
registered organisations by section of the Register)
Although most organisations are content with the status quo, it can be seen that there are views
that too little information is being requested particularly amongst NGOs (Section III) whilst at the
other end, there are many who think that too much information is being requested particularly
amongst in-house lobbyists and associations (Section II) and sub-national authorities (Section VI).
6.3.2 Views on level of data disclosure (Qn B2.1)

Summary
In relation to comments from registered organisations, those who considered that too little or too
much information was requested were more likely to provide further comments as illustrated in the
table below.
Table 6-5: Response to closed questions by those providing an open text response
Number of Number providing % providing
Response to closed question
respondents further comments comments
Too little is asked 50 38 76%
Fully agree 319 47 15%
Too much is asked 100 63 63%
No opinion 15 3 20%
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of 10 of the responses are included in the sample. A further five responses have been added from
other organisations. The table below summarises the key themes that have been extracted from
these responses.

Level of disclosure V (1) Staff not in the III (1) More information is III (3 + 1
currently required is European Parliament required on individual org),
satisfactory access list may need lobbyists VI (1 org),
defining as a lobbyist X (1)
Entries should be X (1) Entries should be III (1)
updated more regularly automatically linked to
information
Details requested are III (1) Need for automatic III (1)
unbalanced plausibility checks
The financial II (1) Up-to-date financial III (1)
information required information is needed
bears no relationship to
the legitimate objective
of transparency
Lobby turnover should III (1 + 1
be disclosed to the org)
nearest 10,000 euros
Lobby dossier III (1)
disclosure is poorly
policed
Funding sources III (1 org)
should be disclosed
Details required in III (1) There should be an III (1)
register are limited option for registrants
compared with other to upload papers that
lobbying registration seek to influence EU
systems institutions
Information on who III (1)
has been sanctioned is
needed
The design of the VI (1)
Register is impossible
for public bodies to
complete accurately
More guidance is II (1 + 1
needed for registrants org),
X (1)
Policy areas need to be II (1)
limited to a pre-
selected set for
practicality purposes
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The specificities of II (2) Registrants should II (1)
certain professions specify third part III (1 + 1
should be recognised organisations through org)
which they conduct
their lobbying
There is some disagreement over the extent to which the information requirements are satisfactory.
One section V respondent noted that they were, but others identified areas that they felt needed
improvement:
 Section II: ‘The breadth and detail of the financial information required…bears no relationship to
the legitimate objective of transparency…and results in the disclosure of information that should
remain private, such as the structure of the internal organization of the entity engaging in
lobbying, its cost structure and profit’ and ‘The calculation of costs and 'man-days' could be
clarified’.
 Section III: ‘When compared internationally to other lobbying registration systems, for example,
in the United States and Canada, the degree of detail of the information provided is more limited
and the data quality is much lower’.
 Section X: ‘More information about the individual lobbyists working in Brussels is required,
specifically to check possible conflicts of interest that could arise from the revolving door,
whereby EU officials move to work for the private sector in areas that they previously used to
regulate’ and ‘Entries should be updated more regularly…In Canada, lobbyists are required to
provide monthly reports of their lobbying activities’.
There is also a number of comments relating to the specificities of certain professions. One section II
respondent notes that ‘the obligation for a lawyer to provide information on the legislative dossiers
followed may conflict with his/her obligations under the rules of professional secrecy or legal
professional privilege’. This can be compared with a response from Section III that ‘too many
organisations making only general, imprecise declarations; this needs remedying so that the register
provides a clear picture of who is lobbying on what. Furthermore, all lobby consultancies and law
firms should be required to list, alongside the specific lobby revenue received from each client, the
precise issues upon which they lobby and / or advise each client’.
One section X respondent suggests that there is ‘room…for more practical guidance or rules for
public officials on contacts with lobbyists’.
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A total of 8 of the responses are included in the sample as summarised below.
Table 6-7: Themes in response to QB2.1; n=8 (By language: DE=1, EN=4, ES=1, FR=1, IT=1)
Level of disclosure currently 2 Registration is voluntary and 1 Sanctions required for 1
required is satisfactory the benefits are insufficient to inaccurate or incomplete
encourage registration information
Data is inaccurate 2 Lobby dossier disclosure is 1
poorly policed
Require organisations to 1
upload their internal Ethical
Code of Conduct (see
commentary)
Publish lobbyists’ requests 1
before meetings
Make all data publically 1
available, so everyone
knows who is lobbying.
One respondent explains the need for lobbyists’ internal Ethical Code of Conduct to be published:
‘While the Transparency Register has a code of conduct for how all members of organisations
registered must conduct themselves when dealing with EU officials and transparency procedures,
there should be a place available on the registry where organisations will be expected to upload their
own ethical codes of conduct. All organisations doing business within the European Union should
have clearly stated principles that guide how their members must at all times act, and if they are
easily available on the registry, they can be held to account should their behaviour be non-compliant.
What is important to note here is that many organisations not only do not have ethical codes of
conduct, they actually encourage law-breaking and ethically outrageous activity. Certain NGOs and
lobby groups calling for restrictions on conventional agriculture or chemicals openly and knowingly
convey alarmist half-truths, use children in their lobbying practices, break EU laws and openly attack
and criticise competitors or alternative. If they fail to comply with basic European ethical norms,
which they themselves must declare in the registry, alerts should be made and sanctions applied….
Action point: Provide a section in the Register for organisations to upload their internal ethical codes
of conduct and consider a dossier as incomplete if they fail to comply.’
Further comments
Word lists (excluding common words) were compiled for responses in English (115) and German (48)
using NVivo. These words were checked against those in the themes mentioned above to see if
there were any ‘new’ words. No new words were identified.
Further brief manual inspection of comments from responses in French (22) revealed a concern from
a two organisations (Sections I and II) that double counting needs to be taken into consideration; e.g.
when one company makes a contribution to another, both companies record the exact same
contribution in the transparency register which results in misleading figures.
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6.3.3 Views on ease of information provision (Qn B2.2)
Summary
In relation to comments from registered organisations, those who partially agreed or disagreed that
it is easy to provide the information required were far more likely to provide additional comments
and suggestions than those who agreed as illustrated in the table below.
Fully agree 237 11 5%
Partially agree 204 85 42%
Disagree 35 27 77%
No opinion 8 1 13%
There were 10 Tier 1 responses received to the open-text box associated with this question. All 10
of the responses are included in the sample. A further three responses have been added from other
organisations. The table below summarises the key themes that have been extracted from these
responses.

It is easy to provide the III (1) Registration is II (2) Need for automatic III (1)
information required X (1) burdensome for alerts that ask
registrants registrants to confirm
implausible
declarations
Administrative burden III (1) Administrative burden VI (1 org)
is reasonable associated with updates
is unreasonable
Companies sometimes X (1) Clear/more guidance is II (2)
list total turnover needed III (2 + 1
instead of lobby org)
expenditure VI (1 org)
X (1)
Some information is III (1) Separate budget lines III (1)
unnecessarily could be requested for
complicated lobbying expenditure
Information on costs for II (1) Drop-down menus III (1)
consultancies is III (2 org) should be used where
irrelevant possible
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Register is not designed VI (1)
for public bodies making
accurate data provision
impossible
Estimating data on II (1)
membership costs is
complicated and
burdensome
* III (2 + 1 org), for example, represents the views from two Tier 1 Section III organisations (2) and the views
of a Section III organisation (1 org) in the sample of non-Tier 1 respondents
Two respondents (one III and one VI) consider that is it easy to provide the information. One section
III respondent also adds that the administrative burden is reasonable. Two respondents, both from
section II, however, comment that registration is burdensome. These add that ‘The requirements
currently…impose too heavy a burden on the registrants without corresponding benefits from a
transparency perspective’ and that ‘it is often very complicated and burdensome for companies and
trade associations to assemble all the data on membership costs…This information is then often
subject to various possible misinterpretations which can create unjustified claims of alleged non-
compliance’. A similar point is made by a respondent from section X who comments that
‘sometimes it can be difficult to separate one's accounts into lobbying activities and non-lobbying
activities if this distinction is not made by the accounting department in the annual accounts’. A
response from one of the other organisations (section VI) also notes that the ‘upgrade requires huge
administrative burden’.
Two respondents comment on the FTE calculation. One (section III) considers it ‘unnecessary
complicated’ while the other asks for ‘better guidance on how to calculate Full-Time Equivalents or
Lobby budgets so that entries in the register are comparable’. One section III respondent broadens
out the discussion noting that ‘the lobbying expenditure in particular data accuracy might be
improved by asking for the different budget lines (staff, office, consulting/communications budgets…)
separately’. These issues are covered in requests for clearer or more guidance, with one section II
respondent focusing on the need for ‘improving and simplifying… the recent guideline on Financial
Information’.
One section II respondent from Tier 1 and two other organisations (both section III) focus on the
requirement for consultancies to provide information on the costs for carrying out activities. The
Tier 1 respondent feels that ‘it is the revenues that should be disclosed’ to avoid asking for ‘the
consultancy’s margins which is business sensitive’.
A total of 6 of the responses are included in the sample. The table overleaf summarises the key
themes that have been extracted from these responses.
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Table 6-10: Themes in response to QB2.2; n=8 (By language: DE=1, EN=4, ES=1, FR=1, IT=1)
It is easy to provide the 2 It should not be too easy 1
information required
Difficult to define “number of 1
lobbyists” and “activities”
Lobbyists should upload 1
position papers and opinions
onto the Register, so citizens
can see them.
Further comments
Word lists (excluding common words) were compiled for responses in English (98) using Nvivo.
‘new’ words. No new words were identified.
Further brief manual inspection of comments from responses in German (24) and French (22)
reiterated calls for extra guidance including (from two indviduals) for clarification for alculating the
number of staff involved in lobbying activities are required, e.g. should a member of staff arranging a
meeting be considered part of lobbying activities?
6.3.4 Views on simplification of process (Qn B2.3)

Summary
In relation to comments from registered organisations, those who could see room for simplification
as regards the data disclosure requirements were far more likely to provide additional comments
and suggestions than those who could not as illustrated in the table below.
Yes 177 95 54%
No 164 19 12%
No opinion 143 3 2%
There were nine Tier 1 responses received to the open-text box associated with this question. All
nine of the responses are included in the sample. A further four responses have been added from
other organisations. The table overleaf summarises the key themes that have been extracted from
these responses.
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The system could be X (1) A list of dossiers that X (1)
made simpler III (1 org) registrants could select
would help make
registration simpler
More data should be III (1) Automatic error alerts X (1)
required VI (1 org) could be programmed
X (1)
Data disclosure II (1) Additional guidance II (1)
requirements need would be welcome III (1)
strengthening
A gradual disclosure III (1)
information linked to
level of interaction
could help reduce
admin burden
An additional category III (1)
of lobbyists should be
added for those that
are most active and
have biggest budgets
Should be a principle III(1)
for updating of entries
when significant
changes occur
Membership fee III (1 org)
disclosure
requirements could be
simplified
Yes/No answers III (1 org)
should be avoided
A number of suggestions are made by different respondents for how the data disclosure
requirements could be simplified. Three respondents (one III, one VI from Tier 1 and one III from the
other organisations) think that more data should be required, including ‘on the critical question of
who is funding interest representatives’. Other responses by section are:
 Section II: ‘the recent guideline on Financial Information…needs improving and simplifying’.
 Section III: ‘rather than asking for regular updates, they should occur, for example, when lobby
expenditure falls into a new category. At least one annual update should be maintained’ and
‘Binary Yes/No answers should be avoided because answers are often more nuanced’.
 Section X: ‘it could be simpler to list different types of lobby expenditure by client, and then name
the dossiers worked on. This will also help to increase the accuracy of the estimated amount
spent on lobbying’.
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One suggestion (from a section III) respondent is to use a gradual disclosure requirement where
‘small organisations with little interactions with the institutions should disclose a minimum, while
organisations with larger lobby budgets and many interactions should provide much more detailed
information’. The same respondent also suggests inclusion of an ‘additional category of lobbyists for
those organisations that are most active and have the biggest budgets…Organisations having more
than 3 high-level meetings per year with Commissioners or…spending more than 1 million euros
annually on their lobbying activities should receive additional scrutiny…Currently, about 500
organisations would fall in this category’.
of 7 of the responses are included in the sample as summarised below.
Table 6-13: Themes in response to QB2.3; n=7 (By language: DE=1, EN=4, ES=1, FR=1)
Limit the detail required (see 2
commentary)
Enable to preparation of registration 1
information off-line and import
Enable links to organisations’ 1
websites where the data is publically
available.
Protect individual’s personal data 1
Ensure that organisations with few 1
resources get exactly the same
amount of access time as
professional lobbyists
Only register organisations 1
committed to a transparent and
democratic Europe
One respondent is concerned to limit the information required: ‘Too much information continues to
produce some misinformation’ translated from Spanish.
Another respondent expands on the concept of giving equal access: ‘Professional lobbyists should
disclose exactly how much they spend schmoozing MEPs, Commissioners etc. The same access should
be given, minute by minute, to people without these resources’
Further comments
Word lists (excluding common words) were compiled for responses in English (98) using NVivo.
‘new’ words. A review of the word ‘badge’ revealed several identical responses from different
offices of Transparency International (registered section III organisation) covering the theme
identified above: ‘A gradual disclosure information linked to level of interaction could help reduce
admin burden’.
Further brief manual inspection of comments from responses in German (27) did not reveal any new
themes.
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6.3.5 Views on data quality of the Register (Qn B2.4)
Summary
In relation to comments from registered organisations, 85% of those who considered the overall
data quality in the Register to be poor provided additional comments and suggestions compared to
the 8% of those who considered the overall data quality in the Register to be good as illustrated in
the table below.
Good 204 16 8%
Average 167 53 32%
Poor 53 45 85%
No opinion 60 9 15%
There were 9 Tier 1 responses received to the open-text box associated with this question. All 9 of
the responses are included in the sample. A further three responses have been added from other
responses.

Most registrants spend II (1) Almost half the entries III (3) EU Transparency III (2)
a lot of time and in the Register are X (1) Register secretariat VI (1)
resources to get the flawed needs to be X (2)
data right adequately staffed to
undertake checks
Lack of guidance makes III (1) Simplification and III (1)
entry into the Register clarification is needed
burdensome
A minimum number of III (3)

entries must be
checked each year
Limited monitoring and III (1 + 1 A proper monitoring III (1 + 1

lack of sanctions mean org) system for org)
data quality is poor registrations is needed
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Software should be III (1)
used to alert
registrants to unlikely-
looking postings
Effective use of III (1)
sanctions is required
Public democratically VI (1)
elected bodies should
not be equated with
private interests
Comparability of lobby II (1) Priority should be III (1)
costs is poor placed on ensuring
accuracy of financial
data
Five of the respondents (three III, one VI from Tier 1 and one III from the other organisations)
highlight the report by Transparency International and that ‘over half the entries for lobby
organisations on the EU Transparency Register, 4,253 organisations at the time, contained factual
errors or implausible numbers’. One section II respondent noted that most registrants spend a lot of
time and resources to get the data right, while another section II respondent states that ‘The
comparability of the lobby costs is poor. The methodology of how to calculate them is unclear’.
Proposed solutions to the issues identified with data quality include:
 Section III: ‘A minimum of 5% of declarations should be thoroughly checked each year’ or ‘at
least a fifth of the entries must be systematically checked every year’. To do this, three section III
respondents suggest that ‘An adequately staffed secretariat should be put in place in order to
ensure all necessary checks and in order to follow up complaints’
 Section VI: ‘Proper monitoring and enforcement could ensure compliance, as well as deter and
detect breaches’; and ‘It would be useful to have more guidance on how to fill in the section on
financial data. It is not always clear which figures have to be included’.
 Section X: ‘more resources need to be provided to the EU transparency register secretariat, so

that they are better able to check the registrations, and to investigate alerts and complaints and
enforce sanctions where applicable’.
A total of 7 of the responses are included in the sample. The table overleaf summarises the key
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Table 6-16: Themes in response to QB2.4; n=7 (By language: DE=1, EN=5, FR=1)
Most registrants spend a 1 No incentive to maintain 1 EU transparency Register 2
lot of time and resources data secretariat needs to be
to get the data right adequately staffed to
undertake checks
Data quality differs greatly 1 A minimum number of 2
between organisations on entries must be checked
the Register each year
Limited monitoring and lack 1 A proper monitoring system 2

of sanctions mean data for registrations is needed
quality is poor
No info about activities 1

Data about money and 1
people allocated to
lobbying is often wrong
Further comments
Word lists (excluding common words) were compiled for responses in English (106) and German (31)
using NVivo. These words were checked against those in the themes mentioned above to see if
there were any ‘new’ words. A review of the word ‘mitgliedsbeiträgen’ (member contributions)
revealed several very similar responses from major German companies with the common theme
that membership contributions from individual companies to associations should only be published
when such contributions were a significant source of funding for the association (interpreted from
the German).
Further brief manual inspection of comments from responses in French (15) did not reveal any new
themes.
6.4 Code of conduct and procedure for alerts and complaints (Qns
B3.1, B3.2a, B3.2b)
6.4.1 Overview
The Code of Conduct sets out the rules for all those who register and establishes the underlying
principles for standards of behaviour in all relations with the EU institutions (Annex III of the
Interinstitutional Agreement). Anyone may trigger an alert or make a complaint about possible
breaches of the Code of Conduct. Alerts concern factual errors and complaints relate to more
serious breaches of behavioural nature (Annex IV of the Interinstitutional Agreement).
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Respondents were asked to consider the following:
 the Code is based on a sound set of rules and principles (Qn B3.1)
 the present procedure for dealing with alerts and complaints is adequate (Qn B3.2a)
 do you think that the names of organisations that are suspended under the alerts and
complaints should be made public? (Qn B3.2b)
Table 6-17: Views on data disclosure and quality by respondent group

(Note that responses of ‘no opinion’ have not been presented in this table)
Individuals
(n=245)
Statement being considered: (n = 484) (n = 22)
76% fully agree 55% fully agree 36% fully agree
The Code is based on a sound set of
14% partially agree 23% partially agree 35% partially agree
rules and principles (Qn B3.1)
1% disagree 9% disagree 10% disagree
The present procedure for dealing with 33% fully agree 32% fully agree 31% fully agree
alerts and complaints is adequate (Qn 20% partially agree 23% partially agree 30% partially agree
B3.2a) 8% disagree 18% disagree 10% disagree
Do you think that the names of
organisations that are suspended 58% yes 59% yes 85% yes
under the alerts and complaints should 25% no 23% no 8% no
be made public? (Qn B3.2b)
Note: Since responses of ‘no opinion’ have not been included, the % figures for each statement add up to less
than 100%
While there is general support for the existing code and procedure for dealing with alerts and
complaints, there is strong support for publishing names of suspended organisations (particularly
amongst individual respondents).
Further analysis of the results for registered organisations indicated that there was some opposition
to such publication amongst all sections of the Register with least opposition from Section III
organisations (non-governmental organisations, etc.).
6.4.2 Views on the Code of Conduct (Qn B3.1)

Summary
There were 8 Tier 1 responses received to the open-text box associated with this question. A total of
7 of the responses are included in the sample. A further two responses have been added from the
other organisations. The table overleaf summarises the key themes that have been extracted from
these responses.
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Issue By type Issue By type Solution By type
Code of Conduct is III (1) Enforcement of the III (1) Need to strengthen X (1)
appropriate V (1) Code is not appropriate obligations of lobbyists
to respond to requests
for corrections of their
entries
The obligation to X (1)
subscribe in the
should be more firmly
included
Effective use should be II (1)
made of sanctions III (1)
Need to include X (2)
stricter provisions on
transparency about
hiring of ex-officials
Definition of II (1)
'inappropriate III (1)
behaviour' needs to be X (1)
clarified
Code of Conduct for X (1)
MEPs and EU officials
need to include more
robust transparency
obligations
Should prohibit III (1)
representation by
private firms of
regimes in breach of
human rights
Should prohibit III (1)
representation by
private firms of the
tobacco industry
Two respondents (one III, one V) consider the Code of Conduct to be appropriate, although the
section III respondent adds that ‘What is not adequate at the moment is the enforcement of the
Code’. One section X respondent notes that ‘recent Heads of Unit…leaving the EU…for the private
sector…the Commission [should] reflect on how it can further tackle this very difficult challenge, to
ensure no conflicts of interest occur’.
In terms of suggested revisions to the code, there are three respondents (one II, one III and one X)
who would like to see the clarification of the definition of ‘inappropriate behaviour’. One section II
respondent suggests this should ‘be remedied, perhaps along the lines of the European Parliament's
decision of April 2014 on the modification of the interinstitutional agreement on the Transparency
Register’. They add further that ‘If…rules are broken by an organisation that hires a former EU
official…suspension from the Register should be an option’.
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One section III respondent noted that ‘we want all lobbyists to register’ and so suggested a change
to the first paragraph of the Code of Conduct whereby the ‘sentence "registered or not" should be
eliminated, as we want all lobbyists to register’.
Both of the other organisations comment specifically on the Code of Conduct, with a section VI
respondent noting that they have ‘formulated a set of additional, specific principles and guidelines
for its lobbying activities’ and the section III respondent suggesting that ‘it might be envisaged to
invite any entity joining the Register to voluntary warrant and represent that to its best knowledge it
complies with the law of the country/ies where it acts’.
A total of seven of the responses are included in the sample as summarised below.
Table 6-19: Themes in response to Q3.1; n=7 (By language: DE=3 EN=3, IT=1)
Effective use should be made of 1
sanctions
Code of Conduct for MEPs and 1
EU officials need to include more
robust transparency obligations
Too much room for 4
interpretation
Meetings between MEPs and 1
lobbyists should be audibly
recorded and made public (see
commentary)
Four of the seven respondents indicated concerns about the room for interpretation in the Code of
Conduct and the words “fudge”, “lax” and “not controllable” are used.
One respondent has views on the recording of meetings: ‘I fully agree with the principles and
standards of behaviour established in the Code though to me there is too much margin for
interpretation. I mean, which is the border between pressure and information? Obviously it's
impossible to objectively regulate this issue and the potential violations of the Code of Conduct have
to be judged case by case. […] A possible measure to help the judging procedure it would be the
audio recording of all the meetings the MEP's have with the entities, which are willing to expose their
arguments in tense contexts.’
Further comments
Word lists (excluding common words) were compiled for responses in English (51). These words
were checked against those in the themes mentioned above to see if there were any ‘new’ words. A
review of the acronym ‘JTRS’ (the secretariat) revealed several identical responses from different
offices of Transparency International (registered section III organisation) covering the theme
identified above: Effective use should be made of sanctions.
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6.4.3 Views on procedures for complaints and alerts (Qn B3.2a)
Summary
total of 12 of the responses are included in the sample. There were 26 responses from individuals
to the open-text box associated with this question. A total of 7 of the responses are included in the
sample.
of nine of the responses are included in the sample. A further three responses are added from the
other organisations. The table below summarises the key themes that have been extracted..
Table 6-20: Themes in response to QB3.2a; n=12 (By section: I = 0, II = 2, III = 7, IV = 0, V = 0, VI = 0, X = 3)

Issue By type Issue By type Solution By type
Complaints and alerts X (1) There are insufficient II (1)
make a valuable resources to deal with III (4)
contribution to complaints or to make X (1)
effective sufficient checks
implementation of the
Register
Greater transparency is X (1) Greater emphasis is III (1) There is a need for III (1)
allowing the public to needed on checking X (1) more systematic
see and ask questions data quality checks and verification
about who the
Commission meets with
Should rely less on III (1 + 1 More automatic III (1)
external complaints and org) checking is required at X (1)
more on internal checks moment of
registration
The due process should II (1) An independent body II (1)
be strengthened is needed to Register III (2)
and administer
sanctions
The process for removal II (1) Sanctions such as III (1)
from the Register must suspending passes
be clear and should be included
transparent
Actions must be taken III (1) There should be public III (1)
against organisations transparency about X (1)
submitting inaccurate sanctions and how
register entries to system is enforced
improve confidence in
the system
Unregistered lobbyists X (1)
should not be able to
attend hearings or
events
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Six of the respondents (one II, four III, one X) agree that the current level of resources is insufficient
to deal with complaints or make the required checks. One section III respondent highlighted that
‘The secretariat for the current (voluntary) EU lobby register…is staffed by only a handful of people
(ratio: 1 staff member per 3653 registrants)’. They compare this with the case in Canada where
there is a ‘ratio: 1 staff member per 95 registrants’. A section VI respondent from the other
organisations suggests that ‘It must be possible to clearly distinguish between factual errors and the
most serious violations of behaviour’.
Three respondents (one II, two III) consider that an independent body is needed to register and
administer sanctions. One section III respondents identifies that the ‘High Authority for
Transparency in Public Life in France could serve as a model for the EU transparency regime’.
Another section III respondent states that ‘only an independent body, with a clear mandate and
appeal procedure set in place, would be in position to legitimately rule on alleged infringements to
the Transparency Register’.
In terms of the sanctions, one section II respondent notes that ‘Submitting inaccurate and / or
misleading information must be specified as a punishable offence…Suspended lobby groups should
be placed on a public blacklist and should be suspended from expert groups and lose access to the
Commission and Parliament’. One section II respondent identifies that ‘Suspension from the
Commission Register has attracted negative publicity and reputational damage to those affected’
and that this means that the ‘process of removal from the Register must be clear and transparent’.
They then feel that ‘Credibility would be improved with an independent complaint body’.
A total of 7 of the responses are included in the sample. The table below summarises the key
Table 6-21: Themes in response to QB3.2a; n=7 (By language: DE=1, EN=3, FR=1, NL=1, PT=1)
Complaints and alerts make 1 There are insufficient 1
a valuable contribution to resources to deal with
effective implementation of complaints or to make
the Register sufficient checks
The due process should be 1 Organisations themselves 1
strengthened should check compliance
Anonymous complaints are 1 Organisations providing 2
unacceptable: complainant misleading information should
and accused must be be penalised heavily: no
protected from unjustified access and public shaming
attack (see commentary)
Detailed definition of alert 1
and complaint required
Specific question about the 1
Code of Conduct, (see
commentary)
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One respondent explains their reasons why the penalties for misleading information should be
severe: ‘Actually, only the lobbyist or the parliamentarian or EU Administrator submit a report and /
or complaint. Others may have no knowledge of the content of the advice of the lobbyist. Reports
and / or complaints will take place normally only after the decision, because then becomes clear
what the content advisory. And then it's too late. Effects with incorrect information must be strongly
punished. For example, by refusing access to the EU buildings, but also by naming and shaming the
perpetrator’ (translated from Dutch).
Another respondent has a specific question about the Code of Conduct: ‘I think the procedure is fine.
There's just one thing I don't understand and it is about the measures available in the event of non-
compliance with the code of conduct. I don't understand why, in Type of non-compliance number 2
(Non-cooperation with JTRS) the measure says: "Removal from the register, de-activation of the
authorisation for access to European Parliament premises and loss of other incentives" but the
"Formal decision to withdraw access to European Parliament premises" says: "NO". Shouldn't that be
a YES?
And in the number 3 case: "Inappropriate behaviour", it's exactly the same, I think this type of non-
compliance is referring to entities who have had a wrong behaviour and so the measure says
"Removal from the register, de-activation of the authorisation for access to European Parliament
premises and loss of other incentives" but the "Formal decision to withdraw access to European
Parliament premises" says: NO. How is that? Is that a mistake or it is me who is not understanding? I
think the withdrawal of the European Parliament Access premises should be automatically applied.’
Further comments
Word lists (excluding common words) were compiled for responses in English (80) and German (31).
‘new’ words. A review of the word ‘einklang’ (accordance) revealed several very similar responses
from major German companies with the common theme that ‘more efforts are required to ensure
that all stakeholders comply in providing register entries in accordance with the guidelines. Without
such compliance, such stakeholders should not claim the moral high ground when criticising correctly
registered organisations’ (interpreted from the German).
6.4.4 Views on publishing names of suspended organisations (Qn B3.2b)

Summary
of 10 responses are included in the sample. A further four responses have been added from the
these responses.
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Table 6-22: Themes in response to QB3.2b; n=14 (By section: I = 0, II = 5, III = 6, IV = 0, V = 0, VI = 2, X = 1)
Only by making it public X (1) There would need to be II (1) Any sanctioning X (1)
can the system be a proper process in VI (1 org) system should include
checked to see if it is place safeguards against
working simple re-registration
Making it public would II (1) This could only be done II (1 + 1 Use of an independent III (1)
be an important III (2) when the alleged org) body is an opportunity
incentive to provide infraction is proved and III (1 org) to strengthen the
accurate information appeal routes are V (1) Transparency Register
exhausted VI (1 org)
Would provide III (1) No because alerts can II (1)
important information be the result of minor
until a legally binding mistakes
register comes into
force
* III (1), for example, represents the views from one Tier 1 Section III organisation (1) while VI (1 org)
Four22 of respondents (one II, two III, one X) provide positive comments to this question, agreeing
that the names of organisations that are suspended should be made public. One section II
respondent comments that ‘this is absolutely crucial as the threat of bad publicity from suspension
should act as a further incentive to keep registrations and data up to date’. One section V
respondent states that ‘Suspension before a final decision should never be made public’ but adds
that ‘Suspension resulting from a final decision could at most be made public when the gravity makes
such publication indispensable in the public interest’.
Another section II respondent though highlights that ‘sometimes alerts are the result of minor
mistakes’ so names should not be published. Five respondents (one II, one VI from Tier 1 and one
II, one III and one VI from the other organisations) agree with making the names public but only
‘when the alleged infraction is proved and the appeal routes are exhausted’ and ‘with the reservation
that there is a proper process in place’. One section III respondent from the other organisations adds
that ‘The current approach provides an appropriate balance, allowing the public to understand which
organisations are genuinely not complying but protecting the reputation of those whose non-
compliance is temporary and not serious’.
22
The responses from one of the section III respondents covers two of the themes
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Table 6-23: Themes in response to QB3.2b; n=8 (By language: DE=2, EN=5, NL=1)
Only by making it public can 5
the system be checked to
see if it is working
Making it public would be an 2 This could only be done when 1 Unjustified whistleblowing 1
important incentive to the alleged infraction is should be made public too
provide accurate proved and appeal routes are
information exhausted
Sanctions must reflect the 1
seriousness of the violation
All of respondents support making public the names of suspended organisations.
Further comments
Word lists (excluding common words) were compiled for responses in English (118) and German
(33). These words were checked against those in the themes mentioned above to see if there were
any ‘new’ words. A review of the word ‘vorübergehenden’ (temporary) revealed several very similar
responses from major German companies who view temporary exclusion (suspension) as a harsh
punishment since, de facto, it limits interaction with EU institutions and publication would have
further damaging effects. As such, they ask that ‘the name of a suspended organisation should not
be published without giving the organisation the opportunity to correct the error (which could be a
simple mistake)’ (translated from the German).
6.5 Register website – registration and updating (Qn B4.1)

6.5.1 Overview
Respondents were asked about the ease of using the Register website. Although most registered
organisations indicated that the processes were straightforward, more than a third thought they
were ‘satisfactory but can be improved’. Similar figures emerged from the other main stakeholder
groups as illustrated in the table below.
Table 6-24: Views on user-friendliness of the Register website

Individuals
(n=245)
in relation to… (n = 484) (n = 22)
59% straightforward 32% straightforward 31% straightforward
Registration process 33% satisfactory 32% satisfactory 29% satisfactory
5% cumbersome 0% cumbersome 5% cumbersome
55% straightforward 32% straightforward 24% straightforward
Updating process
37% satisfactory 32% satisfactory 30% satisfactory
(annual & partial)
4% cumbersome 0% cumbersome 10% cumbersome
Note: responses of ‘no opinion’ have not been presented in this table
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Further analysis indicated that views were fairly evenly distributed across the sections of the
Register as illustrated below.
I: Professional consultancies etc

(n=53)
II: In-house lobbyists and
associations (n=279)
III: Non-governmental organisations, Straightforward
etc (n=109)
Satisfactory
IV: Research and academic
Cumbersome
institutions (n=19)
V: Organisations representing No opinion
churches etc (n=5)
VI: Sub-national authorities (n=19)
0% 20% 40% 60% 80% 100%
Figure 6-3: Qn B4.1: How user-friendly is in your opinion the Register website in relation to registration?
(Responses from registered organisations by section of the Register)
6.5.2 Views on user-friendliness of the Register website (Qn B4.1)

Summary
total of 12 of the responses are included in the sample. There were 14 responses from individuals to
the open-text box associated with this question. A total of 6 of the responses are included in the
sample.
There were 8 Tier 1 responses received to the open-text box associated with this question. All 8 of
the responses are included in the sample. A further four responses have been added from other
responses.

Registration and X (1) The updating process III (2 org)
updating process is not requires considerable VI (1 org)
overly cumbersome effort
More regular updates III (2) Essential to III (3)
could be provided X (1) automatize the X (1)
checking of
registrations
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Currently updates are III (1) There should be a first III (1)
discouraged other than check before an entry
an annual full update becomes public
Unstable IT system can II (1) Updates should be III (1)
require the updating made to common
process to be repeated dates to improve
several times comparability
Some information III (1) Links to expert groups II (1)
requested is unclear and other EU III (1)
Structures and funding X (1)
would make it easier
for registrants
There is no way of III (1 org) Drop-down menus III (1)
providing an update in should be used
terms of compliance whenever possible
with the Code of
Conduct
There is very little III (1) Additional guidance is III (1)
guidance V (1) needed V (1)
Suspect that many III (2) More detailed III (2 org)
mistakes are accidental headings for VI (1 org)
expenditure could X (1)
make it easier to
calculate what is being
spent
Contributions should III (1 org)
only be released when
more than 30% of the
associations activities
fall within the scope of
the Register
Idea and layout can II (1)
become cumbersome
where it does not work
One respondent (section X) comments that the registration and updating process is not overly
cumbersome. They also suggest that this could be improved ‘to include more regular updates of the
information, for example, twice a year’. Other respondents also suggest an increase in the number
of annual updates with two section III respondents also commenting that this should be undertaken
at least twice per year. They also suggest that ‘the register would be far more effective and precise if
all registrants were required to submit at least two updates per year, and on shared dates i.e. 31
January and 31 July’. Three of the other organisations (two III, one VI), however, comment that the
updating process requires considerable effort.
Further comments (three III, one X) are made on the need for automatic checking of data as they are
entered by registrants to help warn about errors as the update is underway. One section III
RPA | 85
respondent suggests that ‘the introduction of additional smart online measures such as basic
plausibility checks, drop-down menus and in-built checklists of basic requirements could improve
user-friendliness and ensure the accuracy of registrations’. One section II respondent though notes
that the IT system is unstable resulting in the need to ‘to repeat the updating process several times’.
Two Tier 1 respondents (one III, one V) suggests that additional guidance is needed, and this this
could take the form of a ‘specific leaflet presenting the Register and the information required,
“workshop”, email address/phone number where registered organization can submit questions’.
Three of the other organisations (two III, one VI) comment on difficulties with the calculation of
membership fees and that this information should only be released where ‘individual
members…contribute to a predominantly high share...[of]…the association's activities…within a
scope of the Transparency Register’.
of 6 of the responses are included in the sample. The table below summarises the key themes that
Registration and updating 1 More regular updates could 1
process is not overly be provided
cumbersome
Cumbersome registration and 1 Any updates should require 1
updates unfairly favour confirmation of all data
organisations with big
resources.
Further comments
were checked against those in the themes mentioned above to see if there were any ‘new’ words.
No new words were identified.
6.6 Current advantages linked to registration (Qn B5.1)

6.6.1 Overview
(incentives) linked to being on the Register. The Commission has also announced its intention to
soon amend its rules on expert groups to link membership to registration.
Respondents were invited to comment which of these advantages were considered important.
Although individuals and unregistered organisations responded along similar lines to registered
organisations, particular attention is given this last group.
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Table 6-27: Views on importance of advantages granted to registered organisations by number of
responses from registered organisations
Very Somewhat Not important Score*
Advantage granted to registered organisations important important / No opinion (Rank)
Access to Parliament buildings: long-term access
passes to the EP’s premises are only issued to
373 76 35 822 (1)
individuals representing, or working for registered
organisations
Committee public hearings: guests invited to speak
331 107 46 769 (2)
at a hearing need to be registered
Patronage: Parliament does not grant its patronage
311 91 82 713 (3)
to relevant organisations that are not registered
Meetings: organisations or self-employed individuals
engaged in relevant activities must be registered in
397 68 19 862 (1)
order to hold meetings with Commissioners, Cabinet
members and Directors-General
Expert groups: registration in the Transparency
Register is required in order for members to be
appointed (refers to organisations and individuals 386 72 26 844 (2)
appointed to represent a common interest shared
by stakeholders in a particular policy area)
Public consultations: the Commission sends
automatic alerts to registered entities about
consultations in areas of interest indicated by them; 368 87 29 823 (3)
it differentiates between registered and non-
registered entities when publishing the results
Patronage: Commissioners do not grant their
patronage to relevant organisations that are not 308 101 75 717 (4)
registered
Mailing lists: organisations featuring on any mailing
lists set up to alert them about certain Commission 281 146 57 708 (5)
activities are asked to register
*Note that score based on a simple rating scale: Very important = 2, Somewhat important = 1, Not important/
No opinion= 0 multiplied by the number of responses
In relation to the European Parliament, the most important advantage was considered to be
associated with the need to be registered in order to gain access to Parliament buildings.
In relation to the Commission, the most important advantage was considered to be associated with
the need to be registered in order to hold meetings with Commissioners, Cabinet members and
Directors-General. The second most important advantage was seen as the ability to be appointed to
expert groups.
6.6.2 Views on advantages

Summary
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of 8 of the responses are included in the sample. A further four responses are added from the other
responses.

Register could be III (1) Activation of badges III (1)
proactively used if the every day for access VI (1 org)
data quality was better cause administrative
burden
Limitation of four II (1) A more flexible II (1)
people per organisation approach is needed
per day is problematic based on prorata by
number of passes an
organisation has
Incentives are II (1) Incentives to register X (1)
disincentives for not should be made so
registering and are not attractive that removal
appropriate from the Register is
the only sanction that
matters
Restrictions imposed on V (1)
non-registered lobbyists
should only apply to
activities falling within
the scope of the
Register
The quality and detail of II (1 org) Communications V (2)
communications to V (2) should feature the title
registrants regarding of the consultation and
public consultations a direct link to the
needs to be improved relevant webpage
The recording related III (1 org) An EU 'transparency V (1)
benefits should not label' could be
undermine the considered
legitimate operation of
an institution
There should be an V (1)
exemption for local
governments
* II (1), for example, represents the views from one Tier 1 Section II organisation (1) while II (1 org)
represents the views of a Section II organisation (1 org) in the sample of non-Tier 1 respondents
RPA | 88
One section III respondent notes that the Register could be used proactively if the data quality was
better adding ‘instead of just checking if representatives of an expert group is on the register, to use
proactively the data to select additional participants from NGOs’.
One section II respondent commented that incentives are disincentives for not registering and are
not appropriate. They further highlighted that ‘The objective of forcing entities whose activities fall
within the scope of the TR to register should result from a proper legal framework and not from
unilateral decisions from the EU institutions that, without legal basis, deny rights to some entities
which others enjoy’. Conversely, one section X respondent identifies that ‘the incentives to register
should be made so attractive that the only sanction that matters is to be suspended or removed from
the Transparency Register’.
There were also comments on the quality and detail of communications to registrants regarding
public consultations needing to be improved from two section V respondents. They stated that
‘such communications should not only feature the title of the specific consultation and a direct link to
the relevant webpage, but also provide a clear added value and edge to registered entities over non-
registered ones’. They also suggested examples of added value where these include ‘e.g.
information on the contact person(s) responsible for the dossier within the Commission services;
advance indications of intermediate possibilities of ad hoc meetings, hearings, further targeted
consultations, testing sessions; provision of additional materials, documentation and information
that is not accessible to non-registered entities’.
In addition to the comments on the incentives there was also one comment from a section II
respondent on the questionnaire itself, specifically that ‘The above categories do not allow for
ticking boxes of disagreement’.
A total of 7 of the responses are included in the sample. The table below summarises the key themes
Table 6-29: Themes in response to QB5.1; n=7 (By language: EN=4, FR=2, IT=1)
Expert groups and meetings for 1
registered organisations only
European Parliament access for 1
registered organisations only
Public consultation access for 1
registered and non-registered
entities
All benefits are important 2 Issue with the phrase 1
and should be linked to “patronage” (see
presence on the Register commentary)
All Commission/ /Council 2
officials & MEPs should only
meet registered organisations
Mailing list is poor 1
Need to control the access 1
of interest groups
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One respondent echoes several views: ‘More lobbying is involved in policy development, and it is
important that it be registered. Therefore, it is essential that the participation in expert groups or
meetings of the Commission is reserved for listed entities. Regarding access to the European
Parliament, it is a great way to encourage lobbyists to register - no lobbyist wants to lose access to
MEPs' offices. Sponsorship and public hearings are important steps, since they are of a symbolic
aspect.
Public consultations should remain open to non-listed entities, whenever: 1) there is no guarantee
that its answers will be taken into account; 2) where established organizations outside Brussels, but
very specialized in one area, may want to address a very ad hoc consultation. It would make no sense
to require these entities to register if they are only involved in a consultation every two years, and
have no office in Brussels’ (translated from French).
One respondent has a specific issue with the word “patronage”: ‘No patronage should ever be given
to any organisation by EU Commissioners. Assuming here that we are talking about financial
patronage or political patronage. All patronage in its every form is poison and corrupts the
legitimacy of the participants. Nepotism, Cronyism, Embezzlement, Favouritism and every other
word comes to mind as a synonym with the word "patronage". However if the patronage is limited
to "Moral Support" and use of the EU Logo according to the European Parliament website then I see
less of a problem. I would also suggest the use of a different word.’
Further comments
were checked against those in the themes mentioned above to see if there were any ‘new’ words. A
review of the word ‘health’ revealed several identical answers from registered section III
organisations calling for the mandatory registration in the Transparency Register to be required for
organisations’ and bodies’ participation in stakeholder forums (such as the EU Alcohol and Health
Forum). These responses went further by calling for: ‘recordings of meetings directly with the
European Commission should be extended to all levels of officials, such as Head of Units, Advisors
and Policy Officers. The information should be made easily available for the public.’
These views were re-presented for the next question (Qn B6.1 – see below).
6.7 Features of a future mandatory system (Qns B6.1, B6.2)

6.7.1 Overview
There was general support for further interactions between the EU institutions and interest groups
to be conditional upon prior registration and strong support for the Commission's view that the
Council of the EU should participate in the new Interinstitutional Agreement on a mandatory
register.
Summaries of the responses are illustrated overleaf.
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Individual (n=245)
Yes
Unregistered (n=22)
No
No opinion
Registered (n=484)
0% 20% 40% 60% 80% 100%
Figure 6-4: Qn B6.1: Do you believe that there are further interactions between the EU institutions and
interest groups that could be made conditional upon prior registration (e. g. access to MEPs and EU officials,
events, premises, or featuring on specific mailing lists)?
Unregistered (n=22)
Yes
Individual (n=245)
No
No opinion
Registered (n=484)
0% 20% 40% 60% 80% 100%
Figure 6-5: Qn B6.2: Do you agree with the Commission's view that the Council of the EU should participate
in the new Interinstitutional Agreement on a mandatory register?
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6.7.2 Views on access being conditional on registration (Qn B6.1)
Summary
of 10 of the responses are included in the sample. Three additional responses have also been
included from the other organisations. The table below summarises the key themes that have been
extracted from these responses.
Table 6-30: Themes in response to QB6-1; n=13 (By section: I = 0, II = 1, III = 5, IV = 0, V = 2, VI = 2, X = 3)

More might be done X (1) Council and European V (1)
to ensure that other Council should join the X (1)
parts of the EU Register and look for
administration rely on incentives for lobbyists
the Transparency to register
Register
Registration should be III (1) Institutions should X (1)
a requirement for VI (1 org) check whether visitors
access X (2) entering premises fall
within the scope of the
Officials should not III (1)
attend events organised VI (1 org)
by non-registered X (1)
lobbyists
Commission, III (1) The EC's policy of not III (1)
Parliament and X (1) meeting unregistered X (3)
Council should make it lobbyists should be
difficult for a lobbyist extended to cover all
to influence decision- Commission officials
making without involved in EU
signing up to the legislation
Register
Members of the III (1)
European Parliament VI (1 org)
should list their X (1)
interactions with lobby
groups
A future mandatory II (1) A mandatory register III (2)
register should not V (2) that is legally binding is
impose undue required
administrative burden
on registrants
RPA | 92
Table 6-30: Themes in response to QB6-1; n=13 (By section: I = 0, II = 1, III = 5, IV = 0, V = 2, VI = 2, X = 3)
An extensive and V (1) Meetings with lobbyists III (1)
detailed record of should be published VI (1 org)
meetings and contacts X (1)
would have drawbacks
Current transparency III (1)
provisions should be X (1)
extended down to Head
of Unit level
Existing measures III (1) Organisations with bad III (1)
need to be reviewed entries should be
and new ones temporarily suspended
considered
Grave or repeat III (1)
offences should result
in a ban from the
Register
Mandatory system is V (1) Any restriction must be II (1)
only viable if it justified and
respects and fits the proportionate to the
nature of actors and intended objective
organisations
concerned
Restrictions on VI (1) Direct access by III (1 org)
interactions of EU democratically elected VI (1)
institutions on EU governments should be
matters that are the encouraged, not linked
competence of to registration
national/ regional/
local authorities is
contrary to Article 4
TEU
A variety of suggestions is made regarding interactions between the EU institutions and interest
groups that could be made conditional upon prior registration. Four respondents (one III, two X
from Tier 1 and one VI from the other organisations) think that registration should be a requirement
for access to ‘Commission expert groups and advisory groups or European Parliament intergroups
and other cross-party groups’. One section X respondent suggests that ‘obligations…to only meet
with representatives of registered entities and that details of those meetings shall be published
online…to extend downwards to Directors and Heads of Units’.
There are also suggestions from two Tier 1 respondents (one V, one X) that the Council and
European Council should join the Register and look for incentives for lobbyists to register. Both
make suggestions as to what these incentives should be, whereby unregistered lobbyists should not:
RPA | 93
 have access to Parliament/Commission premises;
 be able to get lobby meetings, or participate in expert groups, advisory groups or market access
groups;
 advise the Parliament as part of intergroups, parliamentary hearings or in any other advisory
function;
 advise the Commission as part of high-level groups, consultative committees, expert groups and
other consultative bodies; and
 be able to organise events at the European Parliament or the Commission.
There were comments requesting that meetings with lobbyists should be published (two section III
respondents plus one section VI from the other organisations) but also that an extensive and
detailed record of meetings and contacts would have drawbacks (one section V respondent). The
section III respondent added ‘When publishing the subject of meetings, information should include
reference to the concrete legislative procedure…For the European Parliament president, vice-
presidents, group presidents, committee chairs and rapporteurs publishing their meetings should be
mandatory. Other MEPs should publish their meetings on a voluntary basis’. The section V
respondent added that the drawbacks would be ‘bureaucratisation…and for the possible negative
impact on the healthiness of the policy- and decision-making process’.
Table 6-31: Themes in response to QB6-1; n=8 (By language: DE=1, EN=2, FR=5)
Yes, to any measures that 1 Registration should be a 1 Institutions should check 1
encourage registration requirement for access whether visitors entering
premises fall within the
scope of the Transparency
Register
Officials should not attend 1
events organised by non-
registered lobbyists
The EC's policy of not 1
meeting unregistered
lobbyists should be
extended to cover all
Commission officials
involved in EU legislation
Members of the European 2
Parliament should list their
interactions with lobby
groups
Meetings with lobbyists 2
should be published
Mailing lists should be for 1
all, registered and non-
registered
RPA | 94
One respondent explains why all appointments should be publically available: ‘appointments of
officials and MPs should be public in order to obtain a "legislative footprint" for each text’.
Further comments
No new words were identified.
6.7.3 Views on Council participation (Qn B6.2)

Summary
There were 11 Tier 1 responses received to the open-text box associated with this question. Eight of
the responses are included in the sample. A further three responses have been added from other
responses.

Council is falling behind X (1) Council should become II (2)
compared with other a full member of the III (3 + 1
institutions and some Transparency Register org)
Member States X (3)
Subject to the VI (1 org) European Council, II (1)
particularities of the Council of the EU and III (3 + 1
Council permanent org)
representations should
be included
Council participation X (1)
should be restricted to
EU officials
Unregistered lobbyists III (1) There needs to be a III (1)
should not be able to legally binding register
get to meetings
The register should be III (1)
revised and a legally-
binding system set up
even without the
Council
Transparency has to be III (1) Council should publish III (1)
ensured throughout the meetings as does the
whole decision-making EC
process
RPA | 95
All written input by III (1)
lobbyists should be
published in a central
location
* III (3 + 1 org), for example, represents the views from three Tier 1 Section III organisation (3) and the views
of a Section III organisation (1 org) in the sample of non-Tier 1 respondents
Nine respondents (two II, three III, three X from Tier 1 plus one III from the other organisations) feel
that the Council should become a full member of the Transparency Register. Of these, four
respondents (one II, three III from Tier 1 and one section III from the other organisations) suggested
that this should cover the European Council, Council of the EU and permanent representations with
one adding ‘this would ideally mean that capitals and Permanent representations would be included,
not only the Council secretariat, and we do realize the political implications of such a step’. One
section X respondent felt that Council participation should be restricted to EU officials, specifying
‘the staff of the President of the European Council and the secretariat of the Council of Ministers’.
One other organisation (section III) added that this should be ‘Subject to respecting the
particularities of the Council’.
There was again comment that unregistered lobbyists should not be able to gain access to meetings
(one section III respondent) who added ‘Permanent Representations of member states should also
pledge to no longer meet with unregistered lobbyists. The rotating presidency should also not have
contact with unregistered lobbyists – both in Brussels and “at home”’.
A total of 7 of the responses are included in the sample. The table below summarises the key themes
Council is falling behind 1 Council should become a full 7
compared with other member of the Transparency
institutions and some Member Register
States
European Council, Council of 2
the EU and permanent
representations should be
included
All respondents stated that the council of the EU should participate.
Further comments
RPA | 96
The word ‘system’ was reviewed and provided a good example of how many respondents see the
need for a unified ‘system’ to integrate transparent lobbying into the democratic process as
illustrated in the word tree below.
Figure 6-6: Overview of desire for a unified ‘system’ (based on comments related to Council participation –
Qn B6.2)
6.8 Looking beyond Brussels (Qn B7.1)

6.8.1 Overview
Respondents were generally supportive of the Register in comparison to ‘lobby registers’ at Member
State level.
Registered (n=484)
Better
Unregistered (n=22) Worse

Neither
No opinion
Individual (n=245)
0% 20% 40% 60% 80% 100%
Figure 6-7: Qn B7.1: How does the Transparency Register compare overall to 'lobby registers' at the EU
Member State level?
RPA | 97
6.8.2 Views on MS ‘lobby registers’ (Qn B7.1)
Summary
There were 9 Tier 1 responses received to the open-text box associated with this question. A total of
8 of the responses are included in the sample. A further three responses have been added from the
these responses.
Table 6-34: Themes in response to QB7.1; n=11 (By section: I = 0, II = 2, III = 5, IV = 0, V = 1, VI = 2, X =1)
EU is relatively X (1) Better to compare EU III (1)
transparent but needs institutions to USA X (1)
to do more
The EU register goes II (1) The US legislation V (1)
further in its reporting should continue to
requirements than constitute the key
almost all national reference point
registers
EU should set best III (1) Slovenia and Lithuania III (1)
practice standards to are positive examples X (1)
serve as an example for
Member States
The EU Transparency III (1) Potential to learn from III (3 + 1
Register is ahead in good and bad practice org)
some areas but lacks in EU Member States, VI (1)
behind in a majority of but also from other
elements when countries such as
compared with Canada
international best
practice
There are several key III (1) There is a number of III (1)
areas in which the EU elements that emerge
register can significantly from evaluation of
improve existing national
registers
Testing must be done III (1 org)
to identify if a system
that works well at
Member State level
can be effectively
applied at EU level
RPA | 98
Table 6-34: Themes in response to QB7.1; n=11 (By section: I = 0, II = 2, III = 5, IV = 0, V = 1, VI = 2, X =1)
Most Member States V (1) Needs to be more II (1)
have a mandatory coordination of
registration system, but national registers with
this does not mean the the EU one
EU should use a
mandatory instrument
Many Member States III (1 org) A lobby EU Directive VI (1 org)
do not have any V (1) might be useful
registration tool
The specificity of V (1) The Committee of the VI (1)
various entities needs to Regions register
be recognised should be used for
regional and local
authority organisations
* V (1), for example, represents the views from one Tier 1 Section V organisation (1) while VI (1 org)
The majority of the comments focus on best practice in other countries, with specific mentions of
the USA (one III, one X), Canada (three III), Australia (one V), Slovenia and Lithuania (one III, one X),
Austria (one VI), Hungary (one VI) and Ireland (one VI). One section III respondent notes that best
practice seems to comprise of ‘the mandatory dimension of the register, the quality of the data
required, a sufficiently resourced secretariat to ensure a proper checks in the entries, and follow up
complaints, the existence of sanctions are all elements that emerge in the evaluation of existing
national registers’. One section V respondent cautions though that ‘The trend existing among the
Member States…does not automatically make the EU option for a mandatory instrument advisable.
The question of whether mandatory systems introduced at the national level “have worked”, yielding
the expected results, should be carefully addressed. Contacts with the national responsible
authorities are in this sense crucial’. One section VI respondent notes that ‘despite being in principle
mandatory, [Austria’s] transparency register has so far had little impact’. A section III respondent
from the other organisations states that ‘differences in EU and Member State level practices are
reflections of the nature of activities at those levels. Any adaptions to the Transparency Register
based upon Member State actions must be done only after testing whether a system which works at
national level can effectively be applied at EU level’.
One section III respondent notes that although ‘A positive example is Slovenia, where definitions of
both lobbying and lobbied targets are fairly broad…the latter fails to include employees of state- and
municipal owned companies and external advisors when legislation is outsourced’.
A section X respondent notes that ‘both [Slovenia and Lithuania] have an independent oversight
agency equipped with strong investigative powers. Their national lobby regulations include sanctions
to deter and punish organisations that do not comply with their transparency obligations’.
One section III respondent reports on best practice in Canada stating ‘Canada has a mandatory lobby
register with an independent authority overseeing it…The Commissioner of Lobbying…provides
personalised advice to registrants…and approves registrations only when it is satisfied that
RPA | 99
registrations are accurate and complete and registrants have certified the accuracy of their
registrations’.
In terms of sanctions, one section III respondent notes that in Canada ‘In case of violations (non-
registration mostly) there are financial sanctions, public naming-and-shaming and in severe cases
even convictions in court that can lead to imprisonment’.
Searching for information is also reported as being much easier in Canada, with one section III
respondent noting that ‘The information that is published is not too dissimilar to the reports
published by the European…but everything is available on a central website in open data (machine
readable) format that has a great search function and must be updated monthly’.
One section V respondent provides detailed comments on the definition of ‘lobbying’ from both the
US and Australia, noting for example that, in Australian legislation, ‘Lobbyist… does not include: a.
charitable, religious and other organisations or funds that are endorsed as deductible gift recipients;
b. non-profit associations or organisations constituted to represent the interests of their members
that are not endorsed as deductible gift recipients...’.
One section VI respondent from the other organisations suggests that a ‘lobby EU Directive might be
useful for avoiding the lack of good practices or for a better implementing the lessons learned’.
EU should set best practice 1
standards to serve as an
example for Member States
It is often easier to find info 1 The EU Transparency 2 Potential to learn from 1
from the Register than from Register is ahead in some good and bad practice in
our national register areas but lacks behind in a EU Member States, but
majority of elements when also from other countries
compared with such as Canada
international best practice
Law firms should not be 1
excluded
UK parliament is not an 1
example of good practice
One respondent sums up several views: ‘The situation is very diverse in the EU. Some countries have
comprehensive registration systems; others don't have it at all. There should be further
harmonization, but a strong example should be set at the EU level.’
RPA | 100
Further comments
Although no new words were listed, exploration of the word ‘best’ led to some very detailed
responses from several registered section III organisations including reference to a 2015 report by
Transparency International which looked at lobbying in Europe using a range of indicators. The
responses also note that the ‘seven EU Member States that have specific lobbying regulations
(Austria, France, Ireland, Lithuania, Poland, Slovenia and the United Kingdom) have all opted for a
register as the cornerstone of their approach, requiring lobbyist registration and, in most cases, a
periodic reporting of activities’.
6.9 Additional comments

6.9.1 Summary
There were 89 responses from organisations which provided additional comments. A total of 11 of
the responses are included in the sample.
There were 27 responses from individuals which provided additional comments. A total of 7 of the
responses are included in the sample.
6.9.2 Comments from organisations

of 8 of the responses are included in the sample. A further three comments are added from
responses by other organisations. The table below summarises the key themes that have been
extracted from these responses.
Table 6-36: Themes in response to Part B Final Comments; n=11 (By section: I = 0, II = 6, III = 3, IV = 0, V = 0,
VI = 1, X = 1)
Other EU institutions are X (1) All interinstitutional III (2)
encouraged to use the agreement preparatory
framework created by the meetings should be
new IIA open to the public and
web-streamed
The draft agreement, III (2)
proposed changes,
agendas and minutes
should be available
online
There should not be II (2) The proposal should III (2)
additional administrative include regular
burdens on registrants evaluation and revision
mechanisms
Support a legally binding II (3) Further strengthening of II (1)
mandatory register III (1 org) the incentives should be
X (1) used to me a 'de facto'
mandatory register
RPA | 101
Table 6-36: Themes in response to Part B Final Comments; n=11 (By section: I = 0, II = 6, III = 3, IV = 0, V = 0,
VI = 1, X = 1)
There is also a duty on the II (1 org) Discussion needed on VI (1)
'lobbied' to act ethically elected representatives
and avoid corruption and to obtain formal
bias speaking rights in
Parliament
Sanctions need to be X (1)
implemented when the
code of conduct is
violated
There should be a X (1)
connection between the
and the legislative
footprint
An outside body should III (1 org)
be the arbiter of
complaints
Public consultations II (1 org) The introduction of an II (1 org)
should focus on opinions associations hearing
from representative should be considered
organisations
* II (2), for example, represents the views from two Tier 1 Section II organisations (2) while II (1 org)
represents the views of a Section II organisation (1 org) in the sample of non-Tier 1 respondents
Five respondents (three II, one III from Tier 1 and one section III from the other organisations) again
highlight the need for a mandatory register. One of the section II respondents adds that ‘we would
like to make the register even more “de facto mandatory” through further strengthening the
incentives to register’. Two section II respondents state that there should not be additional
administrative burdens on registrants, with one suggesting that ‘Therefore, we need to ensure that a
mandatory register is reformed to include:
 An effective system that continues to motivate all organisations influencing EU decision-

making to sign up to the EU Transparency Register
 Coverage of all EU institutions involved in the political decision-making, including the Council
 A robust system with better official definitions, monitoring procedures and sanctions that
encourages registrants to provide accurate information’.
One section X respondent identifies the need for a connection between the Transparency Register
and the legislative footprint, noting that ‘Rapporteurs…should be obliged to disclose their meetings
with lobbyists… MEPs should be enabled to disclose their meetings with lobbyists on their personal EP
website, linked to the Transparency Register’.
One section VI respondent suggests the need for ‘an open discussion about the possibility for elected
representatives of cities to receive formal speaking rights in the European Parliament in areas where
they are concerned (e.g. urban-related topics)’.
RPA | 102
A section III respondent from the other organisations notes that ‘We think that it is not satisfactory
in the future for the JTRS to be judge and party in any future mandatory complaints procedure. An
outside body would be a wise arbiter with an increased role for the Ombudsman’.
One section II respondent from the other organisations believes that ‘A public consultation should
provide interested parties the opportunity to express and show what are the impacts on the groups
they represent their views. In our view, the introduction of an "Associations hearing" as example in
Germany [should] be seriously considered’. They also add that ‘public consultation must not seek to
obtain a public opinion. Other instruments, such as the Euro Barometer surveys, are a significantly
more suitable instrument’.
6.9.3 Comments from individuals

themes that have been extracted from these responses. The themes have been grouped to combine
similar issues, to highlight positive and negative aspects that have been raised on those issues and to
draw in suggested solutions to the negative issues.
Table 6-37: Themes in response to QB8; n=8 (By language: DE=2, EN=5, FR=1) VI = 1)
Disclose lobbyists source of 1
financial support
Low paid are little represented 1
in Europe, Register should
enable a view on the balance of
labour and capital (see
commentary)
Respect the requirements of the 1
European Citizen’s Initiative
Current negotiations of free 1
trade agreements risk
undermining all confidence in
transparency
Lobbying v democracy (see 1
commentary)
US federal lobbying and 1
disclosure system is worth
looking at
Unsurprisingly, there is a diverse set of comments. One respondent is concerned that: ‘The problem
is lobbying OR the operation of a democratic Union?’ (Translated from French)
Another comment is: ‘Since low income populations in Europe are not represented by anyone except
in terms of parliamentary voting (which is also true for entrepreneurs […] (but) they are still
represented by a variety of economic units and organizations) - there should exist some kind of
method to decide how often interests of labour and of capital respectively are heard in European
institutions, […] to see how balanced the whole process is in fact!’
On a different matter, one respondent raises: ‘respect the opinion of citizens in ICE (European
Citizens Initiative) without legal quibbles’ (translated from French).
RPA | 103
6.9.4 Final comments
Although no new words were listed, examination of the use of the word ‘influence’ provided a useful
overview of the need and role for a transparency register role as illustrated overleaf.
RPA | 104
Figure 6-8: Word tree based on the use of the word ‘influence’ in final comments
RPA | 105
ANNEX 1
THE QUESTIONNAIRE
Transparency Register Study

RPA | A1-1
Public Consultation on a proposal for a mandatory
Fields marked with * are mandatory.
Public Consultation on a proposal for a mandatory Transparency

Register
The European Commission seeks the views of all interested parties on the performance of the current
Transparency Register for organisations and self-employed individuals engaged in EU policy-making
and policy implementation and on its future evolution towards a mandatory scheme covering the
European Parliament, the Council of the EU and the European Commission.
QUESTIONNAIRE
* Are you responding as:

An individual in my personal capacity
The representative of an organisation registered in the Transparency Register
The representative of an organisation not registered in the Transparency Register
* I am a resident in (only one choice possible):

Austria
Belgium
Bulgaria
Cyprus
Czech Republic
Germany
Denmark
Estonia
Greece
Spain
Finland
France
Hungary
Croatia
Ireland
Italy
1
Italy
Lithuania
Luxembourg
Latvia
Malta
Netherlands
Poland
Portugal
Romania
Sweden
Slovenia
Slovak Republic
United Kingdom
Other country
* Please provide your Register ID no:
You can register here
* Name of the organisation:
* The organisation's head office is in:

Austria
Belgium
Bulgaria
Cyprus
Czech Republic
Germany
Denmark
Estonia
Greece
Spain
Finland
France
Hungary
Croatia
Ireland
Italy
Lithuania
Luxembourg
Latvia
2
Latvia
Malta
Netherlands
Poland
Portugal
Romania
Sweden
Slovenia
Slovak Republic
United Kingdom
Other country
* *Your organisation belongs to the following type:

See a descritption of the below categories here
Professional consultancies
Law-firms
Self-employed consultants
Companies and groups
Trade and business associations
Trade unions and professional associations
Other organisations including: event-organising entities (profit or non- profit making);
interest-related media or research oriented entities linked to private profit making interests;
ad-hoc coalitions and temporary structures (with profit-making membership)
Non-governmental organisations, platforms, networks, ad-hoc coalitions, temporary structures
and other similar organisations
Think tanks and research institutions
Academic institutions
Organisations representing churches and religious communities
Regional structures
Other sub-national public authorities
Transnational associations and networks of public regional or other sub-national authorities
Other public or mixed entities, created by law whose purpose is to act in the public interest
* Other profile
Contact for this public consultation:
* Name
* Surname
3
* Email address
This information will not be published:
A. GENERAL PART (7 questions)
1. Transparency and the EU
1.1 The EU institutions interact with a wide range of groups and organisations representing specific
interests. This is a legitimate and necessary part of the decision-making process to make sure that
EU policies reflect the interests of citizens, businesses and other stakeholders. The decision-making
process must be transparent to allow for proper scrutiny and to ensure that the Union's institutions
are accountable.
* a) Do you agree that ethical and transparent lobbying helps policy development?
Fully agree
Partially agree
Disagree
No opinion
Comments or suggestions (Optional)
3000 character(s) maximum
* b) It is often said that achieving appropriate lobbying regulation is not just about transparency, i.e.
shedding light on the way in which lobbyists and policy-makers are operating. Which of the below
other principles do you also consider important for achieving a sound framework for relations with
interest representatives?
More than one answer possible
Integrity
Equality of access
Other (please elaborate in the comments box below)
No opinion
4
* c) In your opinion, how transparent are the European institutions as public institutions?
They are highly transparent
They are relatively transparent
They are not transparent at all
No opinion
* 1.2 The Transparency Register provides information to politicians and public officials about those
who approach them with a view to influencing the decision-making and policy formulation and
implementation process. The Register also allows for public scrutiny; giving citizens and other
interest groups the possibility to track the activities and potential influence of lobbyists.
Do you consider the Transparency Register a useful tool for regulating lobbying?
Very useful
Somewhat useful
Not useful at all
No opinion
2. Scope of the Register
* 2.1 Activities covered by the Register include lobbying, interest representation and advocacy. It
covers all activities carried out to influence - directly or indirectly - policymaking, policy
implementation and decision-making in the European Parliament and the European Commission, no
matter where they are carried out or which channel or method of communication is used.
This definition is appropriate:
Fully agree
Partially agree
Disagree
No opinion
5
* 2.2 The Register does not apply to certain entities, for example, churches and religious communities,
intergovernmental organisations and their diplomatic missions. Regional public authorities and their
representative offices do not have to register but can register if they wish to do so. On the other
hand, the Register applies to local, municipal authorities and cities as well as to associations and
networks created to represent them.
The scope of the Register should be:
Changed to exclude certain types of entities (please elaborate in the comments box below)
Changed to include certain types of entities (please elaborate in the comments box below)
Preserved the same as currently
No opinion
3. Register website
3.1 What is your impression of the Register web

site?
No
Good Average Poor
opinion
*Design and structure
*Availability of information / documents
*Ease of search function
*Accessibility (e.g. features for visually impaired

persons, ease of reading page)
*Access via mobile devices
6
4.Additional comments
Final comments or ideas on any additional subjects that you consider important in the context of this
public consultation (Optional)
If you wish you may provide additional information (position papers, reports, etc) in support of your
answers to this public consultation. Please upload no more than three files of up to 1Mb each.
Attachments above this number willl not be considered.
Attach files
End of Part A
Part B includes questions that require a certain knowledge of the

Transparency Register. Proceed to Part B (optional).
* Do you want to proceed to Part B ?

Yes
No
B. SPECIFIC PART (13 questions)
1. Structure of the Register
* 1.1 The Register invites organisations to sign up under a particular section, for example, professional
consultancies, NGOs, trade associations, etc (Annex I of the Interinstitutional Agreement).
Have you encountered any difficulties with this categorisation?
Yes
No
No opinion
7
2. Data disclosure and quality
* 2.1 Entities joining the Register are asked to provide certain information (contact details, goals and
remit of the organisation, legislative dossiers followed, fields of interest, membership, financial data,
etc) in order to identify the profile, the capacity of the entity and the interest represented (Annex I of
the Interinstitutional Agreement).
The right type of information is required from the registrant:
Fully agree
Too much is asked
Too little is asked
No opinion
* 2.2 It is easy to provide the information required:

Fully agree
Partially agree
Disagree
No opinion
* 2.3 Do you see any room for simplification as regards the data disclosure requirements?
Yes
No
No opinion
* 2.4 What is your impression of the overall data quality in the Register:
Good
Average
8
Average
Poor
No opinion
3. Code of Conduct and procedure for Alerts and Complaints
* 3.1 The Code of Conduct sets out the rules for all those who register and establishes the underlying
principles for standards of behaviour in all relations with the EU institutions (Annex III of the Interinstit
utional Agreement).
The Code is based on a sound set of rules and principles:
Fully agree
Partially agree
Disagree
No opinion
* 3.2 Anyone may trigger an alert or make a complaint about possible breaches of the Code of
Conduct. Alerts concern factual errors and complaints relate to more serious breaches of behavioural
nature (Annex IV of the Interinstitutional Agreement).
a) The present procedure for dealing with alerts and complaints is adequate:
Fully agree
Partially agree
Disagree
No opinion
* b) Do you think that the names of organisations that are suspended under the alerts and complaints
should be made public?
Yes
No
No opinion
9
No opinion
4. Register website – registration and updating
4.1 How user-friendly is in your opinion the Register

website in relation to registration and updating?
Satisfactory but can No

Straightforward Cumbersome
be improved opinion
*Registration process
*Updating process
(annual & partial)
5. Current advantages linked to registration
5.1 The European Parliament and the European Commission currently offer certain practical
advantages (incentives) linked to being on the Register. The Commission has also announced its
intention to soon amend its rules on Expert groups to link membership to registration.
Which of these advantages are important to you?
Very Somewhat Not No

important important important opinion
*Access to Parliament buildings:

long-term access passes to the EP's
premises are only issued to
individuals representing, or working
for registered organisations
10
*Committee public hearings:
guests invited to speak at a hearing
need to be registered
*Patronage: Parliament does not

grant its patronage to relevant
Very Somewhat Not No

important important important opinion
*Meetings: organisations or
self-employed individuals engaged in
relevant activities must be registered
in order to hold meetings with
Commissioners, Cabinet members
and Directors-General
*Public consultations: the

Commission sends automatic alerts to
registered entities about consultations
in areas of interest indicated by them;
it differentiates between registered
and non-registered entities when
publishing the results
*Patronage: Commissioners do not

grant their patronage to relevant
*Mailing lists: organisations featuring

on any mailing lists set up to alert
them about certain Commission
activities are asked to register
*Expert groups: registration in the

Transparency Register is required in
order for members to be appointed
(refers to organisations and individuals
appointed to represent a common
interest shared by stakeholders in a
particular policy area)
11
6. Features of a future mandatory system
* 6.1 Do you believe that there are further interactions between the EU institutions and interest groups
that could be made conditional upon prior registration (e. g. access to MEPs and EU officials, events,
premises, or featuring on specific mailing lists)?
Yes
No
No opinion
* 6.2 Do you agree with the Commission's view that the Council of the EU should participate in the new
Interinstitutional Agreement on a mandatory Register?
Yes
No
No opinion
7. Looking beyond Brussels
* 7.1 How does the Transparency Register compare overall to 'lobby registers' at the EU Member
State level?
It is better
It is worse
It is neither better, nor worse
No opinion
Good practices or lessons learned at the EU Member State level to be considered, or pitfalls to be
avoided. (Optional)
12
8. Additional comments
Final comments or ideas on any additional subjects that you consider important in the context of this
public consultation (Optional)
* Publication of your consultation

I agree to my contribution being published.
I do not agree to my contribution being published.
Justification:
Specific privacy statement
13
Annex 2A: Summary of Campaign Responses (for Part A)
Campaign 1 2 3 3
Are you responding as: The representative of an The representative of an An individual in my personal The representative of an
organisation not registered in the organisation not registered in the capacity (n=37) organisation registered in the
Transparency Register (n=32) Transparency Register (n=25) Transparency Register (n=11)
The representative of an
organisation not registered in the
Transparency Register (n=1)
I am a resident in (only one choice 10 MS represented
possible):
The organisation's head office is Germany (n=28) Austria (n=25) 6 MS represented
in: Austria (n=4)
Your organisation belongs to the Other sub-national public Other sub-national public Non-governmental organisations,
following type: (Corresponding authorities (VI) authorities (VI) platforms, networks, ad-hoc
Register Group) coalitions, temporary structures
and other similar organisations (III)
Other profile various local authorities various local authorities
a) Do you agree that ethical and Fully agree (n=31) Fully agree (n=25) Fully agree (n=32) Fully agree (n=7)
transparent lobbying helps policy Partially agree (n=1) Partially agree (n=4) Partially agree (n=5)
development? Disagree (n=1)
Comments or  The priority should be to  The priority should be to  Checks and balances are  Ethical and transparent
suggestions (Optional) regulate the influence of regulate the influence of needed to take account of lobbying are good for policy
[relevant themes are shown] organisations and individuals organisations and individuals different interests within making
representing special interests representing special interests society  Ethical and transparent
 Public authorities cannot be  Public authorities cannot be  Transparency requirements lobbying needs to be defined
equated to lobbying or as equated to lobbying or as should extend to all 30,000  Transparency requirements
stakeholders stakeholders Commission (and agency should extend to all 30,000
staff) Commission (and agency
 EU decision-makers should staff)
be banned from meeting with  Full minutes or meeting
unregistered lobbyists reports should be taken in far
 Meetings with lobbyists more meetings
should be published online  Transparent lobbying does
 Transparency in lobbying is not equate to ethical
more than just the lobby lobbying
register  Checks and balances are
needed to take account of

RPA | A2-1
Campaign 1 2 3 3
different interests within
society
 Transparency in lobbying is
more than just the lobby
register
 Meetings with lobbyists
should be published online
b) It is often said that achieving Integrity (n=32) Integrity (n=23) Other (n=29) Other (n=12)
appropriate lobbying regulation is + equality of access (n=2) Equality of access (n=21) Integrity (n=7) + Integrity (n=2)
not just about transparency, i.e. + other (n=8) Equality of access (n=6) + Equality of access (n=3)
shedding light on the way in which No opinion (n=2)
lobbyists and policy-makers are
operating. Which of the below
other principles do you also
consider important for achieving a
sound framework for relations
with interest representatives?
More than one answer possible
Comments or  A transparent administration  Elected local politicians have  Privileged/unequal access by  Transparent lobbying does
suggestions (Optional) ensures a record of decisions the same democratic business lobbies should be not equate to ethical
[relevant themes are shown] taken legitimacy as members of the limited lobbying
 Equality of access should be European Parliament  Account must be taken of the  Privileged/unequal access by
ensured through the whole  Regional public authorities imbalance between lobbying business lobbies should be
decision-making process and local, municipal resources between private limited
 Public bodies are treated in authorities and cities should and public interests  Account must be taken of the
the same way as commercial be treated equally imbalance between lobbying
lobbyists (and should not be) resources between private
and public interests
 Public interests must
ultimately prevail
 Lobbying on behalf of
oppressive regimes should be
prevented
 No “gifts” from lobbyists to
officials

RPA | A2-2
Campaign 1 2 3 3
c) In your opinion, how They are relatively transparent They are relatively transparent No opinion (n=26) No opinion (n=10)
transparent are the European (n=32) (n=24) They are relatively transparent They are relatively transparent
institutions as public institutions? They are highly transparent (n=1) (n=6) (n=2)
They are not transparent at all
(n=5)
Comments or  European institutions largely  European institutions largely Open data must be implemented The EU institutions have introduced
suggestions (Optional) work transparently and the work transparently and the to ensure that EU documents and some important transparency
[relevant themes are shown] legislative process can be legislative process can be information are published online measures. However, there is much
tracked well tracked well and made easily available to that could be improved across the
 Trilogues and criteria for  Trilogues and criteria for citizens. EU institutions to boost
public consultations should be public consultations should be transparency. Lobby register: As
transparent transparent mentioned elsewhere there should
 Decisions on selection of  Decisions on selection of be a legally-binding register with
members for expert groups members for expert groups comprehensive disclosure
are justified are justified requirements and an active
 Negotiations on the last IIA on
the transparency register were
not in public
1.2 The Transparency Register Somewhat useful (n=31) Not useful at all (n=25) Somewhat useful (n=35) Somewhat useful (n=12)
provides information to politicians Not useful at all (n=1) Very useful (n=1)
and public officials about those No opinion (n=1)
who approach them with a view to
influencing the decision-making
and policy formulation and
implementation process. The
Register also allows for public
scrutiny; giving citizens and other
interest groups the possibility to
track the activities and potential
influence of lobbyists. Do you
consider the Transparency
Register a useful tool for
regulating lobbying?
Comments or  Transparency Register is a  Transparency Register is ill-  Transparency Register should  Transparency Register should
suggestions (Optional) useful tool conceived be mandatory and legally be mandatory and legally
 There are exceptions for large binding binding

RPA | A2-3
Campaign 1 2 3 3
[relevant themes are shown]  The Commission has only be stakeholders and differences  Register must cover all  Information must be accurate
willing to hold high-level talks between regional and local lobbyists and up-to-date
with representatives of local authorities  Information must be accurate  Negotiations on legally binding
authorities and municipal  Disclosure of lobbying budgets and up-to-date lobby register should be in
authorities after registration seems not to work in many  There should be adequate place by 2017
 No provisions to ensure cases sanctioning capacities  There needs to be a clear
equality of access to decision- threshold for registration
makers which clarifies what
constitutes lobbying and what
does not
2.1 Activities covered by the Partially agree (n=32) Disagree (n=25) Fully agree (n=33) Fully agree (n=12)
Register include lobbying, interest Partially agree (n=3)
representation and advocacy. It No opinion (n=1)
covers all activities carried out to
influence - directly or indirectly -
policymaking, policy
implementation and decision-
making in the European
Parliament and the European
Commission, no matter where
they are carried out or which
channel or method of
communication is used. This
definition is appropriate:
Comments or  The broad definition has led to  There should be no exceptions  Support for a broad definition  Support for a broad definition
suggestions (Optional) misunderstandings in the past where direct or indirect  All efforts to weaken the  All efforts to weaken the
[relevant themes are shown]  The scope is too imprecise and influence is identified definition should be resisted definition should be resisted
could catch MEP campaign
events and information events
at the Commission
2.2 The Register does not apply to Changed to exclude certain types Changed to exclude certain types Changed to include certain types of Changed to include certain types of
certain entities, for example, of entities (please elaborate in the of entities (please elaborate in the entities (please elaborate in the entities (please elaborate in the
churches and religious comments box below) (n=32) comments box below) (n=25) comments box below) (n=37) comments box below) (n=12)
communities, political parties,
Member States' government
services, third countries'
governments, international

RPA | A2-4
Campaign 1 2 3 3
intergovernmental organisations
and their diplomatic missions.
Regional public authorities and
their representative offices do not
have to register but can register if
they wish to do so. On the other
hand, the Register applies to local,
municipal authorities and cities as
well as to associations and
networks created to represent
them. The scope of the Register
should be:
Comments or  Direct representatives of local  Regional public authorities  Transparency Register should  Registration should depend on
suggestions (Optional) authorities should be and local, municipal cover all actors that have an the nature of the activity and
[relevant themes are shown] exempted of registering in the authorities and cities should impact on EU decision-making not the type of entity
Transparency Register be treated equally  Embassies and third countries  All interest representatives
 The influence of direct  Direct representatives of local should be covered by the that undertake lobbying
representatives of local authorities should be Register activities should be registered
authorities should not be exempted of registering in the  Churches and religious  Mandatory registration is
equated with the activity of Transparency Register communities should be required
private interest groups included in the Register  Regional public authorities
 Law firms, PR firms and think and local, municipal
tanks should be included and authorities and cities should
should declare all their clients be treated equally
 Regional public authorities
and local, municipal
authorities and cities should
be treated equally

RPA | A2-5
Campaign 1 2 3 3
3.1 What is your impression of the Average (n=31) Good (n=24) Average (n=18) Average (n=7)
Register website?: Design and Good (n=1) Average (n=1) Good (n=15) Good (n=2)
structure Poor (n=2) Poor (n=2)
3.1 What is your impression of the Average (n=32) Average (n=25) Average (n=20) Average (n=7)
Register website?: Availability of Good (n=8) Poor (n=4)
information / documents Poor (n=6) No opinion (n=1)
No opinion (n=3)
3.1 What is your impression of the No opinion (n=31) No opinion (n=25) Average (n=20) Average (n=5)
Register website?: Ease of search Poor (n=1) Good (n=5) Good (n=2)
function Poor (n=5) Poor (n=4)
3.1 What is your impression of the Good (n=31) No opinion (n=25) Average (n=7) Average (n=2)
Register website?: Accessibility No opinion (n=1) Good (n=2) Good (n=4)
(e.g. features for visually impaired Poor (n=2) Poor (n=1)
persons, ease of reading page) No opinion (n=26) No opinion (n=5)
3.1 What is your impression of the No opinion (n=32) No opinion (n=25) Average (n=7) Average (n=3)
Register website?: Access via No opinion (n=30) Good (n=1)
mobile devices Poor (n=1)
No opinion (n=7)
Comments or  There should be a separate  Should be able to view and  The search function needs to
suggestions (Optional) category for local authorities order the full list of registered be improved
[relevant themes are shown] or their associations lobbyists by different  Membership of EU Structures
 Regional public authorities categories (no. employed, and platforms should be
and local, municipal budget, etc.) included
authorities and cities should  The 100 most recent
be treated equally registrants should be included
 News listing should be more
prominent
Final comments or ideas on any  Quality of data in Register  Quality of data in Register
additional subjects that you need to be improved need to be improved
consider important in the context  Systematic checks on at least  Systematic checks on at least
of this public consultation 20% of declarations are 20% of declarations are
(Optional) needed annually needed annually
[relevant themes are shown]  Sanctions must be in place for  Sanctions must be in place for

RPA | A2-6
Campaign 1 2 3 3
inaccurate or misleading inaccurate or misleading
information information
 Unregistered lobby groups  Unregistered lobby groups
should no longer be able to should no longer be able to
meet officials meet officials
 Register should be extended  Register should be extended
to fully include the European to fully include the European
Council, the Council and Council, the Council and
permanent representations permanent representations
 Changes are required to the  Changes are required to the
disclosure requirements disclosure requirements
(financial, lobby issue, (financial, lobby issue,
lobbyists names, through third lobbyists names, through third
parties) parties, no representation of
unregistered clients)
 Updates should be
compulsory and twice per year
Attach files One file attached
Do you want to proceed to Part B? No (n=32) No (n=25) No (n=36) Yes (n=11)
Yes (n=1) No (n=1)

RPA | A2-7
Annex 2B: Summary of Campaign Responses (for Part B)
Question Campaign 3
Are you responding as: The representative of an organisation registered in the Transparency Register (n=11)
1.1 The Register invites organisations to sign up under a particular section, for example, No (n=6)
professional consultancies, NGOs, trade associations, etc. (Annex I of the Interinstitutional Yes (n=3)
Agreement). Have you encountered any difficulties with this categorisation? No opinion (n=2)
Comments or suggestions (Optional)  A number of organisations have categorised themselves wrongly
[relevant themes are shown]  Some of these can be dealt with by using clearer titles and descriptions for the different
categories
2.1 Entities joining the Register are asked to provide certain information (contact details, Too little is asked (n=11)
goals and remit of the organisation, legislative dossiers followed, fields of interest,
membership, financial data, etc.) in order to identify the profile, the capacity of the entity
and the interest represented (Annex I of the Interinstitutional Agreement). The right type
of information is required from the registrant:
Comments or suggestions (Optional)  Data are inaccurate
[relevant themes are shown]  More information is required on individual lobbyists
 Lobby turnover should be disclosed to the nearest 10,000 euros
 Lobby dossier disclosure is poorly policed
 Funding sources should be disclosed
 Registrants should specify third part organisations through which they conduct their
lobbying
2.2 It is easy to provide the information required: Fully agree (n=5)
Partially agree (n=6)
Comments or suggestions (Optional)  Need for automatic alerts that ask registrants to confirm implausible declarations
[relevant themes are shown]  Forecasts for the next 6-12 months lobbying should also be provided
2.3 Do you see any room for simplification as regards the data disclosure requirements? No (n=11)
Comments or suggestions (Optional)  Data disclosure requirements need strengthening
[relevant themes are shown]  The guidance needs simplifying and clarifying
 Guidance and key elements from IIA could be incorporated into one document and
could be accessed as registrants go through the update process
2.4 What is your impression of the overall data quality in the Register: Poor (n=11)
Comments or suggestions (Optional)  Almost half the entries in the Register are flawed
[relevant themes are shown]  EU Transparency Register secretariat needs to be adequately staffed to undertake
checks
 A minimum number of entries must be checked each year
 Software should be used to alert registrants to unlikely-looking postings
 Priority should be placed on ensuring accuracy of financial data

RPA | A2-8
Question Campaign 3
3.1 The Code of Conduct sets out the rules for all those who register and establishes the Partially agree (n=11)
underlying principles for standards of behaviour in all relations with the EU institutions
(Annex III of the Interinstitutional Agreement). The Code is based on a sound set of rules
and principles:
Comments or suggestions (Optional)  Definition of 'inappropriate behaviour' needs to be clarified
[relevant themes are shown]  Should prohibit representation by private firms of regimes in breach of human rights
 Should prohibit representation by private firms of the tobacco industry
 Effective use should be made of sanctions
a) The present procedure for dealing with alerts and complaints is adequate: Disagree (n=11)
Comments or suggestions (Optional)  There are insufficient resources to deal with complaints or to make sufficient checks
[relevant themes are shown]  Actions must be taken against organisations submitting inaccurate register entries to
improve confidence in the system
 Sanctions such as suspending passes should be included
b) Do you think that the names of organisations that are suspended under the alerts and Yes (n=11)
complaints procedure should be made public?
Comments or suggestions (Optional)  This is absolutely critical
[relevant themes are shown]  Making it public would be an important incentive to provide accurate information
 Would provide important information until a legally binding register comes into force
4.1 How user-friendly is in your opinion the Register website in relation to registration and Straightforward (n=2)
updating?: Registration process Satisfactory but can be improved (n=7)
No opinion (n=2)
4.1 How user-friendly is in your opinion the Register website in relation to registration and Straightforward (n=3)
updating?: Updating process (annual & partial) Cumbersome (n=1)
Satisfactory but can be improved (n=6)
No opinion (n=1)
Comments or suggestions (Optional)  Suspect that many mistakes are accidental
[relevant themes are shown]  The register’s software could help identify and warn about possible errors
 More regular updates could be provided, twice per year and on shared dates
5.1 The European Parliament and the European Commission currently offer certain Very important (n=10)
practical advantages (incentives) linked to being on the Register. The Commission has also Somewhat important (n=1)
announced its intention to soon amend its rules on Expert groups to link membership to
registration. Which of these advantages are important to you? In the European Parliament
(EP): Access to Parliament buildings: long-term access passes to the EP's premises are only
issued to individuals representing, or working for registered organisations

RPA | A2-9
Question Campaign 3
announced its intention to soon amend its rules on Expert groups to link membership to Not important (n=2)
(EP): Committee public hearings: guests invited to speak at a hearing need to be registered
announced its intention to soon amend its rules on Expert groups to link membership to No opinion (n=1)
(EP): Patronage: Parliament does not grant its patronage to relevant organisations that are
not registered
In the European Commission: Meetings: organisations or self-employed individuals Very important (n=11)
engaged in relevant activities must be registered in order to hold meetings with
Commissioners, Cabinet members and Directors-General
In the European Commission: Public consultations: the Commission sends automatic alerts Very important (n=4)
to registered entities about consultations in areas of interest indicated by them; it Somewhat important (n=6)
differentiates between registered and non-registered entities when publishing the results Not important (n=1)
In the European Commission: Patronage: Commissioners do not grant their patronage to Very important (n=8)
relevant organisations that are not registered Somewhat important (n=2)
No opinion (n=1)
In the European Commission: Mailing lists: organisations featuring on any mailing lists set Very important (n=5)
up to alert them about certain Commission activities are asked to register Somewhat important (n=2)
Not important (n=4)
In the European Commission: Expert groups: registration in the Transparency Register is Very important (n=10)
required in order for members to be appointed (refers to organisations and individuals Somewhat important (n=1)
appointed to represent a common interest shared by stakeholders in a particular policy
area)
Comments or suggestions (Optional)  Important to incentivise participation in the Register before a legally binding register
[relevant themes are shown] comes into force
 Such incentives only boost the number of registrations, they do not improve the data
quality
 Incentives do not replace the need for a legally binding register
6.1 Do you believe that there are further interactions between the EU institutions and Yes (n=11)
interest groups that could be made conditional upon prior registration (e. g. access to MEPs
and EU officials, events, premises, or featuring on specific mailing lists)?

RPA | A2-10
Question Campaign 3
Comments or suggestions (Optional)  Registration should be a requirement for access
[relevant themes are shown]  The EC's policy of not meeting unregistered lobbyists should be extended to cover all
Commission officials involved in EU legislation
 Members of the European Parliament should list their interactions with lobby groups
 Meetings with lobbyists should be published
 Officials should not attend events organised by non-registered lobbyists
 A mandatory register that is legally binding is required
6.2 Do you agree with the Commission's view that the Council of the EU should participate Yes (n=11)
in the new Interinstitutional Agreement on a mandatory register?
Comments or suggestions (Optional)  European Council, Council of the EU and permanent representations should be included
[relevant themes are shown]  The Register should be revised and a legally-binding system set up even without the
Council
7.1 How does the Transparency Register compare overall to 'lobby registers' at the EU No opinion (n=9)
Member State level? It is neither better, nor worse (n=2)
Good practices or lessons learned at the EU Member State level to be considered, or pitfalls  EU should set best practice standards to serve as an example for Member States
to be avoided. (Optional)  A legally binding and mandatory register does not automatically mean that lobbying
[relevant themes are shown] with be transparent
 A central database should be used to aggregate all lobbying information (central
transparency hub)
 Introduction of a system of effective and inevitable sanctions for those who do not
comply
 Introduction of a system of sanctions for EU officials who do not comply with their
disclosure obligations
 Introduction of an anti-revolving door and ban on registering as a lobbyist in the period
equal to terms of left office
 There needs to be legally binding legislative footprint regulation
 Potential to learn from good and bad practice in EU Member States, but also from other
countries such as Canada
Final comments or ideas on any additional subjects that you consider important in the  All interinstitutional agreement preparatory meetings should be open to the public and
context of this public consultation (Optional) web-streamed
[relevant themes are shown]  The draft agreement, proposed changes, agendas and minutes should be available
online
 All EU institutions should conduct regular reviews of their transparency rules and the
way that they are implemented
Publication of your consultation I agree to my contribution being published (n=10)
I do not agree to my contribution being published (n=1)

RPA | A2-11
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Analysis of responses to the

Open Public Consultation

(Specific Contract SG/B4/R1-2015/1 implementing

Project reference / title J908 SecGen Transparency Register

Report status Final Report

Dr Peter Floyd, RPA

Approved for issue by Dr Peter Floyd, RPA

Date of issue 28 July 2016

Document Change Record

Report Version Date Change details

Draft Final As submitted 27 June 2016

Report revised following feedback

Further minor revisions to improve

RPA (2016): Analysis of responses to the Open Public Consultation on the

The objectives of the open public consultation were twofold:

The current (voluntary) Register represents an online database of interest representatives.

Executive Summary ……………………………………………………………………………………………………………… i

2 Number and Type of Responses Received.............................................................................. 2

3 Methodology of the Study .................................................................................................... 6

5 Analysis of Part A Questions ............................................................................................... 21

Annex 1: The Questionnaire

The objectives of the open public consultation were twofold:

Table 2-1: Responses from individuals by country of residence

2.3 Responses from organisations

2.4 Responses by language

 Step 1: Obtain raw data

3.2 Step 1: Obtain raw data

3.3 Step 2: Data cleaning

3.3.2 Removal of late submissions

Table 3-1: Summary of responses taken forward

Further work on identifying the campaigns involved three methods:

 web searches to identify any on-line (including social media) campaigns;

3.4.2 Presence of campaigns

3.4.3 Closed questions

3.4.4 Open questions

Qn 1.1a ….lobbying is more than just the lobby register….

Qn 1.1b Stopping the privileged access by business interests…

Qn 2.2 There is no rationale for their exclusion…

Qn 4 Further important changes…

Qn 4 Lobby rules should apply also to the European Council

Of the 49 respondents to Part A, 11 organisations and one individual proceeded to Part B.

3.5 Step 4: Analysis of closed questions

 individuals vs registered organisations (i.e. organisations on the Transparency Register) vs

Of these 25 entities (hereafter referred to as ‘Tier 1 organisations’), 24 provided responses to the

 undertook a word frequency search to identify the most popular words;

Figure 3-1: Example of a word tree highlighting the ALTER-EU campaign

3.7 Step 6: Reporting

Table 4-1: Summary of campaign responses

4.2 Campaigns 1 and 2

4.2.3 Scope of the Register (Qns 2.1, 2.2)

4.2.4 Register website (Qns 3.1)

Table 4-2: Main views on the Register website (Qn 3.1)

4.2.5 Submitted documents

4.3 Campaign 3 – Part A questions

4.3.2 Transparency and the EU (Qns 1.1a, 1.1b, 1.1c, 1.2)

 transparent lobbying does not equate to ethical lobbying;

4.3.4 Register website (Qns 3.1)

4.3.5 Submitted documents

Table 4-5: Summary of attached documents from a Campaign 3 respondent

4.4.2 Structure of the Register (Qn B1.1)

Specific suggestions to improve the Code of Conduct include:

 definition of 'inappropriate behaviour' needs to be clarified;

4.4.6 Current advantages linked to registration (Qn B5.1)

4.4.7 Features of a future mandatory system (Qns B6.1, B6.2)