Photo by Pierreck Le Cunf, "Bruxelles" - Via Unsplash

More than half the entries on the Brussels Lobby Register are inaccurate, incomplete or meaningless

Yannik Bendel
7 September, 2015
Press Release

Over half the entries for lobby organisations on the EU Transparency Register contain factual errors or implausible numbers according to new analysis published today by Transparency International. TI has therefore filed 4,253 official complaints with the Secretariat of the Transparency Register. The register is designed to keep undue influence by lobbyists at bay and provide tran

sparency on lobbying activities and spending in Brussels.

Today’s submission of complaints follows the launch of new lobby monitoring tools on in June 2015. The tools provide for the first time a comprehensive overview of lobby meetings of the European Commission and systematically analyse the declarations filed by lobby organisations with the Transparency Register. But findings also show the poor data quality of the register.

A few simple plausibility checks reveal that data which lobbyists voluntarily file with the lobby register is inaccurate, incomplete or outright meaningless”, says Daniel Freund from Transparency International EU. “Among the hundreds of useless declarations we found organisations claiming to spend more than €100,000,000 on EU lobbying or having tens of thousands of lobbyists at their disposal. We hope that the Commission will swiftly follow up on our complaints and ensure that either the declarations are corrected or non-cooperative organisations are removed from the register.”

Organisations that no longer have an active registration lose their access passes to the European Parliament and can no longer get meetings at the highest level of the European Commission. “This should in theory be a good incentive for lobby organisations to keep their declarations in order, but in the past there has been far too little oversight”, says Daniel Freund. “We see that there is a clear need for more systematic checks and verification.”

As the European Commission is about to start negotiations with the European Parliament and the Council on reforming the current lobby transparency regime, Transparency International hopes that the reforms will bring proper monitoring and sanction mechanisms for organisations that do not respect the rules.

The 4,253 alerts to the Transparency Register were filed for the following reasons:

As one of the changes introduced by the Transparency Register in the overhaul of January 2015 a mandatory field on “Main EU initiatives, policies and legislative files followed by the organisation” was introduced. Organisations that do not report anything in this section either have no business being on the register (as they have manifestly no activity to declare) or they are not declaring their activities covered by the register which would be a clear violation of the Code of Conduct. A quick search of entries shows that many organisations declare “none” or “-“ or have found other ways to fill out the mandatory field without providing any information.

According to the guidelines of the Transparency Register, financial information provided should include costs for staff, offices, in-house operations, representation, outsourced activities and membership fees. There is even 171 organisations, which declare no lobby budget whatsoever. A simple analysis of the ratio of total declared costs per lobbyist (we have used the full time equivalent) shows that many organisations’ declarations are implausible given current labour regulation. It is unlikely that organisations on the register are able to employ a full-time equivalent lobbyist for less than the minimum wage. And these calculations do not even take into account the costs of premises or other related costs. 2,698 of these organisations declare even less than the minimum wage for interns (the minimum employer cost for an intern or “immersion professionelle” in Belgium is 12,894.89 EUR per year).

Although it is likely that many lobby organisations work with interns or volunteers and rightfully declare them as part of their workforce on the Transparency Register it seems doubtful that organisations manage to keep their entire workforce on volunteer contracts. This applies in particular to the 1,193 consultancies, corporations and industry associations among these organisations. 121 organisations declare even less than 10,000 EUR in lobbying expenditure despite registering an address for a Brussels office. Brussels office space, particularly in the area surrounding the EU institutions, is not available for this little money, even for very small organisations. So the budget these organisations declare could not even cover their rent, let alone salaries or other costs.

The same ratio of total declared costs per lobbyist also exposes cases of over-reporting. Even the best-resourced organisations with credible entries barely spend half this amount. Organisations declaring in excess of one million euros per lobbyist have probably filed erroneous information, particularly given the fact that 93% of this group does not even have an office in Brussels.

The list of complaints includes organisations with household names such as Boeing, Yahoo, Wal-mart, Rio Tinto, Thalys, Brussels Airlines and KBC Bank.


EU Integrity Watch:

Launched in October 2014, EU Integrity Watch ( is Transparency International EU’s central hub for online tools aimed at making the EU Institutions more transparent. It contains tools that allow users to monitor the outside activities and incomes of Members of the European Parliament as well as lobbying in Brussels.

Graphic filters and a powerful search function allow citizens, journalists and civil society to hold EU decision makers to account and to monitor them for potential conflicts of interest and false/inaccurate declarations.

Lobbying in Europe:

Today’s assessment of the situation of lobbying in Brussels follows the publication of Transparency International’s report on “Lobbying in Europe: Hidden Influence, Privileged Access” that was published on 15 April 2015. The report analysed lobbying in 19 European countries and in the 3 EU institutions and shows examples of undue influence on politics across the region and in Brussels. The full report can be found here and the press release with main findings and the country ranking here. On 24 June 2015 we also published “Brussels Lobbying in numbers” that can be found here.

Transparency Initiative of the European Commission:

The European Commission under President Jean-Claude Juncker has made strong commitments to increased transparency. Since 1 December 2014 Commissioners, their Cabinets and Director-Generals publish their meetings and only meet with lobbyists registered in the EU Transparency Register. VP Frans Timmermans has been tasked to put forward a proposal for a mandatory register by the end of 2015. The Commission also pledged to “ensure an appropriate balance and representativeness in the stakeholders they meet”.

EU Transparency Register:

Created in 2011 as a joint register for lobbyists by the European Commission and Parliament, the voluntary register of Brussels lobbyists has undergone multiple revisions. Following the launch of an updated website on 27 January 2015, all registered organisations had to undergo a first annual update of their information. Despite the suspension of several hundred organisation and updated declarations from more than 8,000 organisations that are currently registered, the quality of the data remains relatively poor, although improving compared to previous years. Transparency International has been campaigning for a mandatory register with meaningful sanctions for lobbyists that break the rules. Our detailed recommendations can be found here.


  • Make the EU Transparency Register mandatory

Only if registration is mandatory for lobbyists can we be sure to capture all those seeking to directly or indirectly influence EU decision-making. A mandatory register would also allow sanctioning of organisations that do not comply with the rules. The Transparency Register Secretariat needs to be provided with the necessary resources to better check the declarations for possible errors, particularly on those organisations that have frequent meetings at the highest level.

  • Introduce a Legislative Footprint for EU decision-making and legislation

A legislative footprint is a comprehensive public record of lobbyists’ influence on a piece of legislation or public decision. This can be established through the registration of meetings and by capturing written input from lobbyists. The Commission has started both but the measures need to be extended to everyone involved in the decision-making process. This means extending current provision to the lower levels of the Commission but more importantly to the European Parliament and Council. Standardisation of subject matters and the mention of concrete legislative files as well as the use of open data would greatly increase the usability of the data by a wider audience.

Transparency International has published a policy paper with detailed recommendations on how an EU Legislative Footprint can be introduced. The paper, including a set of frequently asked questions on administrative burden or privacy protection, can be found here.


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Daniel Freund

Head of Advocacy EU Integrity (on leave)