1. Bulgaria: The European Commission asked Bulgaria to adopt a law on lobbying due for December 2023. No such draft law can be found. Bulgaria needs to strengthen the integrity framework for members of Parliament in particular by complementing the existing rules as regards revolving doors and lobbying. Note : To date, regulations and special legislation have been adopted on matters as access to information, political parties’ financing and conflict of interests’ prevention laws, as well as the criminalization of trading in influence, even though some implementation difficulties appear to exist. Debates about the introduction of a register are ongoing and have been since at least 1999 when the first bill on the subject was drafted. Later in 2002, the first bill proposing the creation of a registry for lobbyists was launched, followed by a series of new proposals in the period comprised between 2006 and 2008. None of these bills was ever approved. In 2005, the Bulgarian Public Relations Association (BDVO) approved its first Code of Ethics binding Public Relations Professionals that belong to the organization. 10 years later, in 2015, the same organization promoted the creation of the first lobbying register for members who have signed the Code of Ethics.
  2. Croatia: Draft law on lobbyingin the final legislative stages. Would include broad definition, register and code of conduct. Unclear when it will be passed/adopted. Croatia needs to adopt comprehensive legislation in the area of lobbying, including on persons with top executive positions, and set up a public register of lobbying. Note: Since 2008 public discussion around the subject of lobbying have intensified in Croatia. In the same year, the Croatian Society of Lobbyists (HDL) was founded, aiming to promote and raise awareness about the importance of lobbying regulation. To this day, HDL is the only existing source of data on ‘registered lobbyists’. When entering HDL, each member must sign the Ethical Code of HDL, which commits them to abide by conducts in accordance with its provisions. Despite the work of the HDL, there was never an official law introduced with the objective of regulating lobbying activities, even though mention to the introduction of such a law is made in the Anti-corruption Action Plan for 2014-2020 that the Croatian Government has sent to the EU Commission in Brussels.
  3. Czech Republic: Draft law published in November 2023 with a broad definition of lobbyists, register, code of conduct and publication of interaction by lobbyists. Under consideration by legislators. Czech Republic  needs to strengthen the integrity framework for members of Parliament in particular by complementing the existing rules as regards revolving doors and lobbying. Note: The Czech Association of Public Affairs Agencies (APAA) created in 2012 has adopted a Code of Conduct to which Lobbying professionals may adhere to when registering voluntarily with the association. APAA also serves as an advisory body in the process of preparing the lobbying regulatory scheme in the Czech Republic. In 2005 the first proposal which specifically mentioned the need for a parliamentary register was formulated, and in the period between 2005-2013, there were further proposals around the ‘Lobbying Act’ which never came to be approved. In late 2017, the Czech government anti-corruption committee finally introduced its material proposal for the Lobbying Act. The draft law remains in debate to this day.
  4. Denmark: No progress on adoption of lobby regulations despite recommendations to do so. Denmark should introduce rules on revolving doors for ministers and on lobbying and ensure adequate control of asset declarations submitted by persons entrusted with top executive functions. Note: Even though public discussions to introduce a lobbying register are common, Denmark appears to have no plans at the moment to create a mandatory lobbying register. An Ethical Code of Conduct was established by the Danish Public Relations Association. In 2012 MPs were given possibility to register contacts with external entities under a specific category in the voluntary register of financial interests, however, due to the fact that several MPs found it excessively burdensome to record such contacts and difficult to determine which were significant, the system was abandoned shortly afterwards. MPs now have a link on the parliamentary website to personal or party websites where they describe contacts with lobbyists on a voluntary basis.
  5. Hungary: No code of conduct, no register and no legislative footprint. Latest anti-corruption strategy suggests these will be governed by soft-law tools and with no dissuasive sanctions foreseen. Currently, employees of state agencies are only permitted to meet interest representatives with the consent of their superiors who may deny the request or may expect the presence of a third person at the lobby meeting. This is regulated in a brief, sanction-free decree that does not provide for any level of transparency regarding such interactions nor does it expand the afore mentioned requirements to members of the hierarchy. Hungary needs to adopt  comprehensive reforms on lobbying and revolving doors and further improve the system of asset declarations providing for effective oversight and enforcement. Note: Hungary remains a state with no comprehensive lobby regulation, even though there is a stand-alone law on legislative lobbying – The Legislative Lobbying Act – which governs public consultations of legislative proposals. The Act provides for compulsory public and expert consultations prior to bringing legislative proposals to the Parliament. Importantly, the Act does not set any minimal timeline during which these consultations are supposed to take place, nor does it prevent the government from arbitrarily selecting certain partners to be involved as consultants in the legislative process. Furthermore, the Government Decree on the system of integrity management within public administration, issued in 2013, obliges public servants to ask prior permission from their hierarchy to meet lobbyists and to also report back on the contacts or outcome of meetings. There is no mechanism in place targeting the monitoring of the implementation of these obligations. Moreover, the Decree requires neither the mandatory registration of lobbyists, nor the disclosure of contacts with lobbyists to an independent control body, nor does it expect public organs to make reports on lobbying contacts publicly accessible.
  6. Malta: The Commissioners for Standards in public life call for comprehensive regulation of lobbying. No draft law has been published. No lobbying framework really exists in Malta. Note: The Malta Council for Economic and Social Development (MCESD) was established in 2001 as a means of involving the main socio-economic groups in the governmental process through consultation, having a number of entities such as unions, business representatives and the University of Malta. A code of ethics requires Members of the House of Representatives to declare connections with people that have a direct interest in legislation before the House.
  7. Portugal: Multi-draft regulating lobbying activities were in an advanced stage of the legislative process. However, progress stalled due to the dissolution of the Parliament on the 1st January 2024. Portugal should introduce without further delay, rules on lobbying for members of Parliament. Note: Lobbying activities remain without specific legal regulation in Portugal. A number of other laws exist relating to political financing since as early as 1974. Nonetheless, at the end of 2014, the Portuguese Parliament was motivated by a Transparency International report to develop more Transparency regulations, presenting the first Transparency Package in mid-2015. In 2019 a proposal to introduce specific lobbying regulation was actually debated and approved in the Parliament, but since it was vetoed by the President due to regulatory lacunae, it appears that the proposal will not be approved soon.
  8. Slovakia: No progress and no intention to regulate lobbying. No draft law wan be found. Slovakia needs to introduce proposals to regulate lobbying and to stengthen the legislation on conflicts of interest and asset declarations. Note: Lobbying remains without specific regulation in Slovakia, however, a number of other regulations are in place to facilitate participation in the legislative process, such as a governmental website that compiles all legislative proposals and allows the general public to submit comments on them. The first attempt to regulate lobbying in a specific bill came in 2002. Two draft bills on lobbying were submitted in the legislative period that took place between 2012-2016 but none were approved.
  9. Spain: Draft lobbying on the verge of being adopted in previous legislature including register, broad definition, code of conduct and publication of lobby interactions. It is unclear how the new government will proceed. Some regional authorities have adopted advanced regulations on lobbying. These could serve as a model for any future national legislation. Spain needs to proceed to adopt legislation on lobbying, including the establishment of a mandatory public register of lobbyists. Note: Note: Spain approved its Transparency, Good Governance and Access to Information Law in 2013 (Ley 19/2013) which is binding only for the Government and does not establish any rules regarding lobbying, nor does it create a Transparency Register. However, during the parliamentary debate all political groups proposed amendments to include some kind of regulation for lobbies in the law, a move that eventually was opposed by the majority parliamentary group. Despite the efforts, the activity of interest group is not regulated per se in Spain. However, at the sub-state level, a number of regional communities have started to regulate lobbying activities, namely, Catalonia (December 2014), Madrid (July 2016), Castilha-la-Mancha (December 2016), Aragon (June 2017), Navarre (May 2018) and Valencia (December 2018). Self regulation remains the regulatory standard nationally in Spain, with the creation of APRI (Asociación de Profesionales de las Relaciones Institucionales) in 2007, and the adoption of a code of conduct by the same organisation in 2011.
  10. Sweden: Parliamentary enquiry launched for adoption of rules to be published in 2025. Sweden's culture of openness and disclosure of information enables transparency of lobbying while the public debate on regulating lobbying activities. Note: The Association of Public Relations Consultancies in Sweden (PRECIS) issued a series of PR guidelines that member consultancies are committed to follow. The main firms working with public affairs and lobbying are all members of the trade organization PRECIS, which is the dominant Swedish organization for the companies operating in the PR and communications consultancy sector. There appear to be no organizations who represent individual professional lobbyists nor specific public regulations regarding lobbying activities.


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