Recommendation of the Council on Transparency and Integrity in

Recommendation of the Council on

OECD Legal

Instruments

Transparency and Integrity in

Lobbying and Influence

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OECD/LEGAL/0379

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Background Information

The Recommendation on Transparency and Integrity in Lobbying and Influence (hereafter “the

Recommendation”) was adopted by the OECD Council on 18 February 2010 (under the name

“Recommendation on Principles for Transparency and Integrity in Lobbying”) on the proposal of the

Public Governance Committee (PGC). The Recommendation is the first international standard to

address transparency and integrity risks related to lobbying practices. The Recommendation was

revised by the OECD Council meeting at Ministerial level on 3 May 2024 to reflect the evolving

lobbying and influence landscape, and to help actors in government, business and civil society

reinforce the frameworks for transparency and integrity in policy-making.

The needfor an international standard on lobbying

Lobbying and influence actors, represent valid interests and bring to policy makers’ attention much

needed insights and data on all policy issues. Such an inclusive policy-making process provides

opportunities for more informed and ultimately better policies. However, evidence has shown that

policy-making is not always inclusive. At times there may be monopoly of influence by those that are

financially and politically powerful, at the expense of those with fewer resources. Evidence has also

shown that policies may be unduly influenced through the provision of biased or deceitful evidence or

data, as well as by manipulating public opinion. Public policies that are misinformed and respond only

to the needs of a special interest group can ultimately lead to policies that do not always benefit

societies.

As such, the development of the Recommendation was part of a broad set of OECD initiatives

triggered by the 2008 financial crisis to set standards for a stronger, cleaner and fairer economy, and

to avoid making policy choices in the interests of the more financially and politically powerful.

The Recommendation was developed by the PGC on the basis of reviewed data and experiences of

government regulation and self-regulation by lobbyists. It also reflects the views of a wide range of

OECD bodies and stakeholders consulted by the PGC, including legislators, representatives of the

private sector, lobbying associations, civil society organisations, trade unions, think tanks and

international organisations.

2024 revision of the Recommendation

In line with the conclusions of the 2021 Report to Council, the Recommendation was revised in 2024

to increase its relevance and impact.

The revisions reflect the conclusions from the 2021 Report, and the subsequent extensive

feedback from relevant OECD policy communities (including the Regulatory Policy Committee (RPC)

and the Working Group on Bribery (WGB)), along with the public and stakeholder consultation that

was conducted in November-December 2022. The aim of the revision was to provide concrete

guidance for governments on building or strengthening a coherent, comprehensive, effective and

enforceable system for limiting risks of undue influence and monopoly of influence in public decision

making, consistent with the wider policy and regulatory frameworks, and ensuring its proper

implementation, compliance and review.

Certain sections of the Recommendation were strengthened, some mainstreamed, and some new

areas are covered. In particular, the revised Recommendation:

Recommends the disclosure of lobbying and influence activities conducted on behalf of foreign

state interests, as well as donations and contributions received by the government, public

officials, political parties and election campaigns.

Recommends that Adherents introduce a regulatory footprint in public decision-making

processes, a tool that details lobbying and influence actors and stakeholders consulted in the

decision-making process, and which represents a step towards transparency and

enforcement.

Contains expanded principles on transparency measures for all bodies providing advice to the

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Contains expanded principles on transparency measures for all bodies providing advice to the

government, by recommending that Adherents ensure transparency by requiring information on

the funding and functioning of advisory bodies (both internal and external) to be publicly

available, and prescribing integrity-related measures, such as procedural rules, standards of

conduct, and rules on conflicts-of-interest.

Calls for transparency and integrity in companies and not-for-profit organisations when

engaging in lobbying and influence activities.

Strengthens measures on conflicts-of-interest and the revolving door by calling for rules and

procedures for identifying, managing and resolving conflict-of-interest situations, and for a

system that manages the conflict-of-interest risks posed by individuals both entering and

leaving the public sector, including at the international level.

Impact of the Recommendation and next steps

The Recommendation has been key in raising awareness and promoting the relevance of lobbying

standards among Adherents and beyond them, encouraging them to use it in their efforts to enhance

transparency and integrity in public decision making. It has proved to be a valuable instrument in

shaping policy debates at national and supranational levels and guiding the many Adherents and

selected non-Adherents that since 2010 have adopted regulations or policies on lobbying. For

example, Austria, Chile, the European Union, France and Ireland reported having used the

Recommendation as a source for their regulations. It has proven influential in framing and informing

debates in Adherents currently designing or revising lobbying regulations. Similarly, business

representatives as well as non-governmental organisations have built on the Recommendation in their

efforts related to lobbying.

Both the Adherents and the OECD Secretariat are invited to disseminate the Recommendation. The

Working Party on Public Integrity and Anti-Corruption (WP-PIAC) will develop tailored guidance to

support Adherents implement the Recommendation.

To ensure the principles embedded in the Recommendation remain relevant, a third report on

implementation, dissemination and continued relevance of the Recommendation will reach Council in

2029.

For further information please consult: https://www.oecd.org/corruption/ethics/lobbying/.

Contact information: GOV.Integrity@oecd.org.

Implementation

2014 Report to Council

The 2014 Report took stock of progress made in implementing the Recommendation. It concluded

that although there was emerging consensus on the need for transparency to shed light on lobbying,

new regulations were often scandal-driven instead of forward looking. In countries that had regulations

in place, the degree of transparency in lobbying varied considerably across Adherents. The Report

encouraged Adherents to focus efforts on the implementation of the Recommendation, in order to

strengthen confidence in the public decision-making process and restore trust in government.

Publication available at: OECD (2014), Lobbyists, Governments and Public Trust, Volume 3:

Implementing the OECD Principles for Transparency and Integrity in Lobbying, OECD Publishing,

Paris, https://doi.org/10.1787/9789264214224-en.

2021 Report to Council

More than ten years after the adoption of the Recommendation, the 2021 Report highlights the main

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trends and developments concerning the implementation of the Recommendation across Adherents

and selected non-Adherents (Brazil, Romania). It concluded that Adherents and selected non-

Adherents have advanced in providing transparency, integrity, and access, but at different speeds and

in a continuously evolving lobbying landscape. In particular, the Report reflects on new challenges and

risks related to the many ways special interest groups attempt to influence public policies, including

through political finance, and reviews tools adopted by governments to effectively safeguard

impartiality and fairness in the public decision-making process. It concludes that a more

comprehensive consideration of lobbying activities is needed and proposes a review of the

Recommendation by the PGC, through SPIO, within two years.

Publication available at: OECD (2021), Lobbying in the 21st Century: Transparency, Integrity and

Access, OECD Publishing, Paris, https://doi.org/10.1787/c6d8eff8en.

OECD/LEGAL/0379

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THE COUNCIL,

HAVING REGARD to Article 5 b) of the Convention on the Organisation for Economic Co-operation and

Development of 14 December 1960;

HAVING REGARD to the standards developed by the OECD in the area of public governance, regulatory

policy, public integrity, corporate governance, anti-corruption, public procurement, and responsible

business conduct;

RECOGNISING that since lobbying and seeking to influence government decisions are legitimate ways in

which stakeholders participate in public decision-making processes and support informed decisions by

providing valuable perspectives, data and insights for effective public policies, a wide range of stakeholders

should have a fair and equitable opportunity to contribute to public decision-making;

RECOGNISING that increased transparency and accountability of lobbying and influence activities helps

level the playing field for stakeholders from different interest groups;

RECOGNISING that public decision-making processes that include inputs from a plurality of concerned

stakeholders are crucial to safeguarding the public interest;

RECOGNISING that lobbying and influence practices conducted without transparency and integrity, and

without the involvement of a broad group of stakeholders, can result in situations of inequity in influence,

undue influence or foreign interference, for example by means of providing covert, deceptive or misleading

evidence or data, or manipulating public officials by hiding the origin of the influence, which can ultimately

lead to policies that do not always benefit societies;

RECOGNISING the evolving lobbying and influence landscape, with particularly new and more diverse

mechanisms and channels of influence, such as through social media and artificial intelligence tools, and

lobbying and influence by foreign actors, including foreign governments and their related entities or

individuals, foreign political organisations, or foreign state-owned and controlled entities, representing

foreign commercial and political interests;

RECOGNISING that the increasing risks connected with lobbying and influence, including covert foreign

influence, on public decision-making processes make it crucial for governments to set up a strong,

effective, resilient and proportionate framework for lobbying and influence activities that is consistent with

the broader public integrity framework;

CONSIDERING the threat to democracy posed by the rapid and global spread of mis- and disinformation,

including information manipulation and covert foreign influence;

RECOGNISING that integrity, transparency, openness, and equity in public decision-making processes

are necessary for both the creation of optimal policies and public trust in government;

RECOGNISING that lobbying and influence actors, including companies, are under increasing scrutiny

and that there is a need for a clear transparency and integrity framework on their engagement with public

decision-making processes;

RECOGNISING the need to reflect the evolving lobbying and influence landscapes and assist stakeholders

in government, business, and civil society in reinforcing their frameworks for transparency and integrity in

policy-making;

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RECOGNISING the legitimate and imperative rights of non-discrimination, freedom of expression, to

petition government, peaceful assembly and association, privacy and data protection, and the need to

implement international standards related to the protection and promotion of civic space, open government,

and independent and plural media;

CONSIDERING that while the responsibility for ensuring transparency and integrity in public decision-

making processes rests primarily with the government, at all branches and levels of government and by all

public institutions, it is also shared with lobbying and influence actors and therefore this Recommendation

is relevant for all of them.

On the proposal of the Public Governance Committee:

I. AGREES that the purpose of this Recommendation is to set out principles on transparency and

public integrity at the interactions between government and lobbying and influence actors in democratic

systems, and provide guidance on how governments can restrict undue influence on government policies

and increase equity in stakeholder participation, by building or strengthening a coherent, comprehensive,

effective and enforceable transparency and integrity system in public decision-making processes, and

ensuring effective implementation and compliance. It does not cover influence activities exercised by

foreign governments through formal diplomatic channels, communications between public authorities, as

well as the provision of legal advice and representation by lawyers or any other professionals when

advising clients about administrative or judicial proceedings.

II. AGREES that, for the purpose of the present Recommendation, the following definitions are used:

● Lobbying and influence activities refers to actions, conducted directly or through any other

natural or legal person, targeted at public officials carrying out the decision-making process, its

stakeholders, the media or a wider audience, and aimed at promoting the interests of lobbying

and influence actors with reference to public decision-making and electoral processes.

● Lobbying and influence actors refers to legal persons, domestic or foreign, that engage in

lobbying and influence activities on their own behalf, as well as natural or legal persons, domestic

or foreign, who engage in lobbying and influence activities on behalf of or under the direction or

control of other natural or legal persons, or foreign state interest actors. It does not cover

diplomatic and consular officials, natural persons acting in a strictly personal capacity and not in

association with others, journalists or contributors publishing content under the editor-in-chief’s

responsibility of any print or digital publication, public officials acting in their official capacity, as

well as political parties acting within the framework of political party regulations.

● Foreign state interest actors refers to foreign governments and their related entities or

individuals, foreign political organisations, or foreign state-owned and controlled entities,

representing foreign commercial and political interests. It does not cover diplomatic or consular

officials.

● Public decision-making process refers to the development, implementation, evaluation or

modification of any public policy or of any public programme, at all levels of government (e.g.

federal, national, regional or local) and branches of government (executive, legislative and

judicial); the preparation or amendment of any law or regulation, including secondary legislation

such as statutory instruments and by-laws; the award, modification or withdrawal of any grant,

loan or other financial support, contract or other agreement, or of any licence or other

authorisation involving public funds; and the nomination of key public officials.

● Public decision-making process footprint refers to documentation that details the

stakeholders who sought to influence the decision or were consulted in its development, and

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shows what inputs into the particular public decision-making process were submitted and what

steps were taken to ensure inclusiveness of stakeholders in the development of the regulation.

● Advisory and expert group refers to any committee, board, commission, council, conference,

panel, task force or similar group, delegation to an international forum, or any subcommittee or

other subgroup thereof, that provides governments with advice, expertise or recommendations,

and in which non-governmental actors take part. These may be put in place by the executive,

legislative or judicial branches of government or at different levels of government, either on an

ad hoc or standing basis.

● Oversight function refers to an independent public institution or institutions, dedicated or with

broader competencies, adequately resourced and empowered to investigate and enforce policies

and regulations concerning lobbying and influence activities, and monitor and promote their

implementation. Oversight functions are meant to ensure impartial enforcement and provide

adequate responses (including redress, where relevant) to the sanctions, rulings and formal

advice.

III. RECOMMENDS that Members and non-Members having adhered to this Recommendation

(hereafter the “Adherents”) strengthen transparency and openness of lobbying and influence activities in

public decision-making processes, including from foreign state interest actors. To this effect, Adherents

should:

a) Make publicly available online and easily accessible, in an open data format that is reusable for

public scrutiny, timely, comprehensive and detailed information on lobbying and influence

activities, in particular on who, and/or on whose behalf, is lobbying or influencing undertaken,

who is the target of such activities, the policy issue or regulatory act concerned, the objectives,

and any supporting documentation received from lobbying and influence actors;

b) Establish and maintain a mandatory public decision-making process footprint, to the extent

possible, with timely, comprehensive and detailed information on lobbying and influence

activities, made publicly available online and easily accessible, in an open data format, that is

reusable for public scrutiny and allows for cross-checking with other relevant databases;

c) Disclose online in an open data and easily accessible format, that is reusable for public scrutiny,

information about donations and contributions, within a reasonable threshold, received by the

government, public officials, political parties and election campaigns from lobbying and influence

actors, and foreign state interest actors;

d) Foster the right to full access to information about lobbying and influence activities and timely

responses to such requests for information;

e) Consider legitimate exemptions to transparency, in particular the need to preserve confidential

information in the public interest or to protect market-sensitive information when necessary.

IV. RECOMMENDS that Adherents implement transparency and integrity frameworks for all those

that provide advice to the government, notably advisory and expert groups, persons or external

consultancy organisations acting as advisors or experts, or delegations to intergovernmental fora. To this

effect, Adherents should:

a) Publicly disclose information on the funding and functioning of advisory and expert groups,

including information on their members and other persons who participate in providing advice to

government, such as their private interests and their current and past professional affiliations;

b) Provide rules that promote transparency, integrity and inclusiveness in advisory and expert

groups, such as procedural rules, standards of conduct and rules on conflict of interest;

c) Provide rules, including rules on conflict of interest, that promote transparency and integrity for

any person or external consultancy organisation providing advice or expertise to the government.

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V. RECOMMENDS that Adherents increase transparency on the lobbying and influence activities of

all lobbying and influence actors, notably companies, business and trade associations, non-governmental

organisations, think tanks, research bodies, trade unions and other organisations. To this effect, Adherents

should:

a) Ensure there is adequate, accurate, and up-to-date information on ownership, including

beneficial ownership of legal persons and arrangements, that can be obtained or accessed

rapidly and efficiently by competent authorities, through either a register of beneficial ownership

or an alternative mechanism;

b) Apply disclosure regulations to the sources of financing, above a reasonable threshold, of

lobbying and influence actors, including financing by the government, individuals and other

lobbying and influence actors;

c) Ensure the transparency of lobbying and influence actors’ donations, contributions and services

to the government, political parties and election campaigns, either directly or through third parties

or natural persons hired to conduct lobbying and influence activities;

d) Ensure frameworks are in place for lobbying and influence actors to make accessible to the public

pertinent information on their lobbying and influence activities, including activities aimed at

persuading any section of the public or the media with regard to public decision-making and

electoral processes, or the policy interests of the said lobbying and influence actors, either

directly or through third parties, e.g. through trade associations, grassroots movements, think

tanks, research bodies, charities, fundraising organisations, prominent experts and personalities,

natural or legal persons hired to conduct lobbying and influence activities, communications or

advertising on print, broadcast media, or online platform services (including targeted ads via

social media);

e) Provide rules for lobbying and influence actors to disclose their membership in other relevant

organisations, any funding provided to other organisations or individuals for the purpose of

conducting lobbying and influence activities, as well as any gifts, invitations and hospitalities

given to public officials, media and journalists, individual experts and personalities for that

purpose;

f) Require lobbying and influence actors’ board members and senior executives to disclose

membership and interests with other companies, state agencies, and outside organisations such

as business and trade associations, non-governmental organisations, consultancies, think tanks

and research bodies, where such membership is closely linked to the lobbying and influence

activities;

g) Require the disclosure of conflict-of-interest situations between the media content and the private

interests of the owner(s), as well as transparency around all sponsored content and advertising.

VI. RECOMMENDS that Adherents promote a public integrity framework aimed at ensuring integrity

when lobbying and influence actors, including companies, business and trade associations, consultancies

and law firms, non-governmental organisations, think tanks, research bodies and other organisations

engage in lobbying and influence activities. To this effect, Adherents should:

a) Take measures to ensure that companies, business and trade associations, consultancies and

law firms, non-governmental organisations, think tanks, research bodies and other organisations

adhere to integrity standards and engage responsibly in their lobbying and influence activities;

b) Ensure that companies’ lobbying and influence activities are consistent with the companies’

commitments and goals on responsible business conduct matters;

c) Encourage companies to have due diligence measures in place to ensure that their lobbying and

influence activities are coordinated and coherent with their initiatives dealing with anti-corruption,

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responsible business conduct, public integrity as well as with their broader environmental, social,

and governance goals;

d) Encourage media companies to establish integrity standards on: (i) effectively managing

potential conflicts between journalists’ and contributors’ interests connected to the content they

create; (ii) receiving gifts, invitations, and hospitalities from lobbying and influence actors; (iii)

dealing with external pressure from lobbying and influence actors aiming to influence coverage;

(iv) and interacting with partners or funders.

VII. RECOMMENDS that Adherents establish a public integrity framework for public officials adapted

to the risks related to lobbying and influence activities. To this effect, Adherents should:

a) Provide clear standards and guidelines for public officials, including tailored ones for at risk

positions, on: (i) engaging with lobbying and influence actors, including due diligence on the

actors’ integrity and transparency; (ii) how to seek and assess information and evidence, in

particular how to deal with possibly biased or false information and disinformation campaigns;

(iii) receiving gifts, invitations and hospitalities;

b) Strengthen capacities and raise awareness of public officials in at-risk positions and at-risk

sectors about the risks related to lobbying and influence activities on government policies;

c) Support an open organisational culture responsive to integrity concerns, including on lobbying

and influence practices;

d) Require that public officials promote fair and equitable representation of lobbying and influence

actors and proactively seek the views of those stakeholders that may be underrepresented in the

public decision-making process.

VIII. RECOMMENDS that Adherents implement an effective system to manage pre/post public office

and employment risks and other conflict-of-interest situations, whether at the domestic or international

level. To this effect, Adherents should:

a) Establish specific policies, rules, and procedures for managing conflict-of-interest situations in

connection to public decision-making processes;

b) Ensure that the conflict-of-interest risks posed by individuals entering the public sector from

government regulated sectors, in particular into regulatory functions, are properly mitigated;

c) Design effective rules and procedures such as cooling-off periods, subject-matter limits, time

limits, disclosure of post-term engagements by holders of at-risk positions, including abroad, and

prohibiting any use of any “insider” information after they leave the public sector.

IX. RECOMMENDS that Adherents safeguard those that scrutinise and/or report violations of the

policies and rules on lobbying and influence activities, such as media and civil society, by protecting their

right to freedom of expression and information. To this effect, Adherents should:

a) Promote pluralism and independence in media;

b) Protect all those who scrutinise and report violations (including journalists, media, and civil

society organisations) from intimidation, threats and physical attacks and abusive strategic

lawsuits against public participation;

c) Provide clear and effective rules and procedures for reporting suspected violations of the policies

and rules on lobbying and influence activities, and ensure protection in law and practice against

all types of retaliation as a result of reporting on reasonable grounds.

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X. RECOMMENDS that Adherents ensure there is an oversight function on lobbying and influence

activities with the capacity to enforce policies and regulations and monitor and promote their

implementation. To this effect, Adherents should:

a) Ensure that the oversight function reviews the completeness, adequacy and timeliness of all the

information disclosed for public scrutiny and the effectiveness of integrity standards;

b) Provide for fair, objective, proportionate, timely and dissuasive sanctions for non-compliance with

policies and regulations concerning lobbying and influence, through disciplinary, administrative,

civil and/or criminal processes;

c) Provide training on and raise awareness of the risks and policies and rules on lobbying and

influence activities.

XI. RECOMMENDS that Adherents periodically review, in consultation with relevant stakeholders, the

functioning and impact of their legal framework, public policies, procedures and guidelines to ensure

alignment with this Recommendation and evolving lobbying and influence practices, and in order to make

necessary improvements, strengthen their enforcement systems and seek convergence towards best

practices.

XII. ENCOURAGES non-governmental actors involved in lobbying and influence activities to follow

and promote the use of this Recommendation.

XIII. INVITES the Secretary-General to disseminate this Recommendation.

XIV. INVITES Adherents to disseminate this Recommendation at all levels of government.

XV. INVITES Adherents to the Recommendation on Public Integrity to take due account of, and adhere

to, this Recommendation.

XVI. INSTRUCTS the Public Governance Committee, through its Working Party on Public Integrity and

Anti-Corruption, to:

a) Serve as a forum for exchanging information and monitoring emerging trends on lobbying and

influence activities, including experience with respect to the implementation of this

Recommendation, to foster multi-stakeholder and interdisciplinary dialogue on lobbying and

influence activities;

b) Develop guidance to support Adherents’ implementation of this Recommendation;

c) Report to Council on the implementation, dissemination and continued relevance of this

Recommendation no later than five years following its revision and at least every ten years

thereafter.

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OECD Legal Instruments

Since the creation of the OECD in 1961, more than 500 legal instruments have been developed within

its framework. These include OECD Acts (i.e. the Decisions and Recommendations adopted by the

OECD Council in accordance with the OECD Convention) and other legal instruments developed

within the OECD framework (e.g. Declarations, international agreements).

All substantive OECD legal instruments, whether in force or abrogated, are listed in the online

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•

Recommendations are adopted by Council and are not legally binding. They represent a

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•

Substantive Outcome Documents are adopted by the individual listed Adherents rather than

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