Irish Lobbying Act Widens Scope to Include Additional Regulators and Official Bodies

Companies involved in lobbying activities in Ireland now face additional reporting requirements due to the extension of the Lobbying Act to cover over 60 additional official bodies. With senior officials from Ireland’s key regulators now falling under the Act, it is crucial for companies to understand their new obligations to mitigate the risk of penalties and potential reputational damage.

Declaring Lobbying Activity

Under Ireland’s Regulation of Lobbying Act 2015, individuals and organisations that engage in activities considered to be lobbying must publicly declare their engagements. The responsibility lies with companies to self-assess whether their activities meet the criteria for registration and to then disclose it.

Activity needs to be declared on Ireland’s lobbying register, lobbying.ie if it relates to one or more of the following criteria: 

• The initiation, development or modification of any public policy or of any public programme
• The preparation or amendment of any law
• The award of any grant, loan, contract, or of any licence or other authorisation involving public funds other than the implementation of any such policy, programme, enactment or award or any matter of a technical nature only.

This activity must only be declared if the communication was with a Designated Public Official (DPO). A number of political stakeholders are DPOs, including:

• Ministers and Ministers of State.
• Special Advisers to Ministers.
• TDs (Members of parliament) and Senators.
• Irish Members of the European Parliament (MEPs).
• Local authority members.
• Senior public servants and other individuals outlined in the Act.

If these conditions apply, companies are required to register on the Lobbying Register and submit a return detailing their lobbying activities every four months. Although returns can be submitted at any time during the reporting period, all returns must be submitted no later than 21 days after the period ends.

Additional Bodies from January 2025

Since 1 January 2025, an additional 62 official bodies have been included under the Act. Companies must now declare engagement with certain senior officials in these bodies if it is considered lobbying. Notable bodies that now come under the Act include:

• Central Bank of Ireland
• An Bord Pleanála (The Planning Board)
• Office of the Planning Regulator
• Maritime Area Regulatory Authority
• Coimisiún na Meán (Media Regulator)
• Health Service Executive
• National Transport Authority
• The Pensions Authority
• Environmental Protection Agency
• Science Foundation Ireland
• Residential Tenancies Board

The full list of bodies and their DPOs are available here and here.

What it means for companies

The Act’s extension to additional official bodies may have implications for companies across several sectors, such as real estate, energy, financial services, pharmaceuticals, and technology. Companies should take certain steps to ensure they comply with the Act and avoid penalties:

• Companies should consider auditing all employee interactions with official bodies covered by the Act, particularly any engagement involving DPOs. This is especially important for companies with employees who engage with Irish regulators as part of their work, given that several regulators are now covered by the Act.
• If there is engagement with them, then begin to compile a tracker which includes the individuals with whom staff engages and the nature of this engagement.
• Update internal processes to ensure compliance with the Act.

At FTI Consulting, we support companies to ensure they are fully compliant with their obligations under the Act and navigating the reporting process. Get in touch if you’d like to know more about our work in Ireland.