Making the Transparency Register Transparent: European Movement proposals

Take a look at the European Movement’s reaction to the Transparency Register proposals outlined on Wednesday 28 September 2016 here.


The European Commission opened a Public Consultation on a proposal for a mandatory Transparency Register, which will run from 1 March 2016 until 1 June 2016. The public consultation is meant to gather views on the functioning of the current register and to input on the design of the future mandatory register.

The European Movement International believes that ethical and transparent lobbying is indispensable for genuine, democratic and accountable decision-making. A mandatory transparency register is therefore an essential building block in constructing a sound European legislative process.

With this in mind, the European Movement International recently made a submission to the European Commission’s Public Consultation, and we encourage you to make your own contributions.

Here are our main recommendations:

Principles to guide lobbying and advocacy at the EU level

  • The key principles for a Transparency Register are integrity, accountability, enforcement of compliance, equality of access, and full disclosure.
  • EU rules guiding its policy-making processes and their transparency should cover all processes – transparency should be improved both with regard to the Transparency Register and beyond.
  • The Transparency Register can only make an impact if it is accompanied by other actions with regard to transparency, integrity and equal access.
    – This includes the implementation of Article 11 of the Lisbon Treaty: on open, transparent and regular dialogue with civil society; ensuring a balance between business-oriented lobbies and non-business related entities in expert groups; and ending informal trilogues or making them more transparent.
  • The rules and regulations around the Transparency Register should not interfere with the EU’s more general commitment to communicate with EU citizens; rather it should focus on restricting undue influence on the decision-making process.

Scope of the Mandatory Transparency Register

  • The inclusion of the Council in the Transparency Register is a necessity for genuine democratic and accountable decision making at the EU level.
  • All activities carried out to (directly or indirectly) influence policy-making, policy implementation and decision-making in the European Parliament, Commission, and Council, regardless of where they are carried out or which channel or method of communication used should fall under the scope of the Transparency Register.
  • A non-exhaustive list of activities that fall under the Transparency Register should accompany the register, to limit as much as possible the room for (mis)interpretation. This should also include clear descriptions of what spending and personnel should be reported, to avoid confusion.
  • All organisations should be included in the register, including religious organisations. Only public administrations should be exempt if they are subject to existing democratic checks and balances.
  • The Register should be mandatory for membership of all bodies and groups that facilitate the participation of interest representatives in the EU decision-making process.

Setup of the Transparency Register

  • The data quality in the Register should be improved through consistent checks and a better impression of the work of the registered organisations, for which an expansion of the Joint Transparency Register Secretariat might be necessary.
  • The website of the Register should directly link to information of meetings or visits to the European Commission, the Parliament and the Council and details of removals, withdrawals and past registrations should also be made available.
  • The Code of Conduct that accompanies the Transparency Register should better reflect the obligations of interest representatives with regard to integrity, equality of access, full disclosure and accountability.
  • The Code of Conduct and procedure for dealing with alerts and complaints should include provisions on the enforcement of compliance. The names of organisations that are suspended under the alerts and complaints should be published.

Learn more about the public consultation here.


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