Rulebook
a consultant's rulebook by Epaca
Lobbying in the European Union is subject to a framework of rules and standards that aim to ensure transparency, accountability and integrity in interactions between interest representatives and EU institutions. This rulebook provides a comprehensive overview of the main rules and requirements EPACA members must adhere to when engaging with EU institutions.
1. Transparency register
Interest representatives must be registered in the EU Transparency Register to be allowed to participate in certain interactions with the EU institutions. These interactions include meetings with high-level European Commission officials, participation in European Commission expert groups, and access to the European Parliament’s premises.
The Transparency Register requires registrants, including public affairs consultancies, to disclose and regularly update information like:
- Their organisation’s identity and legal form
- Number of people involved in lobbying
- Annual lobbying budget and clients
- Objectives and fields of interest
- Legislative files targeted
- Membership to networks or coalitions
Code of Conduct for Registrant to the Transparency Register
All registrants must agree to and comply with the Transparency Register Code of Conduct, which includes:
- Honest and accurate representation of interests
- No undue pressure or improper behaviour
- Compliance with rules on access and confidentiality
- Clear indication of whom they represent
- Avoid offering gifts or benefits that may create a perception of undue influence
- Respect confidentiality of internal documents
- Refrain from hiring former EU officials in breach of cooling-off periods
Penalties for non-compliance
- Removal from the Transparency Register (temporary or permanent)
- Public exposure on the Transparency Register website
- Suspension of access badges to EU premises
- Possible reputational damage and exclusion from consultations or expert groups
2. MEETINGS WITH EU DECISION-MAKERS
Meetings with certain EU decision-makers are conditional on registration in the EU Transparency Register. However, each institution has its own set of rules governing meetings with interest representatives:
European Commission
- Members of the Commission, their members of Cabinet, and Commission staff holding management functions (i.e. Head of Unit equivalent and above) can only meet interest representatives that are registered in the Transparency Register and need to provide public information on such meetings.
- The information to be made public includes:
a) the date of the meeting
b) the location of the meeting
c) the name and function of the Commission staff attending
d) the names of the interest representatives attending
e) the subject matter of the meeting - Minutes of all meetings that Commission staff covered by this rule hold with interest representatives are to be made public and include the main points raised and positions expressed during the meeting.
European Parliament
- Members of the European Parliament (MEPs) should only meet interest representatives that are entered in the Transparency Register and must publish all scheduled meetings with interest representatives online.
- This rule also applies to meetings attended by the MEP’s parliamentary assistants on their behalf.
- Rapporteurs must list the entities or persons from whom they received input on matters pertaining to the subject of the file in annex to their report or opinion (legislative footprint).
Council of the EU
- The Secretary-General and Directors-General of the General Secretariat of the Council can only meet with interest representatives that are entered in the Transparency Register.
- During their term of office and in the six months before, the Presidency of the Council of the EU commits to only meeting interest representatives that are registered in the Transparency Register.
- There are no EU rules on lobbying transparency for national delegations.
European commission
Commissioners and cabinet members
Commissioners and cabinet members
No registration, no meeting
Publication of meeting
Minutes
Legislative footprint
European Parliament
MEP’s
Rapporteur
No registration, no meeting
Publication of meeting
Minutes
Legislative footprint
Council of the European Union
General secretariat
Presidency of the Council
National Delegations
No registration, no meeting
Publication of meeting
Minutes
Legislative footprint
European commission
Commissioners and cabinet members
Commission staff (Head of Unit and above)
European Parliament
MEP’s
Rapporteur
Council of the European Union
General secretariat
Presidency of the Council
National Delegations
No registration, no meeting
Publication of meeting
Minutes
Legislative footprint
3. Membership and participation in groups, events and briefing sessions
Participation of interest representatives to the following groups, events and briefing sessions, or their offering support to it, are conditional on their registration in the Transparency Register:
European Commission
- Expert Groups
European Commission
- Expert Groups
- Parliamentary events
- Co-hosted events
- Political group events
- Intergroups
- Unofficial groupings
- Thematic briefings
- Public events
European Commission
- Thematic briefings
- Public events
4. Access to the premises of the EU institutions
Participation of interest representatives to the following groups, events and briefing sessions, or their offering support to it, are conditional on their registration in the Transparency Register:
European Commission
- Entities entered in the Transparency Register can request a long-term access badge to the European Parliament’s premises.
- A badge can be withdrawn or deactivated if its holder has been suspended or removed from the Transparency Register for a breach of the Code of Conduct, or if they have refused to comply with a formal summons or hearing.
Council of the EU
- Entities entered in the Transparency Register can request a long-term access badge to the European Parliament’s premises.
- A badge can be withdrawn or deactivated if its holder has been suspended or removed from the Transparency Register for a breach of the Code of Conduct, or if they have refused to comply with a formal summons or hearing.
5. Gift-giving and hospitality
Participation of interest representatives to the following groups, events and briefing sessions, or their offering support to it, are conditional on their registration in the Transparency Register:
European Commission
- Entities entered in the Transparency Register can request a long-term access badge to the European Parliament’s premises.
- A badge can be withdrawn or deactivated if its holder has been suspended or removed from the Transparency Register for a breach of the Code of Conduct, or if they have refused to comply with a formal summons or hearing.
European Parliament
- The General Secretariat of the Council grants interest representatives nominative badges giving them temporary access to Council premises, provided they are registered in the Transparency Register.
6. Revolving doors & cooling-off periods
All interest representatives must refrain from hiring former EU officials in breach of cooling-off periods.
Commissioners
- Former Commissioners must inform the Commission at least two months before engaging in new professional activities within two years after leaving office.
- They cannot lobby on matters related to their former portfolio for two years (three for a former President).
MEPs
- Former Members of Parliament cannot lobby the institution for the first six months after their mandate ends.
- After this period, they must register in the Transparency Register.
- Former MEPs may access Parliament buildings but not for lobbying purposes.
EU Staff
- Staff leaving an EU institution within two years must inform the Commission before accepting new roles.
- The Commission may forbid or condition such activities if conflicts arise with prior responsibilities.
- Senior officials are prohibited for 12 months after leaving service from lobbying their former institution on related matters.