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The list of Designated Public Officials (DPOs) who can be lobbied has recently been significantly expanded. With effect from 1 January 2025, the Minister for Public Expenditure, NDPD and Reform has prescribed an additional 180 new DPOs across 62 public bodies pursuant to the Regulation of Lobbying Act 2015. This is the first major extension of the list of in-scope DPOs since Ireland first introduced lobbying legislation ten years ago.
The new DPOs include a range of senior officials with significant policy-making or development functions in bodies such as the Central Bank of Ireland, Coimisiún na Meán, An Bord Pleanála, the Environmental Protection Agency, the Corporate Enforcement Authority, the Competition and Consumer Protection Commission, the Health Service Executive, the Health and Safety Authority, the Pensions Authority and many others. The full list of new DPOs can be found here.
This is an important change because businesses and organisations that interact with these officials will now be subject to lobbying registration and periodic disclosure requirements in respect of any qualifying lobbying communications they make, either directly or indirectly, to these officials. The obligation for compliance with these requirements falls on the lobbyist, not the DPO.
Therefore, businesses and other organisations that engage with the public sector should familiarise themselves with the new extended list of DPOs, as falling foul of lobbying rules can have serious legal and reputational implications. The first deadline for disclosure of any lobbying of the new DPOs (and registration for any first-time lobbyists) is 21 May 2025.
This development follows close on the heels of a broader strengthening of lobbying law that came into effect on a phased basis last year (see our updates here and here). It is likely that the list of in-scope DPOs will be further extended in the years to come in order to further strengthen the transparency objective of the lobbying regime.
We set out below a brief recap on the scope of lobbying law – who and what it applies to and what obligations attach when it is triggered.
Recap
1. Who do lobbying rules apply to?
Lobbying rules apply to almost all businesses operating in Ireland – except micro-businesses with 10 full-time employees or fewer.
In summary, any of the following can be lobbyists:
2. What qualifies as lobbying?
In broad terms, ‘lobbying’ captures any of three kinds of communications that seek to influence public decision-making which are made either directly or indirectly to DPOs – namely, communications relating to:
This is subject to various exceptions and exemptions in the legislation that apply in particular circumstances.
3. What obligations apply if you are lobbying?
Lobbyists are required to make regular returns disclosing their lobbying activity on the publicly available Register of Lobbying that is maintained by the Standards in Public Office Commission. First-time lobbyists are also required to register.
The deadline for compliance with these obligations falls 21 days after the end of the relevant ‘lobbying period’. There are three lobbying periods each year – January to April, May to August and September to December. The relevant deadlines are 21 May, 21 September and 21 January respectively.
Even if no lobbying activity is conducted within a particular period, a nil return must be filed to record this fact, unless a lobbyist avails of the facility for temporary de-registration from the register.
For further information, please contact Clara Gleeson, Senior Associate, or any other member of our Regulation of Lobbying team.
Date published: 21 February 2025
