Guidelines

1.       INTRODUCTION

The Interinstitutional Agreement between the European Parliament, the Council of the European Union and the European Commission (the ‘signatory institutions’) on a mandatory transparency register (the ‘IIA on the Transparency Register’), which entered into force on 1 July 2021, sets out the rules and principles governing the Transparency Register. The register is a public database set up for the registration of interest representatives and their activities carried out with the objective of influencing the formulation or implementation of policy or legislation, or the decision-making processes of the EU institutions.

These guidelines provide interest representatives who apply to be entered in the register (‘applicants’) and/or who already have an entry in the register (‘registrants’) with practical information on the registration requirements, including updates, and the registration procedure. They also explain the rules of the new IIA on the Transparency Register, in particular conditionality and other transparency measures (Part I, Section 3), eligibility and the code of conduct for registrants (Part II).

The Secretariat of the register is committed to continuously improving the quality of the register’s content and its user-friendliness. It has therefore consulted stakeholders on these guidelines and will update them as often as necessary to take account of registrants’ feedback and any updates to the system. The guidelines are published on the website of the Register (menu: ‘Guidance’) in all official EU languages.

The Secretariat has prepared a list of frequently asked questions (FAQs) for applicants and registrants to refer to, but these cannot cover every situation or issue that might arise. If you have any additional questions, remarks or suggestions that are not covered by the FAQs, you can send a query by connecting to your ‘restricted space’ ('Contact us' in the left column) or via the contact us form (requires EU Login authentication) – the Secretariat will respond as quickly as possible.

These guidelines were revised and adapted to the new version of the Transparency Register launched on 02 April 2024.

 

2.       DISCLAIMER

The Transparency Register is the primary component of the signatory institutions’ transparency policy as regards the representation of interests aimed at influencing the formulation or implementation of EU policy or legislation, or EU decision-making processes.

Registration in the register is voluntary and does not imply that the signatory institutions have given registrants any form of recognition, approval or accreditation. Despite the voluntary nature of the register, the signatory institutions may put in place measures (see Part I, Section 3) that will make registration mandatory for interest representatives carrying out certain types of activities, in order to ensure the transparency of such activities.

The information in the register is provided by the registrants themselves, on the understanding that they are ultimately responsible for its accuracy. The Secretariat monitors the quality of the register’s content and reserves the right to remove ineligible registrants, including those found not to observe the code of conduct.

The Secretariat may decide to suspend registrations that contain unwarranted or self‑promotional statements or that contradict the EU’s fundamental values, as laid down in Article 2 of the Treaty on European Union (e.g. through incitement to hatred or racism).

The content of the register is public. Information from previous declarations made by registrants remains publicly accessible on the official European data portal (data.europa.eu).

The register contains links to external websites over which the signatory institutions have no control and for which they cannot be held responsible. The fact that the register contains information or links provided by third parties does not mean that the signatory institutions either approve of or provide any guarantees regarding:

(i)   the body responsible for managing or providing the content on any of the websites;

(ii)  the services listed there;

(iii) the sites’ content; or

(iv) the views expressed on the sites.

 

3.       CONDITIONALITY AND OTHER TRANSPARENCY MEASURES

Through the IIA on the Transparency Register, the signatory institutions have committed to make the register effectively mandatory for certain types of interest representation activities (‘principle of conditionality’).

The signatory institutions adopt conditionality measures when they decide to make certain interest representation activities subject to prior registration in the register. This means that, although registration is voluntary, interest representatives must be registered if they want to perform the activity concerned vis-à-vis the institution that has put the measure in place. Registration thereby becomes a prerequisite for carrying out the activity in question.

For reasons of internal organisation, each institution implements this commitment individually. Therefore, the measures may differ from one institution to another.

The signatory institutions may also adopt complementary transparency measures to encourage registration and strengthen the joint framework of the register. These measures are designed to promote adherence to the register and its code of conduct, while offering advantages in return for registration.

All conditionality and complementary transparency measures adopted by the signatory institutions are published on ‘Conditionality’ on the register website. The website is regularly updated with any new adopted measures.

Please be aware that any EU institution, body, office or agency may decide to adopt conditionality and/or complementary transparency measures, and these will also be published on the same page.

Member States may also decide to adopt conditionality and/or complementary transparency measures, in accordance with national law, concerning their permanent representations to the EU.

Any such measures will be published on the register website, as applicable.

You should be prepared therefore for the possibility that the register may be used in a wider context than merely vis-à-vis the signatory institutions in relation to your interest representation activities at EU level.

More information can be found on ’Conditionality’.

 

1. ELIGIBILITY

In this context, an interest representative is any natural or legal person, or formal/informal group, association or network engaging in activities covered by the IIA on the Transparency Register.

Activities are ‘covered by the register’ if they are carried out by interest representatives with the objective of influencing the formulation or implementation of EU policy or legislation, or the decision-making processes of any of the EU institutions, bodies, offices and agencies.

Such activities may include (Article 3(2) of the IIA on the Transparency Register):

1. organising or participating in meetings, conferences or events, as well as engaging in any similar contacts with the EU institutions;
2. contributing to or participating in consultations, hearings or other similar initiatives, e.g. expert groups or intergroups;
3. organising communication campaigns, platforms, networks and grassroots initiatives;
4. preparing or commissioning policy and position papers, amendments, opinion polls and surveys, open letters and other communication or information material, and commissioning and carrying out research.

Interest representatives are eligible to register regardless of their legal form, size, location, type or goals, and regardless of the communication channel through which they carry out the activities. Interest representation activities are covered regardless of where they are carried out and of the communication channel used.

The purpose of the register is to show organised and/or collective interests, not personal interests of individuals acting in a strictly personal capacity and who are not in association with others.

Activities not relevant for the purposes of the register are those that do not seek to influence, but only to follow or monitor EU law or policy developments for academic or journalistic purposes, out of personal interest or in order to exercise a right (e.g. interviews by researchers or by journalists, or petitioning the European Parliament).

However, monitoring the legislative decision-making cycle is covered by the register when it is part of proactive intelligence gathering and, generally, part of a comprehensive range of services offered by, for example, public affairs service providers. These activities could lead to direct contacts with the institutions and  should be declared in the registration.

If your influencing activities are beginning or are under preparation, you must be able to provide appropriate details of the specific activities you are about to engage in.

You do not have to register, if you engage in the following activities (Article 4 of the IIA on the Transparency Register):

a) the provision of legal and other professional advice;

b) making submissions as a party or third party in the framework of a legal or administrative procedure established by EU law or by international law applicable to the EU, and submissions based on a contractual relationship with the Commission, Parliament or the Council or based on a grant agreement financed by EU funds;

c) activities of social partners acting as participants in social dialogue pursuant to Article 152 of the Treaty on the Functioning of the European Union (TFEU);

d)  making submissions in response to direct and specific requests from any of the EU institutions, their representatives or staff, for factual information, data or expertise;

e) activities carried out by natural persons acting in a strictly personal capacity and not in association with others;

f) spontaneous meetings, meetings of a purely private or social character and meetings taking place in the context of an administrative procedure established by the EU treaties or EU legal acts;

g) activities carried out by Member State public authorities, including their permanent representations and embassies, at national and subnational levels;

h)  activities carried out by associations and networks of public authorities at EU, national or subnational level, on condition that they act exclusively on behalf of the relevant public authorities;

i) activities carried out by intergovernmental organisations, including agencies and bodies emanating from them;

j)  activities carried out by public authorities of non-EU countries, including their diplomatic missions and embassies, except where such authorities are represented by legal entities, offices or networks without diplomatic status or are represented by an intermediary;

k)  activities carried out by churches and religious associations or communities as well as philosophical and non-confessional organisations referred to in Article 17 TFEU, with the exception of offices, legal entities, or networks created to represent churches, religious communities or philosophical and non-confessional organisations in their relations with the EU institutions, as well as their associations.

Interest representatives must operate in line with the rules and principles set out in the code of conduct when they carry out activities covered by the register. In order to register, they must confirm that they already observe those rules and principles.

 

2. SINGLE REGISTRATION PRINCIPLE

To avoid multiple entries and speed up the administrative handling of an application or registration, interest representatives operating in more than one country (e.g. multinationals, non-governmental organisations (NGOs) with chapters in various countries or regions) should register their activities in the register only once and, in doing so, cover the various other entities of a network, corporate group or similar. In practice, this generally falls on the branch or office representing the interests of the entity vis-à-vis the EU institutions.

 

3. DATA QUALITY

Make sure that the data you enter are complete, accurate and coherent. Remember that the information you provide is made available to in the public domain (except for fields with an eye slash sign ) and is therefore subject to public scrutiny.

The financial information you have to provide will depend on the type(s) of interest you represent (see headings 8 and 14 below).

The Secretariat screens all new applications and assesses:

(i) eligibility;

(ii) the quality of the data submitted.

You may be asked to provide additional information in order to substantiate your eligibility and/or improve the quality of the data. If the application satisfies the information requirements, the Secretariat will validate it and your registration will then be published on the register website. Regardless of whether your application is validated or rejected, you will be informed of the outcome.

In each heading of the registration form you will find info bubbles containing additional explanations on what information you are expected to provide. Hover your mouse over or select the info bubble to see the description for each heading/data field.

 

4. HOW TO REGISTER

You must register online via the register website. You can access the application form by logging in to your restricted space. To access this space, you must have an EU Login account (for more information, please refer to FAQ).

If you have all the necessary information ready to hand, completing the form should take around 20-30 minutes.

When you start completing the form, your application will be attributed a unique identifier (Application number: APP xxxx). Your registration will not be published until it has been assessed and validated by the Secretariat. You will then receive a public registration number (REG xxxxxxxx-yy). Do not confuse the APP number with the REG number.

When completing the form, the information you provide is automatically saved. You can pause at any time and come back later. However, if your draft application is not submitted within 21 calendar days, it will be automatically deleted and you will have to start over.

When completing the form, please bear in mind the following:

• React to the warning messages that may appear next to the fields in which the system has detected inconsistency. These messages help you by highlighting possible inaccuracies in the data you have entered. If you see a message, you may need to correct the data you have entered or provide clarifications in the free text boxes. If you ignore the messages and do not take appropriate action, the Secretariat will have to contact you for further explanation, which will delay the validation of your registration.
• Avoid inappropriate, irrelevant, promotional or misleading content – applications containing such content will not be accepted.
• Avoid abbreviations. The register is a public tool, so the information provided needs to be understandable. The Secretariat will ask applicants to update their entries before validating it if they are using too many abbreviations and acronyms.
• If the data provided are incomplete, you will not be able to submit your application.
• You may fill in the form in any of the 24 official EU languages (forms submitted in any other language will not be validated), but we recommend that you use the same language throughout, for the sake of consistency.
• Nominate a contact person to manage the content of the registration and receive automatic notifications from the register or messages from the Secretariat.
• Please do not include any personal data (information about identified or identifiable individuals) unless specifically asked to do so in certain headings of the form. Avoid introducing personal data under all other headings.

 

5. INFORMATION TO BE ENTERED IN THE REGISTER

 

Enter the name of the interest representative.

Provide the form of the interest representative: it could be the legal status or a type of entity with no specific legal status (e.g. a temporary set-up, a network or a platform).

Examples of legal status include association sans but lucratif (ASBL), charity, foundation, association, public limited company (plc), limited liability company (LLC), Gesellschaft mit beschränkter Haftung (GmbH), Aktiengesellschaft, Komanditgesellschaft, société coopérative à responsabilité limitée (SCRL) and société privée à responsabilité limitée (SPRL).

Your legal status is typically specified in a document such as your statutes or articles of association, or your registration in a national commercial register (e.g. the Moniteur belge in Belgium).

In the interest of transparency, provide a working website address or confirm that you do not have one. You can test the website address from the form to ensure the address is valid and the website can be accessed.

You will need to select the types of interests represented under heading 8, in order to clarify the underlying motivation for your activities.

Provide contact details of your head office and, if you have one, the office in charge of relations with the EU institutions, bodies and agencies.

If the address of your registered office (in your statutes) differs from your place of business, please indicate your place of business.

The person legally responsible must be an individual who is allowed by law to act on behalf of the interest representative or to represent it in contacts with public authorities. This person is also expected to be aware of the registrant’s commitments to observe the code of conduct.

If you have no legal status, please provide the name of a person legally responsible for the activities carried out under the relevant national law, or nominate another individual for the purposes of your register entry. If the interest representative (e.g. a trade or business association) is governed by a board, choose one of the board members (e.g. the president or chairperson); this person does not have to be the only person with legal responsibility.

The email address that you enter will not made public, but the Secretariat may use it to contact this person if a complaint is made about the interest representative.

If you have no formal structure, the person legally responsible is the person entrusted with representing you vis-à-vis the EU institutions.

The person in charge of relations with the EU institutions must be an individual who is responsible for the interest representative’s public affairs or contacts with the institutions.

If you have not designated a specific person responsible for these relations, you must nominate an individual for the purposes of managing your register entry (updates, etc.). This may be the contact person designated under heading 5 below. The email address that you enter will not be made public.

When the Secretariat validates the registration, the contact person will receive a validation email with the public registration number (REG number). The same information will be sent to the other people whose names are listed in the registration form (under heading 6 of the registration form ‘Persons with access to the registration’). 

The Secretariat may need to get in touch for clarifications or request updates on the information entered. The contact person will be the main point of contact for the Secretariat for all questions about the register. People whose names are listed in the registration form will receive all notifications, including:

• reminders about the mandatory annual update;
• information about submitted complaints and replies to queries (‘Contact us’);
• notifications about contributions their entity has made to Commission roadmaps and public consultations.

These people can also choose to receive notifications about:

• Commission roadmaps and public consultations;
• the activities of European Parliament committees.

Since contact persons can change regularly, you should provide at least one functional mailbox address (e.g. in the following format: infoorganisation [dot] com (info[at]organisation[dot]com)) to ensure that you continue to receive notifications and are not removed from the register.

The contact persons’ data are not public.

The system automatically grants access rights to the people below and their email addresses will automatically appear in the list in this heading (‘Access list’):

• the person who completes the application form;
• the person with legal responsibility;
• the person in charge of EU relations;
• the contact person.

You can add further email addresses if you want to grant access to additional persons.

Each of these people will be able to access the registration form as long as they have an EU Login account associated with the email address listed.

At least two different email addresses are required. If you provide the same email address for the person with legal responsibility, the person in charge of EU relations and/or the contact person and do not add any additional email address, you will not be able to complete the registration.

This free text box allows you to give a brief description of your general mission, objectives and remit (max. 1 000 characters). This is particularly important if you do not have a website.

You only have to provide a general description under this heading. You can give details of your interest representation activities under the next heading.

Indicate the geographical range and target area for your activities, e.g. global, EU, national or regional/local.

Choose between the options corresponding to the different types of interest representation. Your choice will determine the financial data you will have to provide under heading 14.

If you fall under more than one category, note that your legal status is not the only determining factor for this selection. You should choose the option that best describes your principal activity and explain the motivations behind your interest representation activities.

The options are described below.

1. Promoting your own interests or the collective interests of your members (which include profit-making entities, while also associations or entities that themselves represent profit-making entities) – this will typically cover companies and groups, professional or employers’ associations, trade union organisations and trade and business associations that represent members, a particular industry or business sector. For this type of interest representation, you will have to provide cost estimates for your activities covered by the register in the most recent financial year for which accounts have been closed.
2. Advancing the interests of your clients (as an intermediary) – representing the interests of clients is the option to choose when you have a contractual/pro bono relationship with companies, groups, associations, government bodies or NGOs that allows you to carry out interest representation activities on their behalf as a public affairs professionals or law firm. You will have to provide details of revenue for the activities declared in the most recent financial year.
3. Not representing commercial interests – this usually means you carry out activities not for profit, but solely for philanthropic, charitable, benevolent, humane reasons or in the public interest. Most of your members, affiliates or partners are also not profit-making entities. You will need to provide information on their budget and sources of funding.

It is possible to change interests represented once registered.

Under this heading, you should enter the information that will indicate why you are registering. In addition, please describe those of your activities that are covered (i.e. the EU policies or legislative proposals you seek to influence) as precisely and specifically as possible. Please do not list activities that do not concern EU policy or legislation.

• Activities conditional on registration

Choose the activities covered by conditionality measures from the drop-down list and indicate which of the EU institutions are concerned. This means you need to indicate your most frequent direct contacts with each institution for which you need to be registered because the EU institutions and bodies’ rules require it.

The information provided in this part of heading 9 will not be made public.

• Main EU legislative proposals or policies targeted

Provide the titles of the most recent EU initiatives, policies and (legislative/non‑legislative) files targeted by your interest representation activities. This includes roadmaps, public consultations, directives, regulations, decisions, interinstitutional agreements, European Parliament reports or resolutions. Please avoid acronyms.

Rather than referring to general policy areas (e.g. ‘environment’ ‘climate’, ‘transport’), refer to specific EU procedures (e.g. ‘Digital Services Act’). If possible, provide full official titles, for example:

• Proposal for a regulation on a Single Market for Digital Services (Digital Services Act);

• Regulation on the marketing of EU fertilising products;
• Communication from the Commission on A European strategy for data;
• European Parliament Resolution on the EU Biodiversity Strategy;
• Council Decision on the system of own resources of the European Union;
• European Parliament report on on-farm animal welfare.

 

• Communication activities (events, campaigns, publications, etc.) in relation to the above EU policies

You should use this free text box to give details on communication activities you have carried out on the EU policies, legislative proposals or decisions you have listed. This can include opinion polls and surveys (if they relate to EU legislation or target members of the institutions or officials working at the EU institutions), open letters and other communication or information material, campaigns, projects, events, publications or position papers and you should mention their titles. Website links with examples are acceptable.

• European Parliament intergroups and unofficial groupings

You may only participate in activities of intergroups or unofficial groupings organised on Parliament’s premises (for example, attending meetings or events of the intergroup, offering support or co-hosting events) if you are registered and if you agree to use neither the name nor the logo of the European Parliament.

If you participate in activities of European Parliament intergroups please select the group names from the list provided. You may use the free text box to indicate the name of any unofficial grouping you participate in and give details about your involvement (e.g. if you provide financial or material support or act as the group’s secretariat).

Do not select intergroups or mention unofficial groupings to express your interest in working with them; this is neither appropriate nor relevant.

• Participation in other EU supported forums and platforms

Provide details here on the EU structures in which you participate. If you do not take part in the work of such structures yet, please enter ‘No’.

This is not an appropriate place to express your interest in taking part in the work of such bodies in the future or your intention to apply for participation. Please enter information only on what is already taking place.

• Information automatically entered by the Commission in your registration

Your registration will show information on your activities that automatically comes from Commission IT systems (information described below). It is not entered by you when registering.

• Meetings with decision-makers

The register shows lists of meetings that registrants have had with Commissioners, members of their private office (cabinet) and directors-general (in PDF format) after the information has been published by the cabinet or the directorate-general concerned (at the latest 14 days after the meeting has taken place).

You can access information directly from registrations about meetings that Members of the European Parliament and their staff have scheduled.

• Commission roadmaps and public consultations

The register shows the titles of roadmaps and public consultations to which registrants have contributed since July 2018 (provided they had indicated their REG number - before 02/04/2024 - TR Id number - and agreed to make their contribution public).

If you contributed to roadmaps or public consultations in the 2 years before registering, you can list that activity here, e.g. ‘participation in the Commission public consultation on Fighting migrant smuggling: 2021-2025 (EU action plan launched in March 2021)’.

• Commission Expert groups

The register shows information on registrants’ memberships of Commission expert groups and other similar bodies. You do not have to register when applying to become a member of an expert group. Once members of an expert group have been selected, interest representatives that are not already registered will have to register in order to be appointed as a ‘type B’ or ‘type C’ member of the group.

Your membership (as a ‘type B’ or ‘type C’ member) of any Commission expert group(s) will automatically be displayed in your registration once your REG number has been encoded in the Register of Commission expert groups.

Give the most up-to-date figure for the number of individuals carrying out activities covered by the register on behalf of the interest representative at the time of the registration (or the update). Do not declare all staff working for the interest representative, but only those involved in the activities declared under heading 9.

Include all individuals carrying out interest representation activities, regardless of whether they have a contract or are paid for those activities (by you or others). This might include regular staff on your payroll and people working for you as interns, volunteers, consultants, academics, collaborators, etc.

You must include anyone with a European Parliament access pass and keep your entry up to date to include anyone who obtains Parliament accreditation.

 

Please use the free text box to describe the status (‘employee’, ‘volunteer’, etc.) of the individuals concerned and enter any other information that may clarify your headcount and ‘full-time equivalent’ (FTE) calculation.

The register automatically expresses the information you have entered as FTEs. This is a standard accounting unit used to measure the number of people performing a given activity (in this case, interest representation activities). This is the average number of hours worked by a given employee as a fraction of the average number of hours worked by a full-time employee, i.e. one FTE corresponds to one full-time employee.

If the five percentage blocks do not exactly match your human resources structure, round off the figures as appropriate. There is no minimum threshold – even if you have only one person working on a basis of 10% FTE or less in interest representation activities, you should still register; however, you can clarify this low level of engagement in the free text box provided.

Update the data provided if the total number of employees falls/increases significantly at any point during the year.

The information you provide should be a good-faith estimate of the total number of individuals involved and should reflect the time allocated to the activities. Bear in mind that you may be asked to provide the Secretariat with additional details on resource calculations.

 

Based on the policy areas that you target in your interest representation activities, you can subscribe to automatic email notifications on certain activities of the EU institutions.

• Commission public consultations and roadmaps – receive information about these in the field(s) that interest(s) you

Indicate whether you would like notifications to be sent to you

• European Parliament committee news – receive news and meeting agendas for the policy area(s) of your choice.

You can manage subscriptions to the European Parliament committees’ news and agendas directly via your registration. For notifications about other European Parliament activities, please visit the Parliament’s Email subscription service.

Give details of:

• your membership of any associations, federations, confederations, networks or other bodies (not run by the EU institutions);

• your own members and affiliates (partners, sponsors and similar) – list your current members and affiliates (partners, sponsors and similar). If this list is publicly available on your website, include a direct link to the web page.

Types of membership are diverse, and this information may need to be updated regularly. It is therefore recommended that you provide direct links to your web page with the relevant details. If your members are both natural (individual) and legal persons (organisations), you should describe the different types. Remember to complete this field if you represent your members’ interests.

For the sake of transparency, the Secretariat welcomes any additional information that helps clarify a registrant’s structure, partnerships, supporters and other affiliations. Any relevant information about affiliates, subsidiaries or similar (e.g. carrying out interest representation activities and related costs) should be included here. You should specify which entities of the network, corporate group or similar are covered by the registration.

Select a category that most closely fits your objectives, mission, structure, activities and legal personality. Even if you could fall under more than one category (e.g. you could be representing a trade association that is also a non-profit-making entity), you can only select one category. If you are in any doubt, the decisive factor should be what you do, not your legal status or similar formal criteria.

You are asked to select a category for descriptive purposes only; this does not affect the (type of) financial information you will have to provide. The categories enable the Secretariat to produce reliable statistics on registrants.

• Newly formed entity, no financial year closed

You should only tick this box if your organisation has only been set up recently and you have not yet closed your accounts for the most recent full financial year. This option reflects a transitional situation for newly established interest representatives. You must provide the financial data requested at the time of your first annual update or, at the latest, the next annual update. Please note that you can only use the ‘newly formed’ status for 24 months.

If you select ‘Newly formed’, you will still have to provide some information for the current financial year (certain data fields will not be editable).

• Most recent ‘financial year’ closed

Please enter an accounting period of 12 consecutive months. This period can start on any day of a calendar year for which accounts have been closed. A financial year may or may not coincide with a calendar year.

• EU grants

All interest representatives must declare the amount and source of any EU grants contributing to their operating costs (relevant programme and funding authority). All amounts must be declared in euro and correspond to the most recent financial year closed or, if more relevant, the current financial year.

If you are a newly formed entity, please provide an estimate of the EU grants received for the current financial year.

You should select the ‘Add’ button each time you add a new source of funding.

What is the difference between grants and public procurement contracts?

Grants: These are mainly awarded by way of donation through calls for proposals for projects furthering EU policy aims. These should be declared in the registration form.

For the sake of transparency, you can provide information about EU grants received by subsidiary companies in the text box under this heading. For ‘decentralised implementation’ of EU funding (i.e. EU funding disbursed by Member States), the national administration awards grants and procurement contracts. You do not have to declare funding received directly from national authorities (e.g. project funding from the structural or cohesion funds).

Public procurement contracts: the EU institutions purchase services, works or goods on the market for internal use via a tendering process. Amounts received through public procurement do not have to be declared in the registration form.

Interest representatives running EU-funded projects should be careful not to overestimate the human and financial resources involved in interest representation activities. For example, you should only count the time for those individuals actually carrying out your interest representation activities vis-à-vis the EU institutions. Do not count the time of those working solely as researchers, tutors, project coordinators, etc. Similarly, you should not include any expenditure or costs relating exclusively to implementing your EU-funded project.

If you promote your own interests or the collective interests of your members, please provide financial information on:

- any intermediary hired to carry out covered activities;

- your annual costs in relation to interest representation activities for the most recent financial year closed.

• Hiring intermediaries to carry out interest representation activities

As an interest representative promoting your own interests or those of your members, you may decide to outsource some interest representation activities to intermediaries acting on your behalf.

An intermediary is any interest representative that advances the interests of a client by carrying out activities covered by the register. The relationship between an intermediary and its client is based on a contract. For instance, if you have hired the services of a professional consultancy or a law firm to carry out interest representation activities vis-à-vis the EU institutions on your behalf, that professional consultancy or law firm is your intermediary. The contractual relationship between you and your intermediary is irrelevant for the purposes of the register when, and to the extent that, it does not concern interest representation activities carried out by your intermediary on your behalf.

If you are a client of such (an) intermediary(ies), you should provide the name(s) and the associated annual cost for each intermediary, according to the financial brackets provided. The estimate should cover a full year of operations and refer to the most recent financial year closed.

You should also declare services provided by intermediaries under contract in the current financial year, and name each intermediary (with no associated cost estimate). If you have not outsourced any activities in the most recent financial year closed or in the current year, please select ‘No’. If there is a change during the year, this declaration should be updated.

• Annual costs relating to activities covered by the register

Interest representatives who promote their own interests or the interests of their members should provide an up-to-date estimate of annual costs relating to activities covered by the register. Financial figures must cover a full year of operations and refer to the most recent financial year closed, as of the date of registration or of the annual update of the registration.

Please declare your estimated costs as a range and only include costs relating to activities covered by the register. Annual costs should not be confused with turnover or total expenditure.

To estimate your total costs you should take account of all activities covered by the register and add up the costs below related to those activities.

1.    Staff costs – based on the FTE figure declared under heading 10. These include gross salary/fees plus any allowances, bonuses or other benefits paid. If staff are paid by others or work on a voluntary basis, please provide this complementary information in the relevant text box.

2.    Office and administrative expenses – rent and utilities, supplies and materials, IT equipment, maintenance, cleaning, permits, etc. Calculate these costs as a proportion of the activities covered by the register.

 

3.    In-house operational expenditure – cost of relevant advocacy, public relations or public affairs campaigns, marketing and advertising, use of media, organisation of events, publications, etc.

4.    Representation costs – expenses incurred by taking part in relevant public affairs events and meetings (e.g. registration fees, travel, accommodation, daily subsistence and other related costs). This includes relevant sponsored activities for members and fees for training and capacity-building events.

5.    Outsourced activity costs – fees for consultants and subcontractors for relevant activities. The costs of activities outsourced to intermediaries should be included, in line with the above declaration. Intermediaries working under contract should make a separate declaration in the register and declare those costs as revenue.

6.    Membership and related fees – fees for joining relevant networks, associations and structures listed under ‘Membership and affiliation’. Please include annual membership fees for trade associations or federations that conduct activities covered by the register, even if these entities are not in the register themselves. Membership fees should be included as a proportional calculation, i.e. an estimated percentage of the total membership fee, in line with the percentage of relevant activities.

7.    Other relevant costs – add any other relevant costs relating to your representation activities.

The register allows for two interest representatives to declare the same expenditure (‘double counting’). The financial declaration made by a registrant about the estimate of costs concerning relevant activities does not exclude another registrant declaring the same amount received by the first registrant in terms of relevant turnover (from clients) or in terms of budget (from membership fees). This approach avoids underestimating the declared financial outlay.

Once you have estimated the costs relating to activities covered by the register for the most recent financial year closed, choose the most appropriate bracket and keep a record of your calculation. The Secretariat may contact you about this calculation for data quality or consistency purposes.

If you are an intermediary advancing the interests of your clients by carrying out interest representation activities on their behalf, please provide financial information about:

• your clients;
• your total annual revenue for the most recent financial year closed.

• Client(s) on behalf of whom you engaged in representation activities vis-à-vis the EU institutions

As an intermediary, you must provide the name of all clients on whose behalf you carry out interest representation activities covered by the register. If you have selected ‘interests of client(s)’ under heading 8, please provide that client information under heading 14. You will not be able to complete your registration without providing names of clients.

A client is any interest representative that has entered into a contractual relationship with an intermediary whereby the intermediary advances its interests by carrying out activities covered by the register.

For instance, if you are a professional consultancy or a law firm and you carry out interest representation activities vis-à-vis the EU institutions on behalf of an interest representative on the basis of a contract, that interest representative is your client.

Please select the appropriate financial bracket for each client, to show the estimated revenue received for relevant representation activities from that client in the most recent financial year for which accounts have been closed.

Please also list the most recent EU legislative proposals, policies or initiatives targeted by the activities on behalf of this specific client; these should correspond to the entries under heading 9.

Select the ‘Add’ button each time you add a client’s name.

Full disclosure of clients

You must provide a complete list of clients (for the most recently closed financial year), specifying their full names (do not use acronyms). You must also declare names of new clients covered in the current financial year, even if you are a newly formed entity.

Declarations that do not name individual clients or that use generic terms only (e.g. ‘corporates’, ‘other small clients’, ‘confidential information’) will not be accepted. The same applies to abbreviations and non-identifiable entities.

Services provided to non‑EU countries

If you carry out interest representation activities vis-à-vis the EU institutions on behalf of public authorities in non‑EU countries, including their diplomatic missions and embassies, on the basis of a contract, you must declare them as client(s).

Services provided to EU institutions, bodies and agencies or to intergovernmental organisations under a public procurement contract

These are not considered to be activities covered by the register, and such institutions, bodies, agencies or organisations are not to be listed as clients.

• Revenue generated by activities covered by the register

Intermediaries must declare the estimated total annual revenue generated that is attributable to interest representation activities for the most recent financial year closed, as of the date of registration or the annual update. The register automatically calculates this amount on the basis of the aggregate sum of the estimated revenue generated per client. This ensures that declared turnover tallies with client revenue. It is therefore very important to include all relevant clients and the revenue attributable per client.

Turnover is the amount of money taken by a business during a particular period. Financial figures must cover a full year of operations and refer to the most recent financial year closed, as of the date of registration or the annual update.

If you also carry out relevant activities in your own interest that do not serve the interests of (a) client(s), you must provide the corresponding description and estimates in the information text box provided.

If you do not represent commercial interests, please provide the following financial information:

• your main sources of funding;
• the amount of each contribution above EUR 10 000 that exceeds 10% of your total budget and the name of the contributor;
• the total budget for the most recent financial year closed.

You are considered as not representing commercial interests if:

1. you promote your own interests, and your principal purpose of establishment and/or field of activity is of a non-commercial, non-business or non-profit-making nature;
2. you promote the collective interests of your members, and the principal field of activity of 50% or more of your members is of a non-commercial, non-business or non-profit‑making nature;
3. where (i) and (ii) apply, your main purpose is advancing societal causes in the public interest, regardless of any ancillary economic activities you may carry out, e.g. administering own funds or property, or implementing programmes and projects on your own behalf or on behalf of your members.

Determining whether you represent non-commercial interests must be done regardless of your legal status or form of establishment.

 

 

The following categories of interest representatives would normally be considered not to represent commercial interests although particular circumstances may involve a decisive commercial or profit-making element in the interests represented:

• civil society organisations, NGOs, charities, foundations;
• academic and research institutions, think tanks, policy institutes;
• organisations representing churches and religious communities.

• Sources of funding

Please indicate the main sources of funding by category: EU funding, (national) public financing, grants (including EU grants), donations and members’ contributions. You can select several categories to cover all possibilities. Please add any other sources that are relevant but not listed (e.g. sponsorships’ or ‘reserves’) by selecting ’Other’.

For each contribution received that exceeds 10% of your total budget AND is above EUR 10 000, please provide the amount of the contribution and the name of the contributor by selecting ‘Add’.

Example 1:

An organisation with a budget of EUR 1million has received a contribution of EUR 15 000. The contribution does not have to be declared as it does not exceed the 10% threshold.

Example 2:

An organisation with a budget of EUR 100 000 has received a contribution of EUR 15 000. The contribution must be declared as it exceeds the 10% and EUR 10 000 thresholds.

If the same contributor has made more than one contribution in the same financial year and the combined amount is above EUR 10 000 and exceeds 10% of your total budget, you should fill in the combined amount.

You can use the text box to provide additional financial information about your interest representation activities.

• Budget

Interest representatives that do not represent commercial interests should provide their total budget for the most recent financial year closed as an absolute amount in euro. The amount should take account of the funding declared above (including any specific amounts). If you are a newly formed entity and have no financial year closed, you do not have to provide a budget or sources of funding but should declare any EU grants received in the current financial year.

Definition of ‘budget’

Your budget is your annual income and expenditure (financial accounts) for the most recent financial year closed. Please note this refers to an organisation’s entire budget (not only funds set aside for interest representation activities).

If you are not in a position to provide a budget because your organisation does not have one, you may indicate a ‘0’ figure as your budget. As this is considered to be exceptional circumstance, please explain in the text box provided:

1. why you are unable to provide a budget;
2. how you finance your interest representation activities.

Please tick the box to confirm that you work in line with the rules and principles laid down in the code of conduct.

6.       PENDING VALIDATION

Once you have completed all 15 headings, you will see the ‘Summary’ page where you can review the information you have provided. At the bottom of that page, you will find the ‘Run check’ button. Selecting this button runs a check to make sure the information is complete. This feature is also available at any time when completing the registration form.

When you select the ‘Submit’ button, the contact person will receive a confirmation email acknowledging that the registration has been submitted and the status is ‘submitted’. To complete the registration and be validated, you must respond to any requests from the Secretariat for additional information. Once the Secretariat has validated your registration, the contact person will receive a validation email, including your identifier, the public REG number.

Do not forget to complete the form by selecting ’Submit’; otherwise, all the data entered will be lost after 21 days.

1.       GENERAL

• continue to observe the code of conduct

You must work at all times in line with the code of conduct. The code of conduct sets out 16 rules and principles, all of which are equally important. You must inform your staff and representatives about those rules and principles; observing them is a matter of eligibility. Only registrants observing the code can remain in the register.

The Secretariat monitors registrations and evaluates registrants’ eligibility and observance of the code of conduct in line with the procedures set out in Annex III to the IIA on the Transparency Register. The Secretariat may open an investigation on the basis of an admissible complaint alleging that a registrant has not observed the code of conduct. Any natural or legal person may lodge a complaint with the Secretariat about a registrant’s alleged non-observance of the code.

A decision by the Secretariat on non-observance of the code of conduct can lead to the removal of the registration concerned from the register. Depending on the seriousness of the case, the decision can lead to:

(i)      a ban on the interest representative concerned from registering again for a period of between 20 working days and 2 years;

(ii)        the publication of the measure taken on the register’s website.

When deciding on the severity of the measure to be applied, the Secretariat will duly take into account the position of the registrant(s) concerned and the circumstances of the investigation.

Registrants that are subject to the measures mentioned above have the right to lodge a reasoned request for review by the register’s Management Board. This can be done by submitting a request for review to the Secretariat within 20 working days of receipt of the notification of the measure taken. Further remedies are available to registrants who are not satisfied with the Management Board’s decision, namely the right to appeal to the Court of Justice or submit a complaint to the European Ombudsman.

• carry out a compulsory annual update

Every 12 months, starting on the first year of your registration, you must carry out an annual update, validate all the data provided and commit to observing the code of conduct. The contact person will receive automatic email reminders 4 and 2 weeks before the deadline. To update, you should log in via the ‘Register or Update’ tab and select ‘annual update’. However, you can make an annual update whenever you need to make fundamental changes or adjust the deadline of your next scheduled annual update. You can do this by logging to your restricted space.

• carry out partial updates to stay up to date

If you do not want to change the annual update deadline, you may also use a ‘partial update’ option to update data under specific headings (such as financial information). Partial updates do not replace the obligation to carry out an annual update.

• be transparent about your activities and set-up

When in contact with the EU institutions and bodies, you are encouraged to state that you have signed up to the register and provide your REG number;

• cooperate sincerely and constructively with the Secretariat

All registrations are subject to monitoring or investigation by the Secretariat at any time. This is to ensure the accuracy and completeness of the information and to avoid factual mistakes and/or non-observance of the code of conduct. Where inconsistencies are identified, the Secretariat will contact the registrant concerned to seek clarifications and find a satisfactory solution.

2.       REGISTRATION UPDATES

The information recorded in the register is publicly available and is closely scrutinised by stakeholders, academics, students, journalists, private individuals and others. It is therefore in your interest to keep your registration up to date.

Ideally, you should update your registration as soon as there are any changes in the information provided and, in any case, within 3 months. We recommend that you review it at least three times a year and update it where necessary. Changes can be part of an annual update (i.e. a systematic review of the whole registration and commitment to observe the code of conduct) or a partial update (i.e. when you do not wish to review the whole registration or change your annual update deadline).

Six months before your annual update deadline, you will receive an automatic reminder to review your registration and update it. The contact person indicated in the registration will then be reminded automatically 4 and 2 weeks before the annual update deadline (which is 1 year after the date of the registration or the last annual update).

Contact people will receive an automatic email with a confirmation of the updated registration.

If you do not carry out the compulsory annual update, your registration will be automatically suspended (it will still be visible on the register’s public website, but marked as ‘suspended’). When it is suspended, you will be able to access your organisation’s space and carry out the update. If this is not done in 15 working days, the registration will be automatically removed from the register.