Lobbying Regulations Compared
How different democracies regulate lobbying, which approaches work best, and what a model regulatory framework would look like.
The Regulatory Spectrum
Countries approach lobbying regulation along a spectrum from heavy regulation to no regulation at all. The United States represents the most comprehensive system: mandatory registration, quarterly spending disclosures, and public databases. Canada requires a dedicated lobbying commissioner who can investigate violations. Australia mandates registration and a code of conduct. France adopted a lobbying register in 2017 overseen by an independent authority.
At the other end, many European countries, including Germany until 2022, had no mandatory registration. Most developing countries have no lobbying regulation whatsoever. Even within regulated systems, the definition of 'lobbying' varies enormously. Some systems only cover direct contact with legislators; others include executive branch lobbying, regulatory lobbying, and even lobbying of subnational governments. The narrower the definition, the more influence activity escapes disclosure.