Our proposal for regulation

The Bureau of the Congress of Deputies defines an interest group, lobby or lobbyist as those natural or legal persons or entities without legal personality that communicate directly or indirectly with holders of public office, elected officials or staff members in their charge in favour of private, public, individual or collective interests, trying to modify or influence issues related to the drafting, development or modification of legislative initiatives.

At APRI we observe that the Spanish political scenario recognizes the importance of creating a regulation of the professional activity of interest groups. However, there is still no national law by consensus, but only some regulations at the regional level within the agenda or the transparency law.

For this reason, APRI works as an association of lobbyists contributing to the dialogue with different parliamentary groups in order to promote a regulation of interest groups.


Currently, there are the following approaches to regulating the professional activity of lobbyists and interest groups at a national and European level:

  • The “Code of Conduct for Deputies”: signed by all members of the Congress of Deputies, which has been in force since April 2nd, The document establishes the obligation of the deputies to make their institutional agenda public in the Transparency Portal of the Congress.
  • European Union Transparency registerhttps://ec.europa.eu/info/about-european-commission/service-standards-and-principles/transparency/transparency-register_en
  • Register of interest groups of the National Commission for Markets and Competition (CNMC):voluntary and in force since March, This is the first register created by a central public body in Spain.
  • Existing registers in several Autonomous Communities such as Catalonia, Madrid and Castilla-La Mancha.


Taking as an example the already existing regulations, and considering the definitive search for the efficiency of the professional lobbying activity, APRI has drafted a Proposal for Regulation which addresses regulations in the sector whose main objectives are:

  1. Guarantee transparency in political and legislative decision-making
  2. Reinforce the legal certainty of norms and their development processes
  3. Reinforcethe legitimacy of institutional representativesin their executive or legislative work
  4. Improve regulatory effectiveness
  5. Promote accountability
  6. Facilitate citizen participation in the political life of the country


In our Proposal for Regulation, we have stated our position on what should shape the final regulation of interest groups and lobbyists. In the aforementioned proposal, we consider that the following essential points should appear:

  1. Definition of interest group: according to the European institutions, it identifies this activity as anyone who tries to influence the process of adopting a public decision.
  2. Definition of public official: any member of an administration or public institution that receives proposals to influence the approval of public regulations.
  3. Creation of a common and obligatory register: it must be attached to the Transparency and Good Governance Council (CTBG) to act before administrations and institutions.
  4. Scope of application: all institutions, bodies, administrations and public corporations and at all levels of the State.
  5. Transparency: publication of the public agenda with all meetings whose subject matter is decision-making.
  6. Conflict of interests and revolving doors: we propose a period of 2 years for the transition from stakeholder representation to public accountability and vice versa.
  7. Code of Conduct: included indisputably in the Register to ensure the ethical performance of the activity.
  8. Rights and obligations: of the registered interest groups and public institutions, bodies and administrations.