Our proposal for regulation

The Bureau of the Congress of Deputies defines an interest group 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 not yet a national law by consensus, but only some regulations at an autonomous level within the agenda or a transparency law.

For this reason, APRI works as an association of lobbyists in dialogue with the different parliamentary groups to push forward 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 and in force since 2nd April 2019. The document establishes the obligation of the deputies to make public their institutional agenda in the Transparency Portal of the Congress.
  • European Union Transparency register: https://ec.europa.eu/info/about-european-commission/service-standards-and-principles/transparency/transparency-register_en
  • Register of interest groups of the National Commission on Markets and Competition (CNMC): voluntary and in force since March 2016. 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 in the definitive search of the efficiency of the professional lobbying activity, at APRI we have written a Proposal of Regulation to approach a directive in the sector whose main objectives are:

  1. Guaranteeing transparency in political and legislative decision-making
  2. Strengthening the legal certainty of standards and their development processes
  3. Strengthening the legitimacy of institutional representatives in their executive or legislative work
  4. Improving regulatory effectiveness
  5. Promoting accountability
  6. Enhancing citizen participation in the country’s political life


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

  1. Definition of interest group: according to the European institutions, it identifies by its activity anyone who tries to influence the process of adopting a public decision.
  2. Definition of public official: any member of the 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.