Transparency on Lobbying Activities

The High Authority for Transparency in Public Life commits to ensuring greater transparency on lobbying activities, notably by facilitating exploitation and enrichment of its own registry by citizens and civil society organisations, and enabling increased access to and use of asset and interest declarations already published in an .XML format. In addition, the High Authority will launch its first control strategy on lobbyists, to ensure compliance with registration obligations [OGP 20,21].

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This commitment is specific as it focuses on a sufficiently narrow policy area: the role of the High Authority for Transparency in Public Life (HATVP) in controlling lobbying activities. The anti-corruption mechanism concerned is the registry of lobbying activities. The commitment also states that it is connected to commitment 20 in the French OGP Action Plan 2018-2020, “Ensuring greater transparency in the activities of special-interest representatives”, and commitment 21, “Improving access to public information on elected representatives and public officials”.[1]

[1] OGP, France National Action Plan 2018-2020, pp.56-59,


The commitment identifies three actions as part of the the French OGP Action Plan 2018-2020.

Last updated: 22 October 2022
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In 2016, the Sapin II Act[1] mentioned creating a digital data repository on special-interest representatives, and it became mandatory by law in 2017 for special-interest representatives to register.[2] The commitment states that it is connected to commitment 20 in the French OGP Action Plan 2018-2020, “Ensuring greater transparency in representatives of special-interest activities”, and 21, “Improving access to public information on elected representatives and public officials”.[3]

1.1  Greater transparency in lobbying activities, by facilitating exploitation and enrichment of its registry by citizens and CSOs:

a) Organising one or more workshops to consult civil society in discussions on criteria for making the data repository available and its enrichment.

The HATVP organised a workshop in May 2018 with citizens, developers and journalists, on the openness and use of data from the public register of lobbyists.[4] This was part of the Open State Forum organised by the French Inter-ministerial Directorate for Digital Affairs – with the participation of Transparency International EU.[5]
b)     Opening the repository’s source code.



The source code for the repository of information on special-interest representatives is published on GitLab.[6]

c)     Publishing, in an open and easily reusable format, data from the repository of information on representatives. Fulfilled

The digital repositories can be downloaded in several formats (JSON, CSV, XLSX). In addition, the website provides basic visualisation of aggregated data.[7]

d)     Publishing, in an open and easily reusable format, the list of public officials regarding whom a communication may constitute an action of representation of interests.



An exhaustive list in HTML format indicates public officials with whom communication may constitute an act of special-interest representation. This is readily available on the “how to declare section” of the HATVP website.[8] In addition, there is a precise list of roles for which the government decides whether communication falls in this category, available in XLSX format.[9]

1.2  To increase access and reuse of the content of asset and interest declarations that are already published in an .XML format.

a)     accompanying publication with production of data visualisation and analyses



There is a basic animated dashboard with data visualisation on the landing page of the registry, and a more detailed one in the statistics section.[10] There is also a webpage dedicated to analysing the data and presenting lobbying activities.[11] Recent HATVP publications have been accompanied by data visualisations and analyses, although very basic in some cases. In its 2020 annual report, the HATVP provided numerous infographics, data visualisations and analyses.[12]

b)     Widening the choice of exportable formats by also publishing declarations in CSV format Fulfilled

The list of declarations can be downloaded in CSV format.[13]

1.3  To launch its first control strategy on lobbyists to ensure compliance with registration obligations.



The HATVP is mandated by law[14] to control lobbyists and ensure compliance with registration. It carries out three types of checks on special-interest representatives, as part of its overall control strategy:

–   Control of non-registered special-interest representatives. This involves checking that representatives who meet the legally defined criteria are registered.

–   Control of annual activity declarations. This is a substantive control to verify the accuracy and completeness of the information declared.

–   Control of professional ethical obligations, in the event of a suspected breach.

Between 2019 and July 2021, the High Authority launched 180 controls on non-registered persons, 117 controls on the annual activity declarations and two controls relating to ethical obligations. Of these checks, 145 had been completed by 1 July 2021. In 2020, the HATPV carried out 77 checks, 51 for non-registrants and 26 annual activity declarations.[15]

The OGP evaluation report assessed the progress as “substantial” for OGP commitments 20 and 21 in the 2018-2020 evaluation report.[16] Civil society actors such as Transparency International France and Anticor acknowledge the significant step achieved with this registry, despite major limitations that prevent it from fulfilling its goals.

Overall, this commitment is considered fulfilled.


Challenges to effective commitment implementation
The 2020 OGP evaluation identified limitations in the Sapin II legal framework. Lobbyists need to update the registry only once a year; some organisations, such as religious associations or local elected associations, do not need to register; communications initiated by public officials need not be registered, and public officials do not have to report their meetings with special-interest representatives. As a result, the registry is not exhaustive. Although registration is mandatory, it is difficult to assess whether lobbyists declare all their activities accurately. The data provided should also be more granular, including the names of public officials lobbyists meet with, and the exact topics they cover.[17]


  • Improve the granularity of the activity registry by providing more details for each declaration. In particular, more information should be required on who is met, including names and detail on the reason for the meeting. In addition, following GRECO’s recommendation, “persons with top executive functions [should] be required to disclose regularly details of the lobbyists they meet and the topics discussed; all lobbyists who enter into contact with public officials (in particular, persons with top executive functions), regardless of whether they initiated the contacts, [should] be required to register on the register of lobbyists.”
  • Increase the scope of the register on declarations of interests by increasing mandatory compliance to a broader range of public officials – for instance, members of ministers’ offices. The more lobbying activities are documented, the more civil society will be able to hold public officials accountable.
  • Provide power of administrative sanctions to the HATVP. It is crucial that failure to comply, results in fast and substantial fines. The existing penal sanction is too heavy to be triggered for smaller omissions.


[1] French Republic, LAW No. 2016-1691 of 9 December 2016 relating to transparency, the fight against corruption and the modernisation of economic life (1),

[2] OGP, Transparency of Interest Representatives (FR0049),

[3] OGP, France National Action Plan 2018-2020, pp.56-59

[4] HATVP, Back to the 2nd State Open Forum on the Directory of Interest Representatives,

[5] Etalab Forum, State Open Forum #2 – Shedding light on the data of the directory of interest representatives,

[6] GitLab, AGORA,

[7] HATVP, Open Data,

[8] HATVP, How to declare,

[9] HATVP, List of jobs to be decided by the government,

[10] HATVP, The directory,

[11] HATVP, Lobbying,

[12] HATVP, Activity report 2020,

[13] HATVP, Directory of interest representatives: Open data in CSV format,

[14] Article 18-6 of LAW No. 2013-907 of 11 October 2013 relating to the transparency of public life (1),

[15] HATVP, Activity report 2020, p.128,

[16] OGP, France Transitional Results Report 2018-2020,

[17] OGP, France Transitional Results Report 2018-2020,

[18] GRECO, Compliance Report 5th Round, Recommendation vi,