Transparency in EU Lobbying & the Role of Associations

The European Union is unique among political systems in that it is built as a governance model rather than a traditional government.

In a national administration, expertise is largely internalised within ministries, agencies and thousands of civil servants. The EU institutions, by contrast, are designed to be lean and to draw on knowledge from civil society, businesses, trade unions, NGOs and academia. The European Commission, responsible for proposing legislation for a Union of 450 million citizens, employs around 32,000 officials and contract staff¹. For comparison, the city of Rome alone employs roughly the same number of municipal workers. The magnitude of EU responsibilities—from agriculture to digital markets, from trade to climate—cannot be managed without systematic input from external actors. This makes lobbying a structural component of EU decision-making, rather than a marginal or optional activity.

Because lobbying is a necessary element of governance, transparency becomes a key safeguard. Citizens need to know who seeks to influence policies, what interests are represented, and with what resources. The EU Transparency Register was created to address this need. It records organisations and individuals engaging with the Commission, the Parliament and, on a more voluntary basis, the Council. Registered actors must declare their objectives, clients or members, and financial resources. They must also follow a code of conduct.

The scale of lobbying in Brussels is significant. Estimates suggest there are about 29,000 lobbyists active around the EU institutions². Transparency International and the European Court of Auditors have pointed to gaps in oversight: not all actors are registered, and not all meetings are consistently logged. Around one third of NGO funding remains insufficiently documented, and a number of Members of the European Parliament fail to declare lobby meetings or record them in a way that makes scrutiny possible³. These shortcomings illustrate the complexity of ensuring transparency in a system where thousands of interests converge.

Associations play a central role in this framework. By pooling resources from multiple companies or stakeholders, they provide structured input to institutions and ensure that positions are coordinated and made transparent. Their role is particularly visible in sectors that cut across borders, such as food, energy or digital. Compliance with the Transparency Register and related rules requires professional management: data must be kept accurate, financial declarations updated annually, and meetings linked to relevant legislative files. The diversity of obligations between institutions—mandatory for the Commission and Parliament, partly voluntary for the Council—adds to the complexity. This makes it necessary for associations to rely on specialised staff or advisors who can manage these requirements.

The European Commission has removed contact details—such as email addresses and phone numbers—of lower-level policy officers from the publicly accessible EU Who‑is‑Who directory, preserving only information for heads of unit and above⁴. This step, framed as a protection against undue pressure, has been criticised by public affairs professionals as a setback for transparency. At the same time, new procedural requirements introduced in 2024 in the European Parliament—requiring all lobbyists to be registered before accessing the institution—may be more burdensome for civil society representatives than effective in enhancing transparency.

In conclusion, lobbying in the EU is not an anomaly but the direct consequence of the governance model chosen for the Union. With a comparatively small administrative apparatus, the institutions cannot rely solely on internal expertise. They depend on structured input from external actors, and this reliance makes transparency indispensable. Associations and professional representatives serve as channels to organise, disclose and transmit such input. The system’s credibility rests on two pillars: that stakeholders make their interests fully visible, and that institutions acknowledge their reliance on civil society and keep the channels of participation open.

References

1. European Commission – HR Key Figures 2025

2. Reuters, “EU auditors say lobbyists can easily slip under bloc’s radar”, 16 April 2024.

3. Transparency International EU – Lobby transparency briefing, 2024. 4. Politico Europe, “EU Who’s Who directory unlisted”, 2023.