Comments I.Adinolfi


Comments of Isabella Adinolfi MEP 5 Star MoVement -

EFDD Group



A preliminary remark concerns the legal instrument (interinstitutional agreement)

chosen by the Commission. A different legal act, i.e. regulation or a decision, would

have represented a better technical solution for guaranteeing a mandatory

Transparency register other than guaranteeing more legal certainty.

Art. 1. The scope of the agreement should not be restricted only to the three

Institutions, but should cover also the EU agencies and bodies as already foreseen in

the current Register (Par. 19);

Art. 2. Definitions should be modified accordingly to include EU agencies and other

bodies functionaries;

Art. 3. The formulation should include clearly all activities carried out with the objective

of directly or indirectly influencing the formulation and implementation of policy and

decision-making processes of the EU. The reference should be Par. 7 of the current

IIA. The Register should clearly cover law firms if those ones carry out lobby activities

and regardless of the duty of confidentiality.

Art. 4. It could be disputable that authorities of third countries should be exempted,

due to the fact they could carry out lobby activities.

Art. 5. The interactions that the Register covers, e.g. meetings, should be also those

occurring at lower levels (e.g. APAs, advisors, head of units. Concerning the Council,

the interactions considered should be also those occurring within Council preparatory

bodies and comitology committees. Furthermore, interaction with all the Permanent

Representations should be conditional upon registration.


Art. 6. It should be introduced a general obligation to provide accurate and updated


Art. 7. It should be introduced a reference to the frequency of the checks carried out

ex officio by the Secretariat and to the appropriateness, to this end, of the financial

and personal resources allocation.

Art. 8. There should be a clarification on the modus operandi of the Management

Board: consensus should not be interpreted as a veto power of any of the three

Institutions. In addition, there should be a mention to the fact that all decisions of the

Management Board should be effectively and immediately made available to the


Art. 9. The Secretariat should collect standardised data that are easily accessible for

users. Furthermore, the Secretariat should become a central hub concerning all data

on lobbying.

Articles 10 & 11. Ok

Article 12. The register should cover also the activities of EU agencies and bodies

(see Article 1), therefore this article should be modified accordingly.

Article 13. This article should be modified to accommodate the changes made in

Article 5 on Permanent Representations.

Article 14. The term of four years should be shortened to three.

Annex I. Independent/freelance lawyers should also be included as a category as well

as public relations firms and media consultancies.

Annex II.

I (General Information) The specific files/reports followed should be indicated.

II (Specific Information) The bandwidths of the costs and revenues should be more

precise. The estimates of the people involved in the activity should be checked, and if


needed upgraded, every 6 months. The same checks, and if needed corrections,

should apply mutatis mutandis to the estimates of costs and attributable revenues. All

these data should be updated, precise and reflecting the reality as much as possible.

Annex III.

The code of conduct of the former Register should not be limited in its scope. In

particular, letter c), d), i), j), l), m), n) of former code of conduct should be fully


Annex IV.

There should be the possibility to lodge anonymous complaints.

The decisions issued and measures adopted by the Secretariat should be effectively

and immediately made available to the public.

The review process (Par. 11) should always be concluded with the issuing of a

reasoning, even when there is no an implicit rejection.


Possible experts to be invited to the Workshop:

- Mr Olivier Hoedeman & Ms Vicky Cann Corporate Europe Observatory;

- Mr Daniel Freund Transparency International;

- Ms Sherry Perrault, Head of Lobbying Regulation with Ireland’s Standards in Public

Office Commission.


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