Comments I.Adinolfi

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