Is lobbying within the UK defence sector regulated?

The defence dividend

Back in February 2025 the Prime Minister promised to boost defence spending to 2.5% of GDP from April 2027, aiming for 3% in the next Parliament. The press release told us the pledge represents the biggest investment in Defence Sector spending since the Cold War, addressing global instability like Russian actions in Ukraine, rapid tech changes and climate impacts.

Fast forward to June 2025 and we see the Prime Minister making a commitment at the NATO summit to allocate 5% of GDP to national security by 2035. This breaks down to 3.5% for core defence and 1.5% for resilience and security. The Government assures us this will make the UK safer and create new defence jobs nationwide. This was confirmed in the National Security Strategy 2025, highlighting the “defence dividend” for the UK.

The defence dividend is set to boost research and development, spark new capabilities and technologies and foster international collaboration. The National Security Strategy 2025 emphasises the need for speed to achieve these goals, supported by changes from the Procurement Act 2023, which we've previously written about.

In the EU, the euobserver has reported a surge in lobbying on defence and increased budgets for major European defence companies. While the UK lacks detailed lobbying data, similar trends are likely here given the rise in defence spending and new industrial strategy.

How is lobbying regulated in the UK?

Lobbying plays a vital role in ensuring decision-makers are informed by diverse perspectives. When conducted properly, it contributes to shaping effective laws, policies, contracts and grants. However, improper lobbying can lead to significant issues. Here’s a clear, friendly guide to help you navigate this process.

First, the headline: most lobbying in the UK is allowed. However, “consultant lobbying” is regulated under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (the Act), and non-compliance can result in civil or criminal liability.

What counts as “consultant lobbying”?

Think of it like this. If you or your organisation are VAT‑registered and you’re paid to speak to a Government Minister or a Permanent Secretary for a third‑party client, that’s consultant lobbying. It covers efforts to influence policy, legislation and big Government decisions about contracts, grants, licences or other official actions. 

Two key duties kick in if you meet this definition: you must register with the Office of the Registrar of Consultant Lobbyists (ORCL) before you lobby, and you must file quarterly client returns. The public can view the register. No registration, no lobbying.

There’s helpful nuance. Consultant lobbying only happens if it’s in the course of a business, for payment and by a VAT‑registered person. If any of those pieces are missing, you’re likely outside the regime.

Do you need to register?

Ask yourself three simple questions:

• Are you VAT‑registered?
• Are you paid to communicate, personally, with a Minister or Permanent Secretary?
• Are you doing this on behalf of someone else?

If you answered “yes” to all three, you probably need to register and report.

What if you’re in‑house?

Good news. If you’re lobbying for a business that carries out consultant lobbying, and you are an employee, you’re generally outside ORCL’s scope and you don’t need to register personally. The Act also says an individual isn’t a consultant lobbyist just because they communicate as an employee in the course of a business carried on by their employer. In‑house lobbyists can choose to join voluntary industry registers for transparency, but that is optional. 

Three quick pointers:

• If your company’s main business is consultant lobbying, the company registers and employees don’t
• If your company carries on a business which consists of mainly non-lobbying activities and you lobby for your own company, no registration is needed
• If you’re a contractor or a non‑executive director lobbying for the company, you may need to register in your own right.

The Foreign Influence Registration Scheme (FIRS)

Here’s the simple rule. If a foreign power or foreign state-controlled organisation instructs you to carry out political influence activities in the UK, you must register with FIRS. There’s a separate track for “specified” foreign powers or their controlled bodies for certain activities (currently Russia and Iran). If any foreign state is in the brief, stop and check FIRS.

Other rules you shouldn’t ignore

• Bribery Act 2010. Offering advantages to induce or reward improper performance is a crime. Companies are strictly liable for bribes by “associated persons” unless they had adequate procedures
• Companies Act 2006. There are controls on political donations and political expenditure by companies.

If you’re a director, keep your duties front of mind: exercise independent judgment, avoid conflicts, don’t accept third‑party benefits and disclose interests. When lobbying for your company, act within its constitution and promote its long‑term success, considering stakeholders, people, community and the environment. 

Voluntary registers and codes

You can boost trust by joining voluntary schemes. The Public Relations and Communications Association (PRCA) keeps a voluntary Professional Lobbying Register and published a Code of Conduct and Code for Professional Lobbying in September 2025. The Chartered Institute of Public Relations (CIPR) runs the UK Lobbying Register, which is open and free.

How to lobby well (and safely)

Be clear on who you are, who you represent, and what you’re asking for. Keep records of meetings, topics and any support you receive. File your ORCL returns on time if you’re registered. Stay away from gifts or favours that could be seen as inducements. If something would look bad on the front page, don’t do it. 

Your quick checklist

• Are you being paid to contact a Minister or Permanent Secretary for a client? Register with ORCL and report quarterly
• Are you an employee lobbying for your own organisation? Registration is generally not needed, but consider including yourself on a voluntary industry body register for the purposes of transparency
• Is a foreign state instructing the activity? Check and register under FIRS if required
• Is your business making political donations or spend? Check the Companies Act rules
• Are you offering or receiving anything of value? Test it against the Bribery Act.

Our insights

In the UK defence sector, lobbying plays a pivotal role in shaping policies that ensure national security and innovation. When conducted transparently, it supports democratic governance by allowing informed voices to contribute to decision-making.

This principle was upheld in 2015 by the Court of Appeal, when Lord Justice Jackson in the case of Peter Cruddas v Jonathan Calvert, Heidi Blake, Times Newspapers Ltd [2015] EWCA Civ 171, stated that "…lobbying by special interest groups is beneficial and contributes to good governance, provided that it is open and transparent. I would add that it is an important element of democratic government that the voices of all who are affected by particular policies or who have relevant specialist knowledge should be heard."

Defence businesses engaging in lobbying, whether directly or through consultant lobbyists, must operate within the UK's legal and regulatory framework to maintain integrity and trust.

Do you want to know more about the regulation of lobbying in the UK?

Simply reach out to Stephen Anderson or Sheilah Mackie.