Staying compliant: how UK tech companies can lobby safely and effectively

Why lobbying is a hot topic in tech

The UK is undergoing a period of rapid regulatory change in the digital space, with new laws and proposals emerging across artificial intelligence, cyber security, data privacy, online safety, and consumer protection.

As the Data Use and Access Act 2025 progressed through Parliament to Royal Assent, earlier this year, there were debates in the latter stages around the issue of whether the DUA Bill should cover transparency on AI models using copyrighted works to train the models. During the passionate debates in the Commons and the Lords there were frequent references to lobbying by big tech companies. Baroness Kidron, speaking on behalf of creatives in the Lords, described the Government as "entrapped by the shiny promises of tech lobbyists".

This is not an isolated example. The Online Safety Act 2023 also attracted significant lobbying from the tech sector, as companies sought to shape the final form of the legislation. The pattern is clear: as the UK introduces and updates regulation in the digital arena, big tech firms are highly active in lobbying efforts, aiming to influence the rules that will govern their operations and the wider industry.

Tech lobbying is also expanding out of Westminster and into the UK regions. The government's commitment to AI Growth Zones and building data centres away from London means that local authorities are now trying to attract digital investment and tech companies are looking for local support to build digital infrastructure.

In the EU, the Corporate Europe Observatory, a research and campaign group, has reported that the tech industry has boosted its lobbying expenditure to record levels. Its research shows that lobby spending by the digital industry has grown by 33.6% in only two years and suggests that lobby groups are pushing for deregulation in the EU. We don't have the same detailed lobbying data in the UK, but similar trends are likely here especially around digital regulation and AI policy.

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 (or a specified equivalent position)?
• 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 tech sector, lobbying is centred on shaping regulation in the digital space, securing infrastructure investment, and influencing compliance costs under consumer and competition legislation. 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."

Guidance issued by the Information Commissioner's Office, in relation to the Freedom of Information Act 2000, states that "Lobbying is a legitimate activity that can benefit government decision-making" though cautions that transparency, as to the process of lobbying and the influence of lobbyists, is crucial. Tech 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.