The Regulation of Lobbying Act 2015 sets out arrangements for bringing transparency to lobbying activities through a web-based register.
The Act does apply to lobbying activities which take place within the State even though the lobbyist is based abroad. Foreign lobbyists who run a lobbying campaign aimed at Irish officials within the State cannot assume that their activities are exempt from the Act.
As regards lobbying activities which take place outside of the State, in line with the objectives of the Act, I would hope that a person or organisation who is based outside the State and is lobbying an Irish Designated Public Official outside the State would register such communications on the new web-based register from 1 September next. However, they would not legally be obliged to do so as there are practical and legal difficulties in terms of the extra-territorial application and enforcement of Irish law. Notwithstanding the issues in relation to the extra-territorial application and enforcement of the Act, I would expect such communications to be registered as each person or organisation lobbying would need to take into account reputational issues if they fail to register relevant lobbying communications with Irish designated public officials.
I have ensured in the legislation that there will be a review of the operation of the Act one year after commencement. I intend to keep this aspect of the legislation under review during that period including any need for appropriate protocols for designated public officials when operating abroad.