The Fund supports networks of state health policy decision makers to help identify, inspire, and inform policy leaders.
The Milbank Memorial Fund supports two state leadership programs for legislative and executive branch state government officials committed to improving population health.
The Fund identifies and shares policy ideas and analysis to advance state health leadership, strong primary care, and sustainable health care costs.
Keep up with news and updates from the Milbank Memorial Fund. And read the latest blogs from our thought leaders, including Fund President Christopher F. Koller.
The Fund publishes The Milbank Quarterly, as well as reports, issues briefs, and case studies on topics important to health policy leaders.
The Milbank Memorial Fund is is a foundation that works to improve population health and health equity.
July 14, 2025
Quarterly Article
Jennifer Lacy-Nichols
Hedeeyeh Baradar
Eric Crosbie
Katherine Cullerton
June 2025
March 2024
Back to The Milbank Quarterly
Policy Points:
Context: Information about lobbying is crucial to alert the public about undue influence in government decision making. Yet, government disclosures of lobbying activities are rare internationally and vary considerably in their completeness and accessibility. Building on a framework to measure lobbying transparency, this study benchmarked national government disclosures to understand what information was shared and to develop recommendations to strengthen political transparency.
Methods: To identify lobbyist registers, we reviewed four international surveys that assessed lobbying transparency in 128 countries. For each country with an online register, we assessed the 50 indicators in the Framework for Comprehensive and Accessible Lobbying (FOCAL), generating an overall score for each government. To highlight the importance of transparency for public health, we compared the visibility of tobacco industry lobbying across all registers by documenting the information provided about two prominent tobacco companies: Philip Morris International and British American Tobacco.
Findings: We identified 28 countries with online lobbyist registers, all from upper or upper-middle income countries. No country fulfilled all 50 indicators in the FOCAL. The category of “scope” had the highest scores across countries, whereas the “revolving door” and “financial” categories had the lowest scores. We found evidence of lobbying by Philip Morris International, British American Tobacco, or one of their subsidiaries in 14 of the 28 countries with online lobbyist registers.
Conclusions: Our study empirically demonstrates the hidden nature of lobbying internationally. In the case of industries whose interests conflict with public health, poor lobbying transparency presents a risk that vested interests may undermine public health policymaking without anyone knowing. To ensure that health harming industry interests cannot escape scrutiny, public health advocates should support efforts to strengthen political transparency measures.