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September 2025 (Volume 103)
Quarterly Article
Jennifer Lacy-Nichols
Hedeeyeh Baradar
Eric Crosbie
Katherine Cullerton
June 2026
Lobbying in the Shadows: A Comparative Analysis of Government Lobbyist Registers
June 2025
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.