The Lobbying (Improving Government Honesty and Trust) Bill 2025 establishes a statutory Register of Lobbyists, makes it an offence for defined lobbyists to undertake lobbying without registration, and creates a set of conduct obligations for registered lobbyists and listed persons. It requires monthly publication of Ministers’ diaries, the inclusion of current and former senior Ministerial staffers in the Australian Government Directory, and gives the National Anti‑Corruption Commissioner (the Commissioner) investigative authority, including AFP referral for alleged offences.
The bill matters because it converts a largely voluntary, self‑regulatory regime into a mandatory, enforceable scheme with criminal penalties (expressed as penalty units), extends application beyond Australia, and creates significant reporting and procedural obligations (quarterly returns, statutory declarations and periodic confirmations). The regime imposes clear compliance costs on professional and inhouse lobbyists, sets new limits on post‑public‑office work for Ministers and senior advisers, and gives the Commissioner—and ultimately the Minister—strong administrative levers to control registration status.
At a Glance
What It Does
The bill defines 'lobbyist' (professional and inhouse) using activity‑ and threshold‑based tests, requires registration on an electronic Register, mandates quarterly returns specifying topics, Government representatives and clients, and makes unregistered lobbying an offence. It also prescribes standards of conduct (gifts, hospitality, truthfulness), monthly publication of Ministerial diaries and records of senior Ministerial staffers in the Government Directory.
Who It Affects
Professional lobbyists, inhouse lobbyists for entities that meet $5 million revenue or $100,000 remuneration thresholds, former Ministers and senior Government advisers (subject to 3‑year post‑separation restrictions), Ministers (diary publication) and Commonwealth departments (Directory maintenance). The Commissioner and the AFP play central enforcement roles.
Why It Matters
This creates a binding national standard where none existed, shifts previously private interactions into public records, and ties enforcement to the National Anti‑Corruption Commissioner—raising the stakes for commercial actors and ex‑public office holders. For compliance teams it introduces recurring operational obligations and new reputational risks.
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What This Bill Actually Does
The bill builds a statutory architecture for regulating lobbying. It starts by defining lobbying activity as any effort to influence government decisionmaking, then separates who counts as a lobbyist into two classes: professional lobbyists (those acting for third‑party clients) and inhouse lobbyists (employees, officers or contractors who meet time and organisational thresholds).
The inhouse test combines an activity test (8 hours/month over multiple months) with organisational size triggers (either $5 million annual revenue, $100,000 spent on relevant remuneration, or being an industry association). Certain categories—constituents, committee communications, grassroots campaigning and routine professional services—are carved out.
Registration is mandatory. Applicants (and proposed listed persons) must lodge an approved form and a statutory declaration that covers specified criminal‑history and dishonesty convictions, membership of party executive bodies, and any prior 'serious contraventions' of the Act.
Once registered, lobbyists must provide a return within five business days after each quarter listing each lobbying activity, the topic and desired outcome, which Government representatives were engaged, forms of communication, dates, and the individuals undertaking and directing the work. Professional lobbyists must also identify third‑party clients by name, ABN and address, subject to a narrowly drawn exception where disclosure would reasonably be expected to cause market speculation and the client has continuous disclosure obligations.The bill sets conduct standards: registered lobbyists must not be corrupt, dishonest, or threaten detriment; must take reasonable steps to verify information; must keep lobbying separate from political or personal activities; must notify Government representatives at the start of contact about their registered status and clients; and face limits on gifts and hospitality (only low‑value token items or in‑person consumables).
It also prevents registered lobbyists from lobbying Government representatives with whom they have a close relationship creating a sense of obligation, and bars inhouse lobbyists or listed persons from playing a substantial role in an election campaign during writs and for six months after the election unless registration is varied.A significant substantive restraint targets former public office holders: Ministers and senior Government advisers are criminally prohibited, for three years after leaving office, from lobbying for their financial advantage on matters they had official dealings with in their last three years, and from advising others to lobby on those matters. Enforcement is administered by the National Anti‑Corruption Commissioner—investigations are conducted under the National Anti‑Corruption Commission Act 2022 regime; the Commissioner can refer criminal matters to the AFP.
The Commissioner must maintain an electronic Register, publish it on the Attorney‑General’s department website, and may vary, suspend or cancel registrations; additionally, the Minister may direct registration decisions and must follow procedural notice requirements. The Act requires an expert panel review within 3–4 years and mandates inclusion of operation data in the NACC annual report.
The Five Things You Need to Know
The bill makes it an offence punishable by 100 penalty units for a defined lobbyist or inhouse lobbyist to engage in lobbying without being registered or listed.
Registered lobbyists must file a quarterly return by the fifth business day after each quarter that lists each lobbying activity, the topic and desired outcome, the Government representatives involved and, for professional lobbyists, client ABNs and addresses.
Section 12 bars Ministers and senior Government advisers, for three years after leaving office, from lobbying for financial advantage on matters they had official dealings with in their last three years in office.
Registration requires statutory declarations from the lobbyist and each proposed listed person confirming no specified recent dishonesty convictions, no imprisonment above 30 months, no political‑party executive membership, and disclosure of prior serious contraventions of the Act.
The Commissioner must publish and maintain an electronic Register on the Attorney‑General’s department website and may vary, suspend or cancel registrations; the Minister can give written directions to the Commissioner affecting registration decisions.
Section-by-Section Breakdown
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Definitions and who counts as a lobbyist
Sections 9 and 10 set the gatekeeping definitions that determine the bill’s reach. Lobbying activity is framed broadly—any activity intended to influence government decisionmaking—while a mix of activity and organisational thresholds decides who is a lobbyist. The inhouse test requires sustained time spent on lobbying and captures large entities (by revenue or remuneration) and industry associations; that design pushes compliance onto bigger private and not‑for‑profit operators while excluding occasional advisers and specific professional services.
Prohibition on unregistered lobbying
Section 11 makes unregistered lobbying by defined lobbyists an offence, listing multiple related roles (employees, contractors, officers). The provision creates a clear compliance trigger: if you meet the definition of lobbyist and are not registered or listed, you cannot lawfully undertake lobbying. The penalty is significant (100 penalty units), making registration effectively compulsory for affected actors.
Three‑year post‑separation bans for Ministers and senior advisers
Section 12 targets revolving‑door risks by criminalising certain post‑employment activities for three years after ceasing to be a Minister or senior Government adviser. The prohibition applies where the former official seeks financial advantage related to matters they had official dealings with in their last three years. It covers both direct lobbying and providing advice to assist third parties to lobby, and carries the same 100‑penalty‑unit exposure.
Register content and quarterly returns
The Commissioner must maintain an electronic Register (section 15) and include detailed data for each registered lobbyist (section 16). Quarterly returns required by section 17 demand granular activity‑level reporting: topics, desired outcomes, named Government representatives, communication forms, dates and the individuals directing and doing the work. Professional lobbyists must also identify third‑party clients and related corporate controllers, but the bill allows a narrowly defined non‑disclosure where client market‑sensitive transactions are involved and continuous disclosure obligations are in play.
Conduct obligations for registered lobbyists and listed persons
Section 13 sets principle‑based duties: avoid corrupt, dishonest or unlawful conduct; verify information; separate lobbying from political activities; disclose registered status and client names at the outset of contact; and impose low‑value limits on gifts and hospitality. It also prohibits lobbying where a close relationship creates a sense of obligation and curbs election campaign roles for inhouse lobbyists during writs and for six months after the election, unless the Commissioner varies registration.
Referral and investigation by the Commissioner
The bill creates a pathway for anyone to refer suspected contraventions to the Commissioner (section 25) and empowers the Commissioner to investigate on their own motion or in response. Investigations are carried out under the National Anti‑Corruption Commission Act 2022 framework (section 26), and the Commissioner may refer suspected criminal offences to the AFP. Those provisions integrate the lobbying regime into existing anti‑corruption investigatory tools but also import their procedural complexity.
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Explore Government in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Journalists, watchdogs and the public — they gain access to monthly Ministerial diaries and a searchable electronic Register, improving the ability to scrutinise who is influencing government decisions.
- Government representatives and departments — consistent registration and pre‑meeting disclosure reduce uncertainty about interlocutors and can make record‑keeping and conflict checks easier.
- Compliant lobbyists and firms with established compliance functions — transparency may confer reputational benefits and make ethical market positioning clearer compared with opaque competitors.
- Civil‑society organisations and advocacy groups — clearer rules and published diaries can level the playing field by exposing preferential access and making it easier to monitor influence patterns.
Who Bears the Cost
- Professional lobbyists and inhouse lobbying teams — they face new registration, quarterly reporting, statutory declaration and periodic confirmation obligations with attendant administrative costs and disclosure risks.
- Former Ministers and senior Government advisers — the three‑year post‑office restrictions narrow post‑public‑service employment options and limit advisory work on matters they previously handled.
- Commonwealth departments and Ministers’ offices — they must publish diaries monthly and ensure the Australian Government Directory tracks current and former senior Ministerial staffers, creating operational and record‑management burdens.
- The National Anti‑Corruption Commissioner and enforcement system — integrating these functions into NACC investigations will require resourcing to assess and pursue a high volume of compliance matters and referrals.
- Commercial clients of professional lobbyists — clients may face disclosure of sensitive commercial information (ABNs, addresses, related entities) in quarterly returns unless narrowly excepted.
Key Issues
The Core Tension
The bill trades off transparency and public accountability against legitimate confidentiality, commercial interests and the post‑employment rights of public officials: increasing disclosure and imposing post‑separation restrictions reduces opportunities for undue influence but also constrains private commercial activity and risks chilling legitimate advocacy and advice.
Several practical and legal tensions are embedded in the bill. First, the definition of lobbying is deliberately broad (any activity intended to influence), but the statutory exclusions (constituents, committee communications, grassroots campaigning, responses to requests, routine professional services) will produce boundary disputes in practice: compliance teams will need to make judgements about intent and whether communications are 'for the purpose of influencing' a decision.
Second, the inhouse lobbyist thresholds shift responsibility to entities to monitor staff time and organisational financial metrics; small teams within large organisations may be swept in unexpectedly, and disputes may arise about retrospective application of the time and financial tests.
Disclosure rules introduce another trade‑off: the quarterly returns demand detailed, activity‑level data and client identifiers, which enhances transparency but risks revealing commercially sensitive strategies or prematurely exposing pending transactions. The bill offers a narrow carve‑out tied to continuous disclosure obligations, but that exception will not cover many private deals.
Enforcement channels raise questions about politicisation and proportionality: the Minister can direct the Commissioner on registration decisions (with notice requirements), and the Commissioner conducts investigations under NACC powers—combining administrative discretion with criminal exposure risks. Finally, the Act binds the Crown but shields it from pecuniary penalties or prosecution, creating an asymmetry in enforcement that could complicate investigations involving Crown entities or ADF members.
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