A recurring theme on Lobbyfacts.eu is the absurd data that some organisations post, especially when it comes to declarations of annual lobbying expenditure. For us, the amount of money spent on lobbying is a really important indicator of lobbying size and likely influence, and so it is important that all registrants post accurate figures. We often highlight this when it comes to the major corporate players, but unfortunately, the NGO sector is not immune to the problems of either under-reporting or over-reporting financial data.
According to the data from the official EU lobby register, as ranked by Lobbyfacts, the top-spending NGO lobbyist is Ehkäisevä päihdetyö EHYT ry which records a wopping great lobby expenditure of €57,517,000 in 2014. Bizarrely this figure is nearly 10 times greater than the NGO’s total recorded budget and it records only 1.75 full-time equivalent lobbyists. EHYT is “a preventive substance abuse work organisation that operates in all of Finland” which makes it very hard to believe that it is really the biggest lobbying NGO of the EU institutions. In fact, this huge recorded lobby expenditure makes it the fifth largest declarer of lobby costs in the whole register. It does not take much effort to work out that this, and many other entries in this ranking are wrong. EHYT only joined the register in October 2015, so it is very concerning that the checks which are apparently carried out by the lobby register authorities on new entries has not queried this.
The US-based Internet Society is ranked as the EU’s second highest spending NGO lobbyist, declaring €46,800,115. That makes it more than ten times bigger than the highest spending US company recorded in the register, namely Microsoft with €4,500,000 - €4,749,000 spent in the year to June 2014. The Internet Society certainly seems to be active at the EU level: it has a Brussels office and it is a member of a couple of Commission expert groups and other forums. But it only records the full-time equivalent of 1.5 lobbyists and one European Parliament pass-holder. Curiously, we could not find it on Opensecrets, the US equivalent of LobbyFacts. This NGO only registered with the EU lobby register on 5 November 2015, and it seems clear that this entry is erroneous, especially considering its annual budget is recorded as €47,862,162.
Number 3 on the Lobbyfacts list is the International Association for the Evaluation of Educational Achievement which is based in the Netherlands and declares the equivalent of 140 full-time lobbyists. Its lobby budget and organisational budget for 2013 are identical at €15,768,000 but yet its mission is to “conduct large-scale comparative studies of educational achievement and other aspects of education”, which does not sound as if it would have a major lobby component.
|Organisation Name||Country head office||Lobbying costs declared|
|1||Ehkäisevä päihdetyö EHYT ry||Finland||57,517,000 €|
|2||Internet Society||United States||46,800,115 €|
|3||International Association for the Evaluation of Educational Achievement||Netherlands||15,768,000 €|
|4||The Smile of the Child||Greece||12,957,800 €|
|5||European Athletic Association (European Athletics)||Switzerland||> 10,000,000 €|
|6||GÉANT Association||Netherlands||> 10,000,000 €|
|7||Gruppo di Volontariato Civile||Italy||> 10,000,000 €|
|8||Teach For All||United Kingdom||> 10,000,000 €|
|9||European Financial Reporting Advisory Group||Belgium||5,250,000 - 5,499,999 €|
|10||Fundatia "Alaturi de Voi" Romania||Romania||4,877,269 €|
|11||ClientEarth||United Kingdom||4,813,709 €|
|12||Plan International España||Spain||4,745,774 €|
|13||Practical Action||United Kingdom||4,522,736 €|
|14||Stiftung Mercator||Germany||4,250,000 - 4,499,999 €|
|15||AVTO-MOTO ZVEZA SLOVENIJE||Slovenia||4,000,000 - 4,249,999 €|
Plan International España is 12th on the list of Brussels’ biggest NGO lobbyists, according to the Lobbyfacts rankings with an expenditure of €4,745,774; this would mean that in 2013-2014 according to its own register data, it spent 38 per cent of its total budget on EU lobbying.
Meanwhile, the Plan International EU office only declares €10,000-€24,999 for 2013-2014, although it also records a Brussels office, 4.5 full-time equivalent lobbyists and two European parliamentary pass-holders. Taken together, neither of these two Plan International registrations make much sense, with the former likely over-reporting and the latter likely under-reporting.
So, if our analysis is right, there is an absurdly high error rate in the lobby register, but why has this happened? There are several possible explanations.
Some keen to be seen to be as transparent as possible, may simply adopt their annual budget figure for their lobbying budget figure “to be on the safe side”, or they overstate their costs because of confusion over what counts as genuine lobbying. Arguably there is a grey area around whether some NGO campaigning should count as EU lobbying, and perhaps the official register guidelines could be made clearer in this regard.
Others, especially those in receipt of EU funds, may (wrongly) think that receiving such a grant requires them to declare those funds as lobby costs, or even that they cannot receive a grant at all without registering. When registering, NGOs are asked to declare any EU funds received as part of their overall budget disclosure, but many of these grants are likely to have no link with lobbying, and thus should not be counted towards actual lobby costs. Commission DGs should clarify this with grant recipients.
Finally, arguably, some organisations which are national members of international NGOs should provide a combined entry coordinated by a central office, rather than multiple ones. The official EU lobby register guidelines say: “To avoid multiple entries and reduce the administrative burden, organisations registered in or operating in more than one country (e.g. multinationals), should register once only. Registering generally falls to the branch or office dealing with the multinational’s EU affairs (usually based in Belgium).” This 'single entry principle' applies to NGOs too, like Plan International.
We have also run the names of the top 25 lobby-spending NGOs through the integritywatch.eu database to see which organisations have held lobby meetings with commissioners, cabinet members or directors-general. From 1 December 2014 to 3 July 2015, only seven of these 25 NGOs had held such lobby meetings and four of these had only had one meeting each. Is it likely that NGOs will have multi-million euro lobby budgets but not meet with the top members of the Commission? We think not. Integritywatch.eu shows that, in the list of organisations having the greatest number of high-level lobby meetings with the Commission between December and July, three NGOs (WWF, Greenpeace, and Climate Action Network) feature; yet they do not appear on the LobbyFacts list of top NGO lobby spenders. This can be seen as a further indication that the list of biggest NGO spenders on lobbying, as recorded by the EU lobby register, is flawed.
All data correct as of 11 November 2015.