The UK lobbying industry is waiting with bated breath for the constitutional reform minister Mark Harper to reveal his plans to introduce a statutory register.
The decision will follow a period of intense consultation with the industry, with Harper said to have felt 'besieged' by differing views on the form that legislation should take.
Looking at how other countries tackle the dual issues of registration and regulation only muddies the picture. With a myriad of national systems to regulate lobbying, there is no single, dominant format.
From the intensely complicated and rule-bound statutory system operated in the US to the voluntary approach of the EU's scheme, the wide range of existing options all have supporters in the UK.
While it is not quite viewed as lobbying's Wild West, the UK system is currently far more heavily based on a spirit of self-regulation and responsibility than in countries such as the US and Canada.
Many have serious concerns that a blunt US-style approach would not be appropriate for the UK.
However, it is widely expected the UK Government will shift to some form of statutory register, although just how draconian it will be remains to be seen. As does the controversial issue of whether to exclude in-house lobbyists - something that has been common law in Australia since 2008.
Over the following pages, PRWeek looks at some of the notable systems for lobbying regulation around the globe and whether there are lessons the UK should heed.
HOW I SEE IT - JANE WILSON, CEO, CIPR
The CIPR has consistently made the point that any register should support self-regulation, which is far less expensive and burdensome for both the industry and the taxpayer.
The CIPR sees lobbying as an integral part of the democratic process. We therefore support the Government's desire to avoid introducing obstacles or burdens to those who engage in lobbying.
It's not necessarily appropriate to directly compare the UK system of governing lobbying with other systems, such as the US. The American system has developed in a different way from the UK - it's like comparing apples and oranges.
There can be no doubt that self-regulation is the right model for the UK - bodies such as the CIPR, the PRCA and the APPC provide active links between ethics and professional standards that are enhanced through structures of accountability.
The 1988 Lobbyists Registration Act established a statutory register, which was backed up by the 2008 Lobbying Act. Lobbyists must file a monthly return if they communicate with ministers or senior officials, which is posted online. A key way in which the Canadian system differs from the UK is that the people doing the lobbying have to register the subject of discussions in meetings held with politicians and officials, rather than vice versa. Ministers and senior officials are prohibited from moving into lobbying for five years after leaving government or the civil service.
Does it work?
In the UK, there is much criticism of the Canadian register, which forces many lobbying firms to employ people whose full-time jobs are to file the required information on government meetings to the commissioner. APCO vice-chairman, public affairs, Europe, Michael Burrell says: 'It wouldn't be a brilliant idea to introduce such a complicated system.'
THE EU (BRUSSELS)
The European Parliament and the European Commission now have a joint voluntary Transparency Register, which includes a code of conduct and is operated by a joint secretariat made up of officials from both institutions. Lobbyists are required to fill in the register annually, which is similar in breadth to the APPC register. As of January 2012, 3,287 lobbyists had registered. The register is very broad and encompasses consultancies and in-house practitioners, NGOs, trade associations and law firms.
Does it work?
One of the benefits of the system is that registering and signing the code of conduct allows lobbyists to get a parliamentary pass. This system is generally well liked by UK consultants, with APCO Worldwide senior counsel Lionel Zetter explaining: 'It's a stick and carrot system. If you sign up for a register, you get a pass. That's a strong incentive for people to accept a voluntary code.'
THE UNITED STATES
1995's Lobbying Disclosures Act enforces what is widely viewed as the most rule-bound and complicated system in the world. Covering both in-house lobbyists and third parties, the Act requires quarterly registration and calls on agencies to reveal the total income from a client, while in-house lobbyists must estimate their company's total lobbying expenses. The US has 12,655 registered lobbyists that actively lobbied in 2011.
Does it work?
This is a high-cost system, and there is generally little appetite for regulation on such a scale in the UK, because of its relatively small size. 'The US tends to be a more rule-based country,' says APCO's Burrell. 'Meanwhile, the UK has tended to work best in a spirit of peer pressure.' However, College Public Policy managing partner Warwick Smith points out that underneath the complexity, the US system makes a degree of sense.
The German Bundestag is currently the only house of parliament in the EU with specific statutory regulation of lobbying, although it is 'light touch' and not supported by law. According to the Bundestag, Germany had 2,094 organisations registered to lobby at the Bundestag or Federal Government in May 2012. The register is updated annually and published in the federal gazette. It only covers groups wishing to defend their interests before the Bundestag or Federal Government. It does not cover lobbyists seeking to influence either ministers or civil servants at the pre-parliamentary stage, and this aspect of lobbying is largely unregulated.
Does it work?
The PRCA's chief executive Francis Ingham says of the German system: 'It fails to include all acts of lobbying, which would again exempt many public affairs practitioners. Further, we believe no lobbyists should be issued with a parliamentary pass even after registration, which is a condition of our current code of conduct.'
Australia's Lobbying Code of Conduct operates a relatively light-touch statutory register for consultants alone, to which 607 lobbyists from 280 organisations are currently registered. Lobbyists are required to update the register on a quarterly basis, only providing information on employees and clients. The register is published on the prime minister's website. Registration only applies to lobbyists who are lobbying on behalf of third parties, not those who are in-house.
Does it work?
The PRCA's Ingham says that the Australian model would not be suitable for Britain because it suffers from the same problem as the UK Government's current proposals: 'Its scope does not include powerful in-house lobbyists.' However, Peter Bingle Consulting founder Peter Bingle has suggested that the Australian system seems most sensible: 'Self-regulation may be dead as a concept, but if we are to be regulated it needs to be as light touch as possible.'