The first time there is a lobbying scandal that involves a company or individual included on the statutory register, the media will generate considerable pressure for the culprit to be punished. With no statutory authority to insist on a minimum standard of behaviour, and with no scale of sanctions available, the authorities will be powerless to act. The result will be a collapse of confidence in the new system.
In the past, the APPC could claim that it fulfilled this policing role effectively and impartially, but in July the APPC abandoned its commitment to be exclusively an independent regulatory body.
It is perfectly legitimate for the members of the APPC to collectively decide that they wish their association to be a commercial business-promoting body, but they cannot at the same time expect unqualified respect as an independent regulatory body. The two roles are incompatible.
Many had hoped that the new UK Public Affairs Council would be able to shore up the principle of statutory registration through more rigorous professional self-regulation. But UK PAC only oversees the policing of its codes of practice by its member organisations - the APPC, CIPR and PRCA.
This situation is unsustainable, but there is a way forward. If the Government has the vision to introduce a statutory code of practice alongside the register, future scandal and controversy could be avoided - to the benefit of confidence in our democratic institutions and the reputation of political consultancy.