That possibility was highlighted by the Channel 4 Dispatches investigation into so-called 'cash for access' involving MPs Jack Straw and Sir Malcolm Rifkind, broadcast on Monday night. Speaking to the BBC, the new lobbying registrar Alison White said she expected "quite a low level" of activity when the registration system goes live next month.
In a letter to White, CIPR chief executive Alastair McCapra said: "Presumably if [MPs] were making representations on behalf of a client to ministers or civil servants, while still serving as members of the House of Commons, they would be required to register on the same basis as any consultant lobbyist? I would be grateful if you could clarify this for me.
"I would also be keen to know whether, in the course of educating the private offices of ministers about the new lobbying register, you will be communicating with parliamentary authorities to ensure that members of both Houses of Parliament are aware of the register and the activity it is intended to capture?"
He added: "When the public read about ‘lobbying’ scandals and learn that there is a statutory lobbying register, they can reasonably infer a number of things. One is that lobbyists have been caught acting corruptly. The other is that the statutory register provides them with some defence against corruption. As we know, neither is the case specifically in relation to this story.
"I therefore believe it would be in the public interest for the lobbying registrar to make a public statement each time a new ‘lobbying’ scandal breaks, to clarify whether or not any professional lobbyists have been involved; if they were, whether they were properly registered; and if not, whether their activities fall within or without the scope of the register as currently constituted."
The new statutory lobbying register is to go live on 27 March, although industry leaders have expressed concerns that significant questions remain outstanding, including the costs for lobbyists.