(VIC) Expand the Definition of 'Lobbyist' to Include Any Person, Company or Organisation Who Engages in Lobbying Activity

Author: Ophelia Davenport | Publish date: 20/10/2025

Problem Identification: 

In VIC, the current definition of ‘lobbyist’ does not capture all persons, companies or organisations that engage in lobbying activity.

Section 3.4 of the Victorian Government Professional Lobbyist Code of Conduct (the Code) has defined a lobbyist as ‘any person, company or organisation who conducts lobbying activities on behalf of a third party client.’ However it excludes in-house lobbyists, those ‘engaging in lobbying activities on their own behalf.’

This means in-house lobbyists are not required to log their activities on the Victorian Professional Register of Lobbyists. It is known the current definition does not subject an estimated 80% of lobbyists to public reporting requirements. The Human Rights Law Centre has stated lobbying activities often proceed without transparency, which could lead to lobbyists exerting disproportionate influence on policymakers without public scrutiny. They said this may undermine public confidence in the integrity of democratic processes.

Context: 

The Code itself refers to lobbying as ‘any contact with a government representative in an effort to influence government decision-making.’ When regulated, it is widely accepted as a legitimate and important part of a functioning democracy. 

The Centre for Public Integrity (CPI) identifies 2 types of lobbyists: in-house lobbyists, who lobby on behalf of their employer; and third-party lobbyists, typically from professional lobbying firms hired as consultants to advocate for clients' interests. 

The Victorian Government Professional Lobbyist Code of Conduct governs lobbying regulation in VIC. The Code outlines rules that monitor interactions between lobbyists and government officials. For transparency purposes, anyone whom the government deems a ‘lobbyist’ is required to report their activity on the publicly accessible Victorian Professional Register of Lobbyists.

The CPI has argued the lobbyist register is incomplete because the ‘overwhelming majority of people who engage in lobbying are “in-house lobbyists”, meaning they represent the interests of their employer and therefore fall outside the registration system.’ Researchers from the VIC Parliamentary Library have noted ‘lobbying registers across Australia, including Victoria’s, do not give a complete picture of lobbying activity.’ Stephen Bell at the University of Queensland estimated that 75-80% of lobbying by large Australian firms is carried out internally by dedicated government relations staff. As the CPI explained, ‘rather than retaining an external lobbyist to engage government on their behalf, most large firms prefer to engage in government relations directly.’

The Office of the Victorian Information Commissioner stated in-house lobbyists can have ‘significant influence on government decision making’, raising concerns their exclusion from the register may not align with transparency objectives. Dr. Jennifer Lacy-Nichols from the University of Melbourne has argued transparency of lobbying activities is required to ‘alert the public about undue influence in government decision making.’

Advice/Solution Identification:

The VIC Minister for Government Services should amend section 3.4 of the Victorian Government Professional Lobbyist Code of Conduct to omit all after ‘any person, company or organisation who conducts lobbying activity’ to broaden the definition of ‘lobbyist’.

The CPI has called for this. Among others, they say broadening the definition could subject all individuals engaged in lobbying to the same standards, which may help foster greater transparency and accountability.

Note: Some groups have acknowledged the potential of an administrative burden that increased reporting requirements may place on those subject to an expanded lobbyist definition. It has been noted that regulation could be appropriately scoped to ensure it does not impose an undue burden on activities, such as individuals advocating for constituency issues.

Precedent:

There is international precedent for subjecting in-house and third-party lobbyists to the same standards. Scotland, Ireland and Canada have regulations that extend to all lobbying activities.

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Public Support: 

1. Centre for Public Integrity

2. Office of the Victorian Information Commissioner 

3. Victoria Independent Broad Based Anti-Corruption Commission

   
   

News Coverage:

• The Guardian - ‘Lobbyist breaches go unsanctioned as critics call for Australia’s rules to be strengthened.’ The VIC government has acknowledged there is a need for lobbying reform after warnings from the anti-corruption commission. By: Tom McIlroy and Henry Belot | Sat 26 July 2025 - Read the article here.

• The Guardian - ‘Leading players urge Labor to tighten rules for cashed-up political lobbyists.’ Critics have expressed a desire to know the names of people who hold sponsored passes issued for lobbying at Parliament House. By: Tom McIlroy and Henry Belot | Mon 16 June 2025 - Read the article here.

Where to go to learn more: 

1. Centre for Public Integrity’s submission to the inquiry into the Lobbying Reform in Victoria (2025) - This submission recommended broadening the definition of ‘lobbyist’ to include ‘in-house lobbyists’. Read it here.

2. Parliamentary Library & Information Service research report - This research report explored the implications of VIC lobbyist definition with comparisons to other Australian states and several international jurisdictions. Read the full report here.

3. Victoria State Government, ‘Supporting transparency and integrity in lobbying’ - This 2025 consultation paper examined the current state of lobbying regulations in Australia and has explored the appropriateness of the current lobbying definition. Access it on their website here.

4. The Victorian Government Professional Lobbyist Code of Conduct - In this Code of Conduct, the rules of contact between lobbyists and government representatives are defined. View the Code of Conduct here.

5. The Independent Broad-based Anti-corruption Commission, Special report on corruption risks associated with donations and lobbying (2022) - This report offered recommendations in response to VIC’s narrow scope of lobbying regulation. Download the report here.

Human Perspective: 

Sarah, a local environmental advocate from regional Victoria, hit a wall after trying to understand why a major development project near her town was fast-tracked despite strong community opposition. Public records showed no lobbying activity related to the project. Later she discovered senior executives from the development company had met multiple times with government officials. Since the executives were in-house lobbyists, those conversations were not recorded on the public register. Sarah felt powerless. She had played by the rules by making submissions and attending consultations, yet others had shaped the outcome behind closed doors. The lack of transparency left her questioning whether her voice ever truly mattered. If all lobbying activity were subject to the same rules, Sarah and her community would at least be able to see who was influencing decisions that affected their lives. Without reform, Sarah felt like she was left in the dark and her faith in democratic processes started to erode.

To protect the anonymity of those involved, this is a fictionalised account drawn from an amalgamation of real-life stories, experiences and testimonials gathered during the research process for this brief. Any resemblance to actual individuals is purely coincidental.

Conflict of interest/acknowledgment statement: 

N/A

Support 

If your organisation would like to add your support to this paper or suggest amendments, please email Info@foreaustralia.com. 

Reference list: 

Centre for Public Integrity. (2025, July). A Seat at the Table. https://publicintegrity.org.au/wp-content/uploads/2025/07/A-Seat-at-the-Table-Embedding-Integrity-Transparency-and-Equality-into-the-Federal-Lobbying-Regime-_10.07.25.pdf

Centre for Public Integrity. (2025, February 13). Submission to consultation on reforming Victoria's lobbying regulation. https://publicintegrity.org.au/wp-content/uploads/2025/05/Victorian-DPC-Lobbying-Reform-Consultation-Submission.pdf

Drury, A. (2021). Selling Out: How powerful industries corrupt our democracy. Human Rights Law Centre. https://www.hrlc.org.au/app/uploads/2025/04/2201-Selling-Out-Our-Democracy-Report.pdf

Regulation of Lobbying Act 2015. https://www.irishstatutebook.ie/eli/2015/act/5/section/5/enacted/en/html#sec5

Lacy‐Nichols, J., Crosbie, E., Cullerton, K., & Baradar, H. (2025, July 2). Lobbying in the Shadows: A Comparative Analysis of Government Lobbyist Registers. Milbank Quarterly. https://doi.org/10.1111/1468-0009.70033

Office of the Commissioner of Lobbying of Canada. (2022, April 4). Lobbying at the federal level — At a glance. https://lobbycanada.gc.ca/en/rules/lobbying-at-the-federal-level-at-a-glance/

Office of the Victorian Information Commissioner. (2025, February 6). Submission to consultation on reforming Victoria's lobbying regulation. https://ovic.vic.gov.au/wp-content/uploads/2025/02/Submission-Department-of-Premier-and-Cabinet-Lobbying-Reform-OVIC-Submission-6-February-2025.pdf

Lobbying (Scotland) Act 2016. https://www.legislation.gov.uk/asp/2016/16/section/1

The Victorian Government Professional Lobbyist Code of Conduct. (2025, June 15). https://www.lobbyists.vic.gov.au/code-of-conduct#3-definitions

Tonkin, A. T., & Florence, E. (2024, February 1). Lobbying in Victoria. Parliamentary Library & Information Service. https://www.parliament.vic.gov.au/498956/globalassets/sections-shared/about/publications/research-papers/lobbyinginvictoria_rn_2024_.pdf#page=6