This chapter examines how the Dominican Republic could strengthen transparency and integrity in lobbying and influence activities aimed at shaping public decision-making. It outlines key elements of a coherent lobbying regulatory framework, including clear definitions, transparency requirements, and complementary disclosure tools such as lobbying registers, open agendas and decision-making footprints. The chapter also explores how integrity standards for both public officials and lobbyists can be developed to mitigate undue influence, alongside incentives to promote responsible engagement by companies and business associations. Finally, it assesses institutional, enforcement and governance arrangements needed to ensure effective implementation, including independent oversight, proportionate sanctions, and stakeholder engagement in the design, operation and periodic review of the framework.
OECD Integrity Review of the Dominican Republic
8. Strengthening transparency and integrity in lobbying and influence activities
Copy link to 8. Strengthening transparency and integrity in lobbying and influence activitiesAbstract
8.1. Introduction
Copy link to 8.1. IntroductionPublic policies are the main ‘product’ people receive, observe and evaluate from their governments. When designing and implementing these policies, governments need to acknowledge the existence of diverse interest groups and consider the costs and benefits for these groups. As such, a wide range of stakeholders should have a fair and equitable opportunity to contribute to public decision-making (OECD, 2017[1]; OECD, 2010[2]).
One way in which stakeholders may seek to contribute to public decision-making is through what is commonly referred to as “lobbying” or “interest representation”, namely communications between lobbyists and public officials aimed at influencing public decision-making processes. These practices, when carried out within a clear, transparent and integrity-based framework, are a necessary component of democratic life and an essential part of the public policy making process. They contribute valuable expertise and critical insights that help governments take more informed public decisions, design better public policies, adopt more proportionate and effective regulations, and ultimately deliver more effective, fair and trusted policy outcomes (OECD, 2021[3]).
However, in the absence of adequate safeguards, lobbying can result in unequal access and advantages for certain groups, as well as opportunities for opaque or manipulative practices, resulting in asymmetric or undue influence over public decision-making (OECD, 2010[2]). Such influence can lead to biased or poorly informed decisions, weakening prosperity through inefficient resource use, reduced productivity, and increased inequalities, and, in some cases, generating harmful outcomes in critical policy areas such as health and consumer protection. Where policymaking is shaped primarily by special interests with preferential access to public decision-makers, necessary regulations to address market failures may be abandoned, while excessive regulation may be adopted to protect incumbents, thereby reducing competition, distorting innovation incentives, dampening economic growth, and limiting job creation (Dellis and Sondermann, 2017[4]).
Ultimately, public policies that are misinformed and respond only to the needs of a specific interest group can negatively affect trust in government, possibly resulting in the dissatisfaction of the public as a whole towards public institutions and democratic processes. Findings from the OECD Survey on Drivers of Trust in Public Institutions highlight these concerns. Across OECD countries, 48% of respondents predict that a high-level political official would grant a political favour in exchange for the offer of a well-paid private sector job, while 41% consider it likely that their national government would accept the demands of a corporation promoting a policy beneficial to their industry but harmful to the society as a whole (whereas 32% believe the government would reject such demands) (OECD, 2026[5]). Perceptions are slightly more pessimistic across Latin America and the Caribbean (LAC). While a similar share of respondents (49%) believe it is unlikely that a policymaker would refuse a well-paid private sector job offered in exchange for a political favour, 45% believe their national government would accept the demands of a corporation promoting a policy beneficial to its industry but detrimental to society at large (whereas 33% believe the government would reject such demands) (OECD, 2025[6]).
These challenges are further amplified in an era of digital influence, where traditional closed-door interactions are increasingly complemented, and sometimes overtaken, by integrated digital campaigns that shape narratives and information environments. Often powered by artificial intelligence, these campaigns enable messages to be targeted, amplified and adjusted at scale, making online visibility as consequential as connections to decision-makers. While this transformation has lowered barriers to participation and allows a more diverse range of interest groups to have their voices heard, it has also heightened risks of deception and the manipulation of public opinion (OECD, 2021[3]).
The OECD Recommendation on Public Integrity (OECD, 2017[1]), the OECD Recommendation on Guidelines for Managing Conflict of Interest in the Public Service (OECD, 2003[7]), the OECD Recommendation on Transparency and Integrity in Lobbying and Influence (OECD, 2010[2]), and the OECD Recommendation on Information Integrity (OECD, 2024[8]) set out the main pillars for building or strengthening a coherent, comprehensive, effective and enforceable transparency and integrity system for lobbying and influence practices, and ensuring effective implementation and compliance. This includes, among other measures:
Granting all stakeholders, including the private sector, civil society and individuals, access to the development and implementation of public policies (see also Chapter 5).
Making publicly available online and easily accessible, in an open data format that is reusable for public scrutiny, timely, comprehensive and detailed information on lobbying and influence activities.
Implementing transparency and integrity frameworks for all those that provide advice to the government, notably advisory and expert groups.
Promoting a public integrity framework aimed at ensuring integrity when lobbying and influence actors, including companies, business and trade associations, consultancies and law firms, non-governmental organisations, think tanks, research bodies and other organisations engage in lobbying and influence activities
Establishing a public integrity framework for public officials adapted to the risks related to lobbying and influence activities.
Ensuring that the conflict-of-interest risks posed by individuals entering and exiting the public sector from and to government-regulated sectors, are properly mitigated (covered in Chapter 2).
Strengthening transparency and integrity in the financing of political parties and election campaigns (covered in Chapter 9).
Ensuring there is an oversight function on lobbying and influence activities with the capacity to enforce policies and regulations and monitor and promote their implementation.
In the Dominican Republic, a vibrant civil society has progressively emerged since 1978, following the peaceful transfer of power to the Partido Revolucionario Dominicano (PRD), which marked the end of decades of authoritarian rule. This democratic transition, together with reforms implemented since 1996 to build a sustainable, market-based economy and promote greater transparency in civic life, has supported the growth and consolidation of labour unions, human rights organisations, and other non-governmental organisations (NGOs) (Bertelsmann Stiftung, 2024[9]; Freedom House, 2024[10]).
The representation of interests as a legitimate act of political participation is grounded in the Constitution of 2010, which provides foundational rights that implicitly enable lobbying-like activities. In particular, Articles 47-49 guarantee fundamental civil and political rights that allow individuals and groups to organise and advocate for their interests, including freedom of expression, association, and assembly. Article 22 explicitly recognises the right of citizens to participate in national affairs through mechanisms such as the right to petition, popular legislative initiatives, referenda, and access to public information. Additionally, Articles 138-139 embed principles of transparency and accountability in public administration (Presidency of the Dominican Republic, 2024[11]).
Since the enactment of the Constitution in January 2010, the Dominican Republic has strengthened its policies and regulatory legal frameworks aimed at promoting transparency and integrity in public decision-making, as well as fostering citizen participation (as detailed in Table 1.1 of Chapter 1). As a result of those reforms, civil society has grown significantly in influence in recent years. Co-operatives, community organisations, and mutual-aid societies have long existed across both rural and urban areas, and civil society, labour, and business groups are now fairly well-organised. This evolution is illustrated by several notable trends:
Prominent NGOs dedicated to democracy and human rights have emerged, including Participación Ciudadana, a nonpartisan civic organisation founded in 1993, and FINJUS (Fundación Institucionalidad y Justicia), a pro-democracy foundation established in 1988. These organisations play an active role in public discourse, regularly contributing to debates on legislative reforms, judicial proceedings, and constitutional changes. They are also deeply involved in monitoring nominations to high courts and prosecutorial offices, monitoring election processes and the exposure of corruption cases.
Business associations are well-established and influential actors, including organisations such as the National Council of Private Companies (Consejo Nacional de las Emprasas Privadas, CONEP), which represents over 80 companies and 70 associations.
Investigative journalism is gaining traction and exerting increasing influence on political life, particularly through high-impact exposés of corruption. Its growing audience and visibility have strengthened its role as a key accountability mechanism within the democratic landscape (Bertelsmann Stiftung, 2024[9]; Freedom House, 2024[10]).
According to the 2022-2023 Democratic Culture Survey launched by the Ministry of Economy, Planning and Development (Ministerio de Economía, Planificación y Desarrollo, MEPyD), engaging in community-based organisations, direct contact with elected officials, as well as donations or volunteer work for political parties and leaders, remain the preferred channels through which active citizens seek to influence the political sphere (Ministry of Economy, Planning and Development, 2024[12]). In regions affected by foreign mining operations, such as Pueblo Viejo and Loma Miranda, rural communities have mobilised effectively outside traditional political parties (Bertelsmann Stiftung, 2024[9]). Other forms of engagement have emerged online, allowing NGOs without mass membership to reach broader audiences through social media and popular radio and television platforms (Bertelsmann Stiftung, 2024[9]).
Consultation with civil society and other stakeholders to build consensus around key reforms has shown signs of meaningful improvement. Representatives from business and civil society organisations interviewed for this report noted their participation in congressional working committees as a positive practice. A notable step forward occurred in 2021, when President Luis Abinader established the country’s first Multiactor Forum for Open Government (“Foro Multiactor para el Gobierno Abierto de la República Dominicana”). Framed as “a permanent space for dialogue and collaboration between the government and civil society”, the Forum represents a significant institutional innovation aimed at fostering transparency, participatory governance, and inclusive policymaking. It marks a shift toward more structured, ongoing engagement with non-governmental actors in the design, implementation, and monitoring of public policies (Government of the Dominican Republic, 2021[13]).
In practice, however, the ability of interest groups to influence policy beyond formal consultations or outside of political party structures varies significantly, and the Dominican Republic continues to face important challenges in ensuring inclusive and transparent policymaking. A deeply rooted, nonpartisan civil society has yet to fully take hold, as decades of state and political party dominance have historically co-opted citizen groups and the media. According to MEPyD’s Democratic Culture Survey, members and supporters of the three main parties still dominate non-partisan political activism, with the exception of protest mobilisations (Ministry of Economy, Planning and Development, 2024[12]). As a result, civil society participation often leans more toward symbolic consultation or co-optation than meaningful involvement or influence in the policy process. Executive and legislative authorities still tend to show limited receptivity to civil society input in the day-to-day formulation of policies. Labour unions, with the notable exception of those representing transportation workers and teachers, remain relatively weak and fragmented (Bertelsmann Stiftung, 2024[9]; Freedom House, 2024[10]).
Most importantly, concerns about undue influence persist, particularly in sectors such as infrastructure and public construction, which are seen as vulnerable to opaque decision-making. Barriers to market competition continue to pose a challenge, with public policies frequently favouring incumbent firms, big landowners and business elites eager to preserve the status quo – in particular in key sectors like tourism, mineral extraction and sugar production – while raising entry costs for new market participants (Bertelsmann Stiftung, 2024[9]). Civil society representatives interviewed for this report also highlighted an uneven playing field in access to decision-making processes, noting that international firms and professional lobbying actors, due to their experience and established relationships, are often better positioned to influence public officials.
In this context, several governance indicators and survey findings suggest that Dominicans perceive public policies as vulnerable to undue influence from vested interests, and that powerful groups may exert excessive influence over public decisions. This is reflected, first and foremost, in the results of the OECD Survey on Drivers of Trust in Public Institutions, which point to high perceptions of undue influence in the Dominican Republic. For example, nearly half of respondents (49%) believe that their national government would be unlikely to resist harmful corporate influence, while 44% consider it unlikely that a policymaker would refuse a well-paid private sector job offered in exchange for a political favour. While these findings point to a degree of public concern regarding the integrity of public decision-making, they remain broadly in line with OECD and regional averages, indicating that perceptions of undue influence in the Dominican Republic are comparable to those observed elsewhere in the OECD and the Latin America and Caribbean region (OECD, 2026[5]).
These findings are confirmed by results from the Latinobarómetro, which show that in 2023, 64% of citizens in the Dominican Republic perceived that a few powerful groups govern their country, although this proportion remains below the LAC average (Figure 8.1). Perceptions peaked in 2011, when 90% of the population believed the country was governed for the benefit of powerful groups. By 2020, this indicator had fallen to its historical low of 59.8%, before rising again to 64% in 2023. In the 2022-2023 Democratic Culture Survey launched by the MEPyD, the proportion of respondents who believe the Dominican Republic “is governed by a few powerful groups for their own benefit” reached 67.3% (Ministry of Economy, Planning and Development, 2024[12]).
Figure 8.1. Citizens in the Dominican Republic perceive that a few powerful groups govern their country
Copy link to Figure 8.1. Citizens in the Dominican Republic perceive that a few powerful groups govern their countryRespondents were asked the following question: “Generally speaking, would you say that your country is governed for a few powerful groups in their own interest? Or is it governed for the good of all?”
Note: This survey has been conducted in 18 countries in the region (Argentina, Bolivia, Brazil, Colombia, Costa Rica, Chile, Dominican Republic, Ecuador, El Salvador, Guatemala, Honduras, Mexico, Nicaragua, Panama, Paraguay, Peru, Uruguay, and Venezuela).
Source: Latinobarómetro (2024), https://www.latinobarometro.org/latOnline.jsp.
The concepts of “lobbying” and “interest representation” are also often associated with corruption, collusion, undue influence, or unethical practices, such as bribery or using personal relationships to gain favour with public officials. Several stakeholders interviewed for this report, including businesses and civil society organisations, used the concept “el hombre del maletín” (the man with the briefcase), which encapsulates in the Dominican public discourse the idea of hidden corrupt intermediaries whose untraceable operations destabilise governance, undermine transparency and negatively impacts the quality of legislative processes. This figure refers to an unnamed, often faceless individual who operates from the shadows and exerts powerful influence over public officials through clandestine means. Such actors are described as more powerful than the state itself, capable of influencing high-stakes decisions ranging from court rulings to national legislation. They prop up illicit influence by buying silence and bending institutional integrity with financial leverage, all while leaving no traceable evidence and making prosecution exceedingly difficult (Lístin Diario, 2023[14]).
Various stakeholders interviewed for this report called for a comprehensive study of lobbying and influence practices in the country to better understand their scope, risks, and regulatory needs. The OECD Public Integrity Indicator for Principle 13 of the OECD Recommendation on Public Integrity confirms that reforms are needed to strengthen the regulatory framework on lobbying, as the Dominican Republic fulfils no criteria for regulations nor for practice on lobbying, compared to the OECD average of 43% and 38%, respectively (Figure 8.2) (OECD, 2026[15]).
Figure 8.2. The OECD Public Integrity Indicator for lobbying in the Dominican Republic and cross-country comparison
Copy link to Figure 8.2. The OECD Public Integrity Indicator for lobbying in the Dominican Republic and cross-country comparison
Note: This set of indicators covers regulations and practice related to lobbying. The criteria are from the OECD Public Integrity Indicators’ datasets on “Regulatory framework for transparency in lobbying, conflict-of-interest and political finance” and “Transparency of lobbying activities and prevention of undue influence”. 2025 data or latest year available. Data not provided for Japan and Switzerland.
How to read: In 2025, Canada fulfilled 80% of criteria on regulation and 89% on practice.
Source: (OECD, 2026[16])
The OECD Public Integrity Indicator values show that the Dominican Republic currently lacks a specific legal framework that defines lobbying and lobbying activities and that could provide for transparency in lobbying. Beyond clear definitions of lobbying and lobbyists, the Dominican Republic also lacks pre- and post-public employment rules for both lobbyists and public officials (covered in Chapter 2), as well as robust beneficial ownership transparency requirements (Table 8.1). Indeed, even where lobbyists are clearly defined and subject to transparency requirements, the identity of a legal entity may not reveal its beneficial owner or the ultimate beneficiaries of lobbying activities, underscoring the need for public disclosure of adequate, accurate and up-to-date ownership and beneficial ownership information (OECD, 2010[2]). Similarly, without adequate safeguards, transitions between the public and private sectors may give rise to undue influence, highlighting the need for integrity measures that balance beneficial mobility with the protection of the public interest (OECD, 2003[7]; OECD, 2020[17]).
Table 8.1. The OECD Public Integrity Indicator for lobbying in the Dominican Republic – Regulation
Copy link to Table 8.1. The OECD Public Integrity Indicator for lobbying in the Dominican Republic – RegulationThe Dominican Republic fulfills no criteria for regulation.
|
Criteria |
Dominican Republic |
OECD average |
LAC average |
|---|---|---|---|
|
Lobbying activities are defined in the regulatory framework, including which actors are considered as lobbyists. |
✕ |
61% |
38% |
|
Cooling off periods for public officials are established in the regulatory framework. |
✕ |
75% |
46% |
|
Cooling off periods for lobbyists are established in the regulatory framework. |
✕ |
6% |
0% |
|
Sanctions for breaches of standards for transparency and integrity in lobbying are defined and proportional to the severity of the offence. |
✕ |
47% |
15% |
|
Beneficial ownership rules make mandatory the disclosure of company data to identify owners of corporations, establish a central register, and make information accessible to the public. |
✕ |
25% |
23% |
Note: The criteria are from the OECD Public Integrity Indicators’ datasets on “Regulatory framework for transparency in lobbying, conflict-of-interest and political finance” and “Transparency of lobbying activities and prevention of undue influence”.
Source: OECD Public Integrity Indicators Database (as of 10 March 2026), https://oecd-public-integrity-indicators.org/
As a result of the absence of a comprehensive regulatory framework on lobbying, the Dominican Republic does not have transparency tools such as a lobbying register to provide information on lobbying activities, nor does it have integrity standards governing interactions between public officials and lobbyists or an oversight function responsible for supervising the transparency of lobbying activities (Table 8.2).
Table 8.2. The OECD Public Integrity Indicator for lobbying in the Dominican Republic – Practice
Copy link to Table 8.2. The OECD Public Integrity Indicator for lobbying in the Dominican Republic – PracticeThe Dominican Republic fulfills no criteria for practice
|
Criteria |
Dominican Republic |
OECD average |
LAC average |
|---|---|---|---|
|
A supervisory function in central government oversees transparency of lobbying activities issues. |
✕ |
47% |
15% |
|
The code of conducts that regulates interactions between public officials and lobbyists is supported by practical examples of at-risk or undesirable behaviours and situations. |
✕ |
36% |
8% |
|
Lobbyists’ registration tools are made accessible for all and detail the registration procedure step by step to support the registrant. |
✕ |
56% |
23% |
|
The lobbying register allows to sort information collected at the minimum by lobbyist’s name, company or organisation, domain of intervention, and piece of legislation or regulation targeted. |
✕ |
28% |
8% |
|
Information disclosed by lobbyists in the register includes their name, organisation, domain of intervention, and type of lobbying activities. |
✕ |
44% |
8% |
|
Information disclosed by lobbyists in the register include budget/expenses for lobbying activities, and pieces of legislation and regulation targeted. |
✕ |
11% |
0% |
|
The lobby register is accessible online. |
✕ |
67% |
23% |
|
At least one investigation was carried out for non-compliance with the regulation of lobbying activities or incomplete or erroneous disclosure of information during the latest full calendar year. |
✕ |
36% |
8% |
|
A register of beneficial ownership of corporate entities is operational and accessible to the public. |
✕ |
17% |
8% |
Note: The criteria are from the OECD Public Integrity Indicators’ datasets on “Regulatory framework for transparency in lobbying, conflict-of-interest and political finance” and “Transparency of lobbying activities and prevention of undue influence”.
Source: OECD Public Integrity Indicators Database (as of 10 March 2026), https://oecd-public-integrity-indicators.org/
Ultimately, these regulatory voids and implementation gaps can contribute to perpetuating the cycle of undue influence, as they benefit incumbents and malign actors, enabling them to shape rules in their favour at the expense of smaller, less powerful actors. Accordingly, this chapter reviews strengths and opportunities for improvement with respect to strengthening transparency and integrity in public lobbying in the Dominican Republic, and proposes tailored recommendations along the following priorities:
Building a coherent framework for transparency and integrity in lobbying and influence activities aimed at influencing government decision-making processes.
Establishing a public integrity framework adapted to the risks of lobbying and influence activities for both lobbyists and public officials.
Ensuring effective compliance and review of the lobbying regulatory framework.
8.2. Building a coherent framework for transparency and integrity in lobbying and influence activities aimed at influencing government decision-making processes
Copy link to 8.2. Building a coherent framework for transparency and integrity in lobbying and influence activities aimed at influencing government decision-making processesGovernments have the primary responsibility to establish a coherent, comprehensive, and enforceable regulatory framework that strengthens transparency and integrity across all stages of the policy cycle. When effective, such a framework recognises lobbying and other forms of influence as legitimate forms of political participation and promotes fairness and equity in the exercise of influence, while upholding citizens’ rights to understand the origins and drivers of policy choices that affect them. As such, lobbying regulations should not aim to prevent or reduce such interest representation activities, but they should establish safeguards to ensure that relevant interests are represented fairly in policymaking and that lobbying activities are conducted within the bounds of transparency and integrity (OECD, 2010[2]).
In OECD countries, lobbying is typically regulated through dedicated frameworks that define key concepts such as “lobbying” and “lobbyists”, establish transparency and integrity requirements, and provide for sanctions proportionate to the severity of breaches. Against this backdrop, this section outlines key recommendations for establishing a lobbying regulatory framework in the Dominican Republic. Recognising that addressing undue influence arising from opaque or manipulative lobbying practices requires a comprehensive and integrated approach, the section goes beyond the creation of a standalone lobbying law or register and identifies complementary reforms and tools to strengthen transparency and integrity across lobbying and influence activities more broadly. Related safeguards, such as rules on political finance and third-party campaigning, are addressed in Chapter 9, while measures to manage revolving-door risks between the public and private sectors and standards on gifts, hospitality, and other benefits offered to public officials are discussed in Chapter 2 and Section8.3.1 below.
8.2.1. The Dominican Government could adopt a lobbying regulatory framework in primary legislation that clearly specifies definitions and transparency requirements for lobbying activities
An increasing number of countries are enacting regulatory frameworks on lobbying, a growing trend that reflects the recognition of lobbying regulation as a necessary tool for strengthening public integrity (Figure 8.3). National approaches nonetheless vary considerably in both the terminology used (e.g. “interest representation”, “management of interests”, “public relations” or “advocacy”) and the form and scope of regulatory frameworks, reflecting different administrative and political traditions. Now, 61% of OECD countries and 29% of partner countries have formal definitions of lobbying activities and covered lobbying actors in their frameworks. This represents a total of 29 countries where lobbying activities are defined in the regulatory framework, including which actors are considered as lobbyists (OECD, 2026[16]).
In Latin America, Chile and Peru stand out as the only countries to have adopted comprehensive lobbying regulations enshrined in primary legislation. Peru was the first in the region to regulate this area in 2003 (Law No. 28024 on the management of interests in public administration), followed by Chile in 2014 (Law No. 20730 regulating lobbying and activities representing private interests before authorities and public officials). By contrast, Mexico, Brazil and Argentina operate more partial frameworks, typically limited to a single branch of government. In Mexico, lobbying is governed through the internal rules of procedure of the Senate and the Chamber of Deputies, which require basic registration for access. In Brazil and Argentina, executive decrees mandate certain public officials to disclose information on their meetings, providing a degree of transparency regarding interactions with interest groups.
Figure 8.3. An increasing number of countries are adopting lobbying regulatory frameworks
Copy link to Figure 8.3. An increasing number of countries are adopting lobbying regulatory frameworksCountries with a regulatory framework on lobbying establishing definitions of “lobbying” / “lobbyist”
Note: Data is based on country values for criterion “Lobbying activities are defined in the regulatory framework, including which actors are considered as lobbyists”. Countries marked with an * regulate lobbying exclusively through parliamentary rules of procedure, under which lobbyists must register to access one or both houses of Parliament. Countries marked with a (*) limit lobbying regulation to decrees or administrative schemes applying only to the executive branch. All other countries primarily regulate lobbying through primary legislation, either in dedicated lobbying laws or broader integrity and transparency laws. These approaches are not mutually exclusive, as primary legislation is sometimes complemented by branch-specific rules, such as parliamentary codes of conduct or additional access requirements.
Data not provided for Japan and Switzerland.
Source: (OECD, 2026[16]).
Establishing a lobbying regulatory framework in primary legislation that clearly specifies definitions and transparency requirements for lobbying activities would have many benefits in the Dominican Republic. First, it would signal a commitment not to restrict legitimate lobbying activities, but rather to enhance transparency and safeguard the public’s right to know who is seeking to influence policy decisions, bringing the Dominican Republic closer in line with other OECD countries’ practices and with the principles embedded in the OECD Recommendation on Transparency and Integrity in Lobbying and Influence. It would also ensure a coherent and comprehensive approach to promoting transparency and accountability in all areas of public decision-making, avoiding fragmented approaches across various branches and levels of government (OECD, 2010[2]).
The introduction of lobbying regulation would also present a valuable opportunity to clearly distinguish legal efforts to influence public policy through transparent, accountable lobbying from illicit practices such as influence peddling and trading in influence. While the adoption of a lobbying law would not fully eliminate the risk of undue influence or unequal access, and cannot be expected to address all forms of malpractice, such as the provision of misleading information by lobbyists, or the concealment of the true source of influence, it would nevertheless establish clear rules for disclosure and registration. In doing so, such legislation would help define a legal and normative boundary between legitimate lobbying and corrupt influence, serving as a preventive mechanism to ensure that lobbying does not become a conduit for influence-peddling or other forms of undue influence. It would also strengthen the work of investigative journalists by providing them with reliable, standardised disclosures that can be used to uncover patterns of influence, trace relationships between interest groups and decision-makers, and hold public officials and lobbyists accountable (OECD, 2010[2]).
Lastly, the adoption of such legislation would yield significant economic benefits by fostering a more competitive and level playing field. By enhancing transparency in the policy-making process and curbing the undue influence of powerful interests, a robust lobbying framework can reduce barriers to entry and prevent regulatory capture, thereby encouraging fair competition. The lack of comprehensive legislation on lobbying is highlighted as a key regulatory barrier to firm entry and competition in the OECD Product Market Regulation (PMR) Indicators (OECD, 2025[18]).
In the Dominican Republic, while no government-sponsored bill is currently under development, the Directorate General of Government Ethics and Integrity (Dirección General de Ética e Integridad Gubernamental, DIGEIG) has explicitly acknowledged the importance of enacting a lobbying law in the country. This recognition is also present in the legislative branch, where a Bill No. 00360-2020 regulating lobbying was formally submitted to the Senate of the Republic in 2020. However, it has not advanced beyond the initial stages of review (Senate of the Dominican Republic, 2020[19]).
The majority of civil society and business representatives interviewed for this report were also in favour of the introduction of a lobbying regulatory framework in the Dominican Republic. While some emphasised self-regulatory initiatives (for example, business associations and businesses adopting their own code of conduct and transparency frameworks), experience from OECD countries shows that voluntary approaches to lobbying regulation are largely ineffective, as they lack consistency, robust enforcement, and meaningful participation from key actors, such as law firms and think tanks. Evidence also indicates that companies often avoid voluntarily disclosing their lobbying activities, using such schemes more for public image than genuine accountability (OECD, 2021[3]).
Recognising the need for such legislation is a positive and necessary step. The Dominican Republic could therefore pursue these efforts and adopt a dedicated framework regulating lobbying activities in primary legislation. While lobbying regulation does not strictly require a standalone law, it is recommended that such frameworks be established separately from anti-corruption provisions. Embedding lobbying rules within anti-corruption legislation can inadvertently reinforce the perception that lobbying is inherently corrupt, thereby stigmatising a legitimate democratic practice instead of advancing transparency and accountability. It is therefore preferable for the lobbying regulatory framework to be adopted through either a dedicated lobbying law, as in Canada, Chile, and Peru, which would provide a clear and targeted framework for managing interactions between interest groups and public officials, or as part of broader legislation focused on promoting transparency, integrity, and accountability in public decision-making.
Regardless of the approach chosen, a key success factor for implementation will be the clarity of the definitions of lobbying and lobbyist, in particular: what would be the scope of public officials and public decisions targeted by lobbying activities that would be within the scope of the framework, which type of actors would be considered as “lobbyists”, and which type of activities targeting policymaking processes, both direct or indirect, would be considered as “lobbying”. The following sections set out key considerations and recommendations for defining the scope of lobbying regulations and clarifying the core concepts of “lobbying” and “lobbyists.”
Levels and branches of Government covered
In terms of institutional scope, given that lobbying activities can occur across all levels of government (federal, national, regional, and local) as well as across all branches of government, it would be sensible for the Dominican Republic to adopt a framework that covers the executive, legislative, and judiciary branches, as well as decentralised institutions, provincial and municipal governments. This broad coverage was also the approach suggested in the lobbying bill submitted to the Senate. Such a broad coverage, including at the municipal levels, would also ensure that public decision-makers, lobbyists and citizens, regardless of where they reside in the Dominican Republic, have access to the same legal framework, which would reinforce its coherence, make it easier to understand, and avoid a multiplication of divergent frameworks at various local levels.
However, since the legislation would be introduced in a previously unregulated space, the legislation could also first prioritise the executive and legislative branches. Most regulations in place within the OECD focus on the executive and legislative branches of Government and only a few (including Austria, Chile, France, Ireland, Lithuania, Slovenia and Croatia) have national lobbying regulations that also apply at the regional and local levels. The scope of the framework could then be progressively expanded to include the judiciary and subnational levels of government in subsequent revisions, allowing for a phased approach that builds on initial implementation and lessons learned. Alternatively, the judiciary and local levels of government could be included from the outset in the legal framework, while postponing implementation at the local level for a few years. This phased rollout would allow lobbyists and public officials to first become familiar with the framework at the national level before extending its application more broadly.
Public institutions and public officials targeted by lobbying activities.
With regards to public officials targeted by lobbying activities, it is essential that any regulatory framework combine a sufficiently broad scope with a risk-based approach, ensuring coverage of those public officials most likely to be subject to lobbying and influence efforts. In the Dominican Republic, this would typically encompass the President of the Republic and his/her political advisors, members of the Government and their cabinets, Members of Parliament and their staff, as well as local elected officials and heads of municipal and regional governments. The inclusion of the staff and advisors of ministers and Members of Parliament is particularly important because of the nature of the functions they perform – strategic advice in the design of policies or reforms, crisis management, diplomacy, design of new laws and policies, which means that they are exposed to risks of undue influence because they interact closely with stakeholders and are often contacted by lobbyists more easily (OECD, 2011[20]).
In addition, the scope could cover any public official who, by virtue of their role, has the capacity to influence decision-making. This includes all holders of senior executive functions, such as heads of public administration bodies, as well as positions deemed at risk due to their regulatory or oversight responsibilities. To ensure comprehensive coverage and maintain flexibility, the legal framework could define certain core categories of public officials, while allowing individual agencies to designate additional roles within their structures that should be subject to the framework based on their functions. A similar system exists in Chile, enabling the transparency framework to be tailored to sensitive sectors and high-risk roles within the administration, such as procurement officials in specific ministries (Box 8.1).
Box 8.1. Designation by resolution of public officials targeted by lobbying activities in Chile
Copy link to Box 8.1. Designation by resolution of public officials targeted by lobbying activities in ChileTo promote transparency and accountability, the Lobbying Act in Chile requires the list of public officials targeted by lobbying activities to be made publicly available and kept up to date by each public institution covered by the Act.
Article 4 of the Act states that the institutions covered by the legal framework can establish by means of resolutions or agreements other public officials as designated public officials if these officials, by virtue of their function or position, have relevant decision-making powers or decisive influence on the persons who have such powers. The list of persons who are determined by these resolutions to be passive subjects are published annually on the websites of each institution.
In addition, if a person considers that a particular civil servant or public official, by reason of his or her function or position, has relevant decision-making powers or decisive influence over those who have such powers, he or she may request their incorporation, in writing, to the relevant authority. The latter must rule on the request within a period of ten working days, in sole instance, and any decision rejecting the request must be substantiated.
This system allows some level of flexibility and to include in the list of passive subjects public officials who have not been considered as such in the legal framework.
Source: (OECD, 2024[21])
In addition to the executive and legislative branches, there are other relevant institutions in the Dominican Republic that could be included within the scope of a lobbying regulatory framework. These include the Central Electoral Board (Junta Central Electoral), as well as key bodies within the judiciary, such as the National Council of the Judiciary (Consejo Nacional de la Magistratura), the Judicial Council (Consejo del Poder Judicial), and the Constitutional Court (Tribunal Constitucional). There have been credible reports of lobbying efforts targeting the National Council of the Judiciary, which is responsible for appointing judges to the Supreme Court (Suprema Corte de Justicia), the Constitutional Court, and the Superior Electoral Court (Tribunal Superior Electoral) (Bertelsmann Stiftung, 2024[9]).
Public decisions targeted
With regard to public decisions targeted by lobbying activities, lobbying activities can be directed at the whole policy cycle, including the setting of policy agendas, the development and adoption of policies, or in the implementation or evaluation phases of policies and regulations. Across the OECD, comprehensive lobbying frameworks typically cover the development of primary legislation, including its introduction, consideration, amendment and adoption by Parliament; the development or amendment of regulations; the formulation of government policies and programmes; the awarding of grants, contributions and other financial benefits; and the awarding of public contracts, generally limited to stages of the procurement and tendering process not already subject to transparency requirements.
Decisions on the appointment of certain public officials can also be a key area of interest for lobbyists, allowing them to advance their interests if a person in line with their specific interests is placed in the position concerned. In the Dominican Republic, this could cover the appointment of specific high-level positions (e.g. nominations of members of the Supreme Court, Constitutional Court and the Superior Electoral Court) as well as heads of agencies. This list could be aligned with Article 2 of Law No. 155-2017 on Money Laundering and Terrorism Financing (Ley No. 155-2017 lavado de activos y el financiamiento del terrorismo), which identifies specific categories of public officials holding “politically exposed persons” (“personas expuestas políticamente”), in line with FATF standards.
Actors considered as “lobbyists”
When it comes to actors conducting lobbying activities and those on whose behalf lobbying activities are conducted, the OECD Recommendation on Transparency and Integrity in Lobbying and Influence encourages a broad definition of lobbyists, extending beyond professional or paid lobbyists to include a wider range of individuals and organisations, domestic or foreign, engaged in influencing public decision-making (OECD, 2010[2]). Indeed, what determines whether a specific actor should be bound by transparency requirements on lobbying activities is not the status of the actor, whether for-profit or not-for-profit, specifically remunerated or not remunerated to conduct such activities, but whether the actor conducts activities to influence public decision-making processes. In this sense, countries should promote mechanisms to improve transparency around the influences over public policymaking, rather than trying to regulate or control the conduct of specific actors.
The proposed lobbying bill covered a wide range of actors, including both in-house lobbyists and consultants representing clients. It distinguished between “lobbyists” (external consultants lobbying on behalf of clients) and “managers of interests” (legal entities or groups such as trade associations, neighbourhood groups, businesses, civil society organisations, lawyers, universities, non-profits, and religious organisations) that seek to influence public decisions. However, in countries where this distinction exists, such as Chile, it has often led to confusion and created loopholes that allow certain actors to evade disclosure requirements. It may also reinforce the perception that those registered as “managers of interests” are not true lobbyists (OECD, 2024[21]). A more effective alternative is the Canadian model, which distinguishes between “in-house” and “consultant” lobbyists while maintaining the overarching “lobbyist” terminology to ensure consistency and clarity.
Regarding the specific actors that the scope would cover, the inclusion of religious organisations in the bill is particularly notable. While many OECD countries exempt them, these groups can wield significant influence on policymaking. In the Dominican Republic, the Catholic Church has long held political sway, while evangelical churches have grown in prominence in recent decades. For instance, there have been cases where strong opposition from religious groups has influenced policy reversals or reforms, illustrating the role that religious interests can play in shaping public policy, particularly on societal issues (Bertelsmann Stiftung, 2024[9]). Several stakeholders interviewed noted the significant influence of churches, with some describing them as “invisible lobbyists” whose interests often intersect with political or economic agendas.
An environment where civil society can operate safely is a precondition for including civil society organisations and religious groups in any lobbying framework. As such, including religious groups in the scope of lobbying regulation should not be intended to stigmatise or restrict their advocacy. However, when such advocacy influences public decisions on key societal issues, it is appropriate to ensure transparency by subjecting their lobbying activities to the same standards as other interest groups.
Activities considered as “lobbying”
In terms of the types of communication considered lobbying, the OECD Recommendation on Transparency and Integrity in Lobbying and Influence encourages a broad interpretation, reflecting the full range of tools used to influence public decision-making. While the draft lobbying bill in the Dominican Republic did not explicitly define the forms of communication covered, it appeared to focus mainly on formal meetings and hearings, similar to the approach in Chile and Peru. However, such a narrow focus on planned lobbying meetings would leave out other forms of influence, including informal or ad hoc communications, such as written communications (email exchanges, WhatsApp messages) or impromptu meetings in which lobbying activities subsequently take place.
Additionally, indirect forms of lobbying, such as communication campaigns and the use of social media, could also be considered within scope. Often referred to as “grassroots lobbying”, these efforts aim to mobilise public opinion to influence policymakers and are frequently driven by well-funded actors. In the Dominican Republic, civil society organisations and other interest groups frequently influence policy debates through traditional media (print, radio, and television) and increasingly through social media. Digital platforms have amplified their reach, enabling more diverse actors, from grassroots movements to business interests, to shape public discourse in real time, often with more immediacy than traditional forms of lobbying. Despite being rarely covered in OECD lobbying regulations to date, many countries are now considering the inclusion of these activities in their lobbying frameworks given their growing prevalence and impact (OECD, 2021[3]).
Given this context, adopting a broader definition of lobbying communication in the Dominican Republic would better reflect current influence dynamics. At the same time, as noted earlier in relation to actors covered, it is crucial to ensure that any lobbying regulatory framework preserves a safe and open space for civil society. A lobbying law should never be used to stigmatise or suppress advocacy and grassroots activity, but rather to promote fair and transparent policymaking by requiring disclosure of those behind campaigns seeking to shape public policy. Box 8.2 provides an overview of OECD Members’ experience in setting out clear, comprehensive and broad definitions on lobbying.
Box 8.2. Examples of broad definitions of ‘lobbying’ amongst OECD Members
Copy link to Box 8.2. Examples of broad definitions of ‘lobbying’ amongst OECD MembersCanada
Communications considered as lobbying include direct communications with a federal public office holder (i.e. either in writing or orally) and grass-roots communications. The Lobbying Act defines grassroots communications as “any appeals to members of the public through the mass media or by direct communication that seek to persuade those members of the public to communicate directly with a public office holder in an attempt to place pressure on the public office holder to endorse a particular opinion”. For consultant lobbyists (those who lobby on behalf of clients), arranging a meeting between a public office holder and any other person is also considered as lobbying.
The means used for the purpose of appealing to the general public may include letter and electronic messaging campaigns, advertisements, websites, social media posts and platforms. Participation in the strategic and operational activities of an appeal to the general public (approving items, providing advice, conducting research and analysis, writing messages, preparing content, disseminating content, and interacting with members of the public) also requires registration.
Ireland
“Relevant communications” means communications (whether oral or written and however made) made personally (directly or indirectly) to a designated public official in relation to a relevant matter. They can also include informal communications such as casual encounters, social gatherings, social media messages directed to public officials, or “grassroots” communication, defined as an activity where an organisation instructs its members or supporters to contact public officials on a particular matter.
European Union
In the European Union, the Inter-institutional agreement between the European Parliament, the Council of the European Union and the European Commission on a mandatory transparency register defines “covered activities” as: (a) organising or participating in meetings, conferences or events, as well as engaging in any similar contacts with Union institutions; (b) contributing to or participating in consultations, hearings or other similar initiatives; (c) organising communication campaigns, platforms, networks and grassroots initiatives; (d) preparing or commissioning policy and position papers, amendments, opinion polls and surveys, open letters and other communication or information material, and commissioning and carrying out research.
Source: (OECD, 2021[3])
8.2.2. The proposed lobbying regulatory framework could enhance transparency through a range of complementary transparency tools
Once a regulatory framework is in place, a critical step in enhancing transparency in lobbying is the establishment of mechanisms and tools that allow public officials, businesses and civil society to understand who has sought to influence public decision-making and on what issues. These mechanisms should ensure that relevant and timely information on key aspects of lobbying activities is disclosed, thereby strengthening public oversight of the information, advice and interests shaping policymakers’ decisions (OECD, 2010[2]).
Transparency can be ensured by various complementary means that should ultimately aim to clarify who is lobbying, on behalf of whom, whom they are lobbying, how they are doing it, and for what purpose (Table 8.3.). In most OECD countries, the primary responsibility for disclosure lies with lobbyists, who are required to register and report their activities through a lobbying registry. An alternative or additional model places the disclosure obligation on public officials, requiring them to report meetings with lobbyists, whether through open agendas, dedicated registers, or internal reporting requirements to their superiors. Public decision-making process footprints, which refer to documentation that details the stakeholders who sought to influence the decision or were consulted in its development, and shows what inputs into the particular public decision-making process were submitted and what steps were taken to ensure inclusiveness of stakeholders in the development of the regulation, as also an additional avenue for transparency. When used together, these approaches can contribute to a fuller and more accessible picture of influence on public decision-making.
Table 8.3. Tools for ensuring transparency in lobbying
Copy link to Table 8.3. Tools for ensuring transparency in lobbying|
Lobbying registers |
Voluntary or mandatory public registers in which lobbyists and/or public officials must disclose information about their interactions. The information disclosed may include the purpose of lobbying, its beneficiaries and the specific activities conducted. |
|
Public agendas |
The obligation for certain categories of public officials to publish their agenda online, including their meetings with external organisations and interest groups. |
|
Public decision-making footprints |
Documentation that details the stakeholders who sought to influence the decision or were consulted in its development, and shows what inputs into the particular public decision-making process were submitted and what steps were taken to ensure inclusiveness of stakeholders in the development of the regulation. |
Source: (OECD, 2010[2]; OECD, 2021[3])
In 2025, 67% of OECD countries (compared with 52% in 2022) and 21% of partner countries (Brazil, Croatia, Romania, Serbia and Ukraine) had a publicly available register providing information on lobbying activities (OECD, 2026[16]). Having a lobbying register in place does not, in itself, guarantee adequate transparency, given significant variation in the scope and quality of these registers. A first step toward ensuring that lobbying registers provide meaningful transparency is to establish disclosure requirements that capture how lobbying occurs in practice, enabling stakeholders, including government authorities, civil society organisations, businesses, the media and the public, to fully grasp the scope and depth of these activities.
However, in many OECD countries, transparency measures fall short of this goal. Among the 24 OECD countries and 5 partner countries with an operational register, all require the disclosure of the lobbyist’s name. However, only 17 require information on the type of lobbying activities conducted. Even fewer countries require disclosure of the specific legislative or regulatory initiatives targeted, with only 12 including this information, despite its fundamental importance for understanding how public policies are influenced. Similarly, only 7 countries require disclosure of lobbying budgets or related expenditures (Figure 8.4). These gaps limit the ability of lobbying registers to foster ethical conduct, support better policymaking, and build public trust. Insufficient disclosure of the concrete aspects of lobbying, particularly the specific policy or legislative targets, may also create incentives for more opaque or manipulative practices, especially where registrants are required to disclose little more than their identity and, where applicable, that of their client.
Figure 8.4. Characteristics of lobbying registers by country
Copy link to Figure 8.4. Characteristics of lobbying registers by country
Note: Data based on country values from the criteria “Information disclosed by lobbyists in the register includes their name, organisation, domain of intervention, and type of lobbying activities”, “Information disclosed by lobbyists in the register include budget/expenses for lobbying activities, and pieces of legislation and regulation targeted” and “The lobby register is accessible online”. In Czechia, the register is designed to include more detailed information on lobbying activities. However, as the first statements on lobbying activities were submitted in January 2026, the register does not yet contain this information, which is reflected in the table.
Source: (OECD, 2026[16]).
In this regard, the proposed transparency provisions in the lobbying bill aligned well with international good practices and the OECD Recommendation on Transparency and Integrity in Lobbying, which calls for detailed disclosures on the specific public policy or regulation targeted, the objectives pursued, and any supporting documentation provided by lobbyists (OECD, 2010[2]). To this end, the bill would have established a mandatory National Register of Lobbyists, accessible through open data portals, requiring registration before any lobbying activity could take place. Several of the features proposed would go beyond common international practice and would have established a comprehensive and ambitious transparency framework for lobbying in the Dominican Republic. As such, any future legislative proposal could therefore maintain, at a minimum, this level of ambition to ensure meaningful transparency, public scrutiny and oversight of lobbying and influence activities. Specifically:
The register would have included information on the objectives and intended outcomes of lobbying activities, the final beneficiaries, the public institutions and officials targeted, supporting documentation exchanged, sources of funding and lobbying-related expenditures, as well as any previous public positions held by lobbyists or their close family members and any public funding received. In particular, the disclosure of supporting documentation, such as expert reports and position papers, is currently required only in Germany, while the disclosure of previous public employment, already required in countries such as Canada, Germany and Ireland, would facilitate greater transparency over revolving door risks.
The bill also proposed requiring lobbyists to update their registration on a quarterly basis, including reports on lobbying meetings (dates, locations, institutions or officials involved), the interests represented, compensation received and related travel expenses. Quarterly reporting is consistent with international good practice and strikes an appropriate balance between ensuring timely transparency and limiting unnecessary administrative burdens. Most OECD countries requiring activity reports apply quarterly or semi-annual reporting cycles, while Canada remains the only country requiring monthly disclosures.
The bill would have required each public institution subject to lobbying activities to publish, through its open government portal, a segmented list of registered lobbyists engaging with that institution, following a model similar to that used in Chile (OECD, 2021[3]).
In addition to lobbying registers, other transparency tools described in Table 8.3 can also help provide clarity on who is shaping the policymaking process. For example, the lobbying regulatory framework could include a provision requiring the publication of a mandatory decision-making footprint for all relevant public decisions covered by the framework, or at least for specific categories such as administrative acts, legislative bills, and laws. This would entail requiring public authorities to disclose which actors engaged in lobbying activities and how they exerted their influence, as well as who was consulted to provide views, expert advice and recommendations. This approach would go beyond the provisions of the previous lobbying bill, which required the Senate and Chamber of Deputies to publish legislative reports grouped by subject matter, including descriptions of public hearings and participation by registered lobbyists.
Lastly, another important transparency tool could be the publication of open agendas for certain categories of public officials. These agendas would detail meetings held by public officials, including the date and time, the stakeholders involved, and the purpose of each meeting, whether or not lobbying took place. As with lobbying registers, open agenda disclosures are most effective when they provide meaningful detail, including information on the issues discussed, the objectives pursued by lobbyists and the policy or legislative matters targeted. The examples of Argentina and Brazil are provided in Box 8.3.
Box 8.3. Open agendas in Argentina and Brazil
Copy link to Box 8.3. Open agendas in Argentina and BrazilIn Argentina, Decree No. 1172-2003 established the General Regulation on the Transparency of Interest Representation before the National Executive Branch. The decree created a Unified Register of Interest Representation Meetings, which requires designated public officials to record their meetings with lobbyists. This information is publicly accessible through the platform https://audiencias.mininterior.gob.ar/. Officials subject to disclosure include the President, Vice-President, Chief of the Cabinet of Ministers, Ministers, Secretaries, and Undersecretaries, as well as senior authorities of agencies, entities, companies, corporations, and other bodies under the Executive Branch. The requirement also extends to civil servants with executive functions at the rank of Director General or higher.
In Brazil, Decree No.10889-2021 (regulating the item VI of art. 5 and art. 11 of the Law No. 12813-2013 on conflict of interest), adopted in 2021, makes mandatory the disclosure of certain executive branch public officials' public appointments, their participation in hearings with private sector representatives and in political-electoral events, as well as the receipt of gifts, hospitalities and other benefits from persons outside government. The Decree includes definitions of “private representation of interests” and “interest representative” and provides for the establishment of the Electronic System of Agendas of the Federal Executive Branch (e-Agendas), a single transparency platform where information on the public agendas of these public officials is published on a daily basis.
Source: Information provided through the OECD Public Integrity Indicators database.
In countries that combine open agendas with lobbying registers, such as the United Kingdom and Lithuania, cross-referencing both sources can provide valuable insights into who sought to influence public officials, when, and on what issues. This dual approach strengthens oversight and enables a more comprehensive understanding of influence dynamics in policymaking. However, when used as an alternative rather than a complement to lobbying registers, open agendas offer only a partial view of lobbying activity, as they capture meetings but no other important channels of influence, such as written communications, unplanned meetings, grassroots lobbying, social media campaigns or the funding of third-party organisations. This reinforces the importance of establishing a coherent and complementary ecosystem of transparency tools for lobbying and influence, in which data can, to the extent possible, be centralised or cross-checked across different disclosure mechanisms.
If several complementary tools are established, it will also be crucial to centralise and publish information collected through lobbying registers, open agendas, and decision-making footprints via a public portal that facilitates access to and interpretation of large volumes of data. While these portals may take different forms, they should move beyond static lists or isolated disclosures that offer limited insight into lobbying dynamics or their influence on public decision-making. To be effective, such portals should function as integrated information ecosystems for citizens, lobbyists, and public officials, maximising the usability and public value of disclosed data. In practice, this requires enabling users to search, filter, and sort information by key criteria (such as the lobbyist’s name, the organisation represented, the policy area concerned, or the legislative or regulatory initiative targeted) and to cross-reference this information with other relevant datasets, including political finance and gifts.
8.2.3. Transparency and integrity rules could be established for government advisory and expert groups, including lobbying activities targeting these groups
Governments across the OECD make wide use of advisory and expert groups to inform the design and implementation of public policy. An advisory or expert group refers to any committee, board, commission, council, conference, panel, task force or similar group, or any subcommittee or other subgroup thereof, that provides advice, expertise or recommendations to governments. Such groups are composed of public and private sector members and/or representatives from civil society and may be set up by the executive, legislative or judicial branches of government. These groups can be permanent or set up on an ad hoc basis to respond to specific needs in a specific period of time (OECD, 2010[2]; OECD, 2021[3]).
Chairpersons and members of advisory or expert groups can help strengthen evidence-based decision making. However, without sufficient transparency and integrity safeguards, there is a risk that the legitimacy of expert groups’ advice is undermined. External representatives participating in these groups have direct access to policy-making processes, often without being subject to lobbying or broader integrity rules, and may, whether unconsciously or not, favour their own interests as they participate in policymaking.
To preserve the benefits of inclusive policymaking while preventing undue influence, the legal framework could incorporate specific transparency and integrity safeguards that balance the right of external stakeholders to participate in government advisory and expert groups with the need to guard against policy capture or biased advice from special interests participating in these groups. One effective approach would be to integrate such provisions into the lobbying regulatory framework. For instance, public institutions covered by the lobbying law could be required to adopt formal rules and guidelines that establish minimum standards for the composition, functioning, and transparency of advisory and expert groups involving persons from outside the government. These rules could include clear procedures for appointment, disclosure of interests, meeting agendas, and publication of recommendations. In turn, participation in such structured groups, when conducted in accordance with these minimum standards, could be explicitly excluded from the definition of “lobbying” communications, thus encouraging open and transparent engagement while maintaining the integrity of the process. The Transparency Code for working groups in Ireland (Box 8.4) may serve as a useful example.
Box 8.4. Transparency Code for Working Groups in Ireland
Copy link to Box 8.4. Transparency Code for Working Groups in IrelandIn Ireland, the Regulation of Lobbying Act 2015 includes a list of excepted communications (Section 5, subsection 5(n)). This list includes communications between members of a relevant body appointed by a Minister of the Government or by a public service body, that includes at least one designated public official and at least one person from outside the public service, and which reviews, assesses or analyses any issue of public policy with a view to reporting on it to the Minister of the Government or the public service body.
However, the exception only applies if the relevant body conducts its activities in accordance with a Transparency Code prepared by the Department of Public Expenditure and Reform in accordance with Section 5 (7) of the Act. The following information must be published on the website of the public body on its establishment:
Names of chairperson and members, with details of their employing organisation (if they are representing a group of stakeholders, this should be stated).
Whether members from outside the public sector were formerly public officials.
Terms of reference of the group.
Expected timeframe for the group to conclude its work.
Reporting arrangements.
In addition, the agenda and minutes of each meeting must be published and updated at least every four months. The chairperson must include with the final or annual report of the group a statement confirming its compliance with the Transparency Code. If the requirements of the Code are not adhered to, interactions within the group are considered to be a lobbying activity under the Regulation of Lobbying Act 2015.
Source: Department of Public Expenditure and Reform, Transparency Code prepared in accordance with Section 5 (7) of the Regulation of Lobbying Act 2015, https://www.lobbying.ie/media/5986/2015-08-06-transparency-code-eng.pdf
Regardless, lobbying activities carried out by interest groups that are not formally part of advisory or expert groups, but that seek to influence the deliberations or decisions of these bodies, should be clearly covered by the lobbying regulatory framework proposed in Section 8.2.1.
8.3. Establishing a public integrity framework adapted to the risks of lobbying and influence activities for both lobbyists and public officials
Copy link to 8.3. Establishing a public integrity framework adapted to the risks of lobbying and influence activities for both lobbyists and public officialsThe strength and effectiveness of a lobbying regulatory framework also depend on the integrity of both public officials and those who seek to influence them. However, lobbying and influence are typically an example where public officials and lobbyists may face ethical dilemmas in cases where there are no clear legal “right” or “wrong” answers or where there may be conflicts between different values or principles. As such, lobbying-related ethical dilemmas are a key challenge for integrity policies. This is particularly true in an age of social media and information overload, where back and forth between the private and public sectors is commonplace, and where public officials are constantly exposed to public scrutiny and criticism, risking the collapse of their reputations every time an intervention is misperceived or misinterpreted. Lobbying and influence actors, in particular companies, are also under an increasingly high degree of scrutiny from all stakeholders, notably their own employees, investors and the public. This has significantly increased the expectations regarding their level of and their commitment to integrity in engaging with the policymaking process (OECD, 2010[2]; OECD, 2021[3]). This is why many OECD countries have established minimum expected standards of behaviour for lobbyists and/or public officials in their lobbying laws or specific codes of conduct (OECD, 2021[3]). Accordingly, this section outlines key recommendations for establishing a public integrity framework adapted to the risks of lobbying and influence activities for both lobbyists and public officials in the Dominican Republic.
8.3.1. The Dominican Republic could develop specific rules, standards and guidelines for public officials on their interactions with lobbyists
Lobbying integrity standards for public officials may be included in a specific lobbying law, a lobbying code of conduct as well as guidelines specific to interactions with between public officials and external parties. Within the OECD, 13 countries have a code of conduct that regulates interactions between public officials and lobbyists that is supported by practical examples of at-risk or undesirable behaviours and situations (OECD, 2024[22]).
Standards for public officials can also be integrated into general frameworks such as laws, codes of integrity, or codes of conduct (including those covered in Chapter 2). These standards may also be tailored to specific sectors or functions within the executive and legislative branches, with stricter requirements for politically exposed persons, such as members of parliament, ministers, and policy advisors, given their heightened exposure to lobbying and influence efforts. Depending on the nature of the instrument used, these standards may set out expectations for how public officials interact with lobbyists, including, for example:
The duty to check that lobbyists are duly registered in the Register of Lobbyists, or that they intend to do so within the indicated timeframe.
The duty to treat lobbyists equally by granting them fair and equal access, including maintaining equal treatment with respect to persons, organisations and entities requesting meetings on the same matter.
The obligation to report violations of existing lobbying standards to the competent authorities.
The duty to publish information on their meetings with lobbyists (through a lobbying registry or open agendas).
The obligation to refuse to accept gifts from lobbyists, or to declare gifts and benefits received in exceptional circumstances where they cannot be refused, among others (covered in Chapter 2).
The duty to abide by specific post-employment rules and restrictions after they leave office (also covered in Chapter 2).
As such, should a lobbying regulatory framework be established in the Dominican Republic, it could include specific standards for public officials on their interactions with lobbyists. Several examples are provided in Table 8.4. Existing standards, such as codes of integrity in the executive and judicial branches (covered in Chapter 3), could also be updated to specifically take into account lobbying-related risks. This would be in line with the recommendation set out in Section 3.2.2 of Chapter 3.
Table 8.4. Examples of specific standards for public officials on their interactions with lobbyists
Copy link to Table 8.4. Examples of specific standards for public officials on their interactions with lobbyists|
Framework |
Standards |
|
|---|---|---|
|
Australia |
Australian Government Lobbying Code of Conduct |
|
|
Chile |
Law regulating lobbying and the representation of private interests before authorities and civil servants. |
|
|
Latvia |
Cabinet Regulations No. 1 Values of State Administration and Fundamental Principles of Ethics |
|
|
Lithuania |
Law on Lobbying Activities |
|
|
Slovenia |
Integrity and Prevention of Corruption Act |
|
Source: (OECD, 2021[3]).
In addition to the post-employment restrictions outlined in Chapter 2, some countries with lobbying regulatory frameworks have introduced cooling-off periods that apply specifically to lobbying (Box 8.5). For a defined period after leaving public office, public officials are barred from engaging in lobbying activities as set out in the relevant legislation. In addition to the recommendations already made in Chapter 2 on general cooling-off periods, the Dominican Republic could therefore also consider introducing specific cooling-off periods on lobbying activities.
Box 8.5. Examples of provisions on lobbying cooling-off periods for elected officials and appointed officials in at-risk positions in OECD counties
Copy link to Box 8.5. Examples of provisions on lobbying cooling-off periods for elected officials and appointed officials in at-risk positions in OECD countiesIn the Netherlands, a circular adopted in October 2020 – “Lobbying ban on former ministries” – prohibits ministers and any officials employed in ministries to take up employment as lobbyists, mediators or intermediaries in business contacts with a ministry representing a policy area for which they previously had public responsibilities. The length of the lobbying ban is two years. The secretary general of the relevant ministry has the option of granting a reasoned request to former ministers who request an exception to the lobbying ban.
In Australia, Ministers and Parliamentary Secretaries cannot, for a period of 18 months after they cease to hold office, engage in lobbying activities relating to any matter that they had official dealings within their last 18 months in office. Additionally, persons employed in the Offices of Ministers or Parliamentary Secretaries at Adviser level and above, members of the Australian Defence Force at Colonel level or above (or equivalent), and Agency Heads or persons employed in the Senior Executive Service (or equivalent), must not, for a period of 12 months after they cease their employment, engage in lobbying activities relating to any matter that they had official dealings with in their last 12 months of employment.
In Canada, during the five-year period after they cease to hold office, former designated public office holders are prohibited from engaging in any consultant lobbying activities. Similarly, former designated public office holders who are employed by an organisation are also prohibited from engaging in any in-house lobbying activities for this same five-year period.
Ireland’s Regulation of Lobbying Act provides that certain designated public officials (DPOs) are restricted from being engaged in lobbying in certain circumstances for a year after they leave their employment or office unless they get permission from the Standards Commission – in effect, they are subject to a “cooling-off” period. The DPOs concerned are Ministers and Ministers of State, special advisers and prescribed public servants.
Source: (OECD, 2021[3])
8.3.2. The advisory bodies or units recommended in Chapter 1 could also support public officials on lobbying-related ethical dilemmas and the application of lobbying rules
Even in systems where a central lobbying oversight body is vested with broad advisory and educational functions, it is important that public officials have access to clear and trusted contact points within their own institutions to seek guidance on the application of lobbying rules and ethical dilemmas. In this regard, and consistent with the recommendations in Chapter 1 to strengthen preventive and advisory bodies or units across each branch of government, these structures could also be tasked with providing guidance on lobbying-related integrity issues. This could include responding to queries related to interactions with lobbyists, gifts and hospitality, participation in events, revolving door situations, third-party influence, or broader ethical dilemmas arising in the context of lobbying and influence activities. Such an approach is particularly important given that lobbying-related ethical dilemmas often overlap with broader issues related to conflicts of interest, impartiality and integrity in public decision making.
8.3.3. The Dominican Republic could consider developing and adopting standards of conduct which would apply to all lobbyists
As with standards applicable to public officials, standards governing lobbyists’ interactions with public officials can take various forms. They may consist of core values and guiding principles that shape ethical lobbying behaviour, complemented by a more detailed code of conduct outlining specific obligations. Box 8.6 provides examples of such standards in other jurisdictions. Typically, these standards include the following types of obligations:
The duty to disclose truthful and complete information and to certify that the information disclosed is correct.
The duty to present accurate information or not to make misleading claims when interacting with public officials.
The duty to disclose, when interacting with public officials, the interests they represent and the ultimate beneficiary of the lobbying activities.
The duty to disclose the sources of funding for any research or expertise they provide to public officials.
The duty to inform their clients, when applicable, of the obligations to which they are subject by virtue of the lobbying regulatory framework.
A prohibition to offer gifts or any form of personal benefit (in whole or beyond a certain value) to public officials whose duties and decision-making are directly related to their lobbying activities.
The draft lobbying bill already included a provision requiring the Dominican government to adopt a Code of Conduct for lobbyists through secondary regulation. This constitutes a positive and forward-looking element of the proposal. Building on this foundation, the Dominican Republic could ensure that clear, enforceable standards governing lobbyists’ behaviour are firmly embedded in any future lobbying regulatory framework, either by enshrining key obligations directly in primary legislation or by mandating a binding Code of Conduct adopted through regulation.
Box 8.6. Standards of conduct for lobbyists in selected OECD countries
Copy link to Box 8.6. Standards of conduct for lobbyists in selected OECD countriesAustralia’s Lobbying Code of Conduct includes ethical standards for both lobbyists and Australian government representatives. In addition to the obligation to register as a lobbyist before communicating with an Australian Government representative in an effort to influence decision-making on behalf of a third party, lobbyists must also observe, under Section 12 of the Code, 5 principles when engaging with Australian Government representatives: (i) no corrupt, dishonest, illegal or unlawful conduct; (ii) use truthful and accurate statements; (iii) no misleading or exaggerated claims about their access to government representatives or other persons; (iv) keep lobbying activity and personal activity on behalf of a political party separate; (v) when making initial contact with government representatives, lobbyists must disclose that they are lobbyists, whether they are registered, the name of the client they are acting on behalf of, the nature of the matters they wish to discuss and, if relevant, details relating to any prohibition period due to their previous employment as a government representative.. Lobbyists who fail to comply with any of these obligations may be removed from the register.
In France, Article 18-5 of Law No. 2013-907 sets out the ethical obligations governing lobbyists’ conduct. Lobbyists must act with honesty and integrity in their dealings with public officials and are required to clearly disclose their identity, the organisation they represent, and the interests they promote. They are prohibited from offering gifts, donations or advantages, misleading officials, or using dishonest methods to influence decisions or obtain information. They must also refrain from encouraging public officials to breach their own ethical obligations or involving them in paid speaking engagements. Additionally, they must not misuse official information or materials for commercial gain, and they should extend these ethical practices to dealings with officials' close associates.
Canada’s Lobbyists’ Code of Conduct, which was updated in 2023 following extensive consultations with relevant stakeholders, defines standards of ethical behaviour that lobbyists must comply with. The Code applies to any individual who must be identified as a lobbyist in the Registry of Lobbyists. It covers lobbying activities and interactions that lobbyists have with officials that they lobby or expect to lobby. The Commissioner of Lobbying administers the Code, and breaches can result in a report to Parliament.
Germany’s Code of Conduct for representatives of special interests requires them to uphold the principles of openness, transparency, honesty and integrity, and establishes rules for making contact with Members of the Bundestag and members of the Federal Government. Infringements of the Code of Conduct are published in the Lobbying Register.
Ireland’s Lobbying Code of Conduct, issued under the Regulation of Lobbying Act 2015, sets ethical standards for individuals and organisations engaged in lobbying activities. The Code requires lobbyists to act with honesty, respect, and integrity, to provide information that is accurate and not misleading, and to avoid placing public officials in a conflict of interest.
Chile’s Lobbying Act’s sets out ethical obligations for lobbyists. They must provide accurate and timely information to public officials when requesting meetings, including the identities of attendees and topics to be discussed. They are also required to disclose whom they represent and whether they are receiving remuneration for their actions. In addition, a voluntary Code of Good Practice for Lobbyists (Código de buenas prácticas para lobbistas) requires lobbyists to act with honesty, integrity, transparency, and professionalism, ensuring their activities align with the public interest.
Source: updated from (OECD, 2021[3])
8.3.4. The Dominican Republic could adopt specific incentives to encourage more responsible and transparent engagement in the policymaking from companies and business associations
Given the growing public and investor scrutiny of corporate lobbying and political engagement practices, governments can adopt specific incentives to encourage more responsible and transparent engagement in the policymaking process from companies and business associations. A key concern among institutional investors is the misalignment between companies’ public commitments on matters related to responsible business conduct, and their behind-the-scenes lobbying efforts that may work against these same objectives. This perceived contradiction has led to heightened investor demand for robust standards, transparency, and accountability in how companies engage politically, with lobbying increasingly viewed not only as a reputational risk but also as a material investment risk (OECD, 2021[3]).
To help bridge this gap, a number of OECD instruments provide clear expectations for corporate behaviour in this space (Box 8.7). These include the OECD Recommendation and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, which encourage companies to ensure that their lobbying activities are aligned with their broader commitments on a range societal and environmental issues. Similarly, the OECD Recommendation on Transparency and Integrity in Lobbying and Influence and the OECD/G20 Principles of Corporate Governance encourage companies to ensure their lobbying and influence strategies are consistent with their sustainability-related goals and targets.
In that context, and in line with the recommendation of Chapter 5 to strengthen the shared responsibility of the Dominican private sector for integrity, the Dominican government could promote responsible business conduct by encouraging companies and interest groups to adopt formalised internal standards and procedures for lobbying and other forms of engagement. Doing so would help reassure both the public and investors that lobbying activities are conducted professionally, ethically, and in alignment with broader societal expectations. The Code of Conduct proposed in the lobbying bill specified that it would enable the adoption of additional voluntary commitments by lobbyists, including through collective action mechanisms such as corporate social responsibility initiatives, subject to appropriate oversight and monitoring. This is a commendable step that sets an example in the region. In this regard, initiatives such as the Código de Ética y Conducta del Consejo Nacional de la Empresa Privada (CONEP) could be further promoted and potentially aligned with the proposed regulatory framework on lobbying to ensure coherence and credibility (CONEP, 2022[23]).
Responsible lobbying could also be promoted through existing corporate compliance programmes by expanding their scope to explicitly cover lobbying and influence activities. This could include requiring companies to adopt, implement, and periodically review internal responsible lobbying policies and procedures, in line with the recommendations outlined in Section 5.2.2 of Chapter 5, thereby embedding transparency, integrity, and accountability standards for lobbying within broader corporate compliance frameworks.
Lastly, responsible lobbying principles could also be anchored in corporate governance frameworks. As encouraged by the OECD/G20 Principles of Corporate Governance, legal provisions can help ensure that lobbying activities are subject to appropriate internal checks and shareholder oversight. For example, under the UK Companies Act (Part 14, “Control of political donations and expenditures”), companies are prohibited from making political donations or incurring political expenditures unless authorised by a formal resolution passed by shareholders. Similar legal mechanisms could be considered in the Dominican Republic to enhance accountability, ensure alignment with corporate values, and reinforce public confidence in private sector involvement in the policy process (OECD, 2022[24]).
Box 8.7. OECD standards providing (government) expectations to businesses on lobbying
Copy link to Box 8.7. OECD standards providing (government) expectations to businesses on lobbyingOECD Guidelines for Multinational Enterprises on Responsible Business Conduct
General Policies – A.5: “enterprises should ensure transparency and integrity in lobbying activities, and refrain from seeking or accepting exemptions not contemplated in the statutory or regulatory framework related to human rights, environmental, health, safety, labour, taxation, financial incentives, or other issues”.
OECD/G20 Principles of Corporate Governance
Chapter VI – Sustainability and resilience – VI.C.1: “Boards should ensure that companies’ lobbying activities are coherent with their sustainability-related goals and targets.
Boards should effectively oversee the lobbying activities the lobbying activities management conducts and finances on behalf of the company, in order to ensure that management gives due regard to the long-term strategy for sustainability adopted by the board. For instance, lobbying against any carbon pricing policy may be expected to increase a company’s short-term profits but not be in line with the company’s goal to make an orderly transition to a low carbon economy. In some jurisdictions, boards also have a role in overseeing the disclosure of political donations, including related to lobbying activities”.
OECD Recommendation on Transparency and Integrity in Lobbying and Influence
Principle VI b) and c) of the Recommendation: “Adherents should (…): b) ensure that companies’ lobbying and influence activities are consistent with the companies’ commitments and goals on responsible business conduct matters; c) encourage companies to have due diligence measures in place to ensure that their lobbying and influence activities are coordinated and coherent with their initiatives dealing with anti-corruption, responsible business conduct, public integrity as well as with their broader environmental, social, and governance goals”.
8.4. Ensuring effective compliance and review of the lobbying regulatory framework
Copy link to 8.4. Ensuring effective compliance and review of the lobbying regulatory frameworkEffective lobbying regulation depends not only on clear rules and disclosure requirements, but also on robust arrangements for oversight, enforcement, and continuous review. Ensuring compliance requires an institutional framework that is independent, adequately resourced, and equipped with the powers to monitor implementation, investigate breaches, apply sanctions, and promote awareness and guidance among stakeholders. Independent oversight is particularly essential to ensure impartial enforcement and to provide credible responses, including corrective measures or redress where appropriate, to breaches of lobbying regulations (OECD, 2010[2]). Accordingly, this section examines how the Dominican Republic could strengthen the operational effectiveness of a future lobbying regulatory framework by establishing credible oversight and enforcement mechanisms, embedding proportionate sanctions, and fostering ongoing stakeholder engagement and periodic review in line with OECD standards.
8.4.1. The monitoring and enforcement of a future lobbying regulatory framework could be entrusted to an oversight body with functional independence
Oversight functions are an essential feature to ensure an effective lobbying regulation. The oversight function refers to an independent public institution or institutions, dedicated or with broader competencies, adequately resourced and empowered to investigate and enforce policies and regulations concerning lobbying and influence activities, and monitor and promote their implementation (OECD, 2010[2]). While institutional arrangements for lobbying oversight vary across the OECD, examples of countries with independent oversight are provided in Table 8.5. Experience from these countries suggests that when functions related to investigation and the imposition of sanctions are able to operate with a degree of independence, oversight bodies are better placed to monitor compliance, enforce rules on lobbying and influence activities, and support effective implementation (OECD, 2026[16]).
Table 8.5. Oversight functions for lobbying activities in selected OECD countries
Copy link to Table 8.5. Oversight functions for lobbying activities in selected OECD countries|
Country |
Legal framework |
Oversight |
|||
|---|---|---|---|---|---|
|
Law |
Reporting obligations |
Branches of government |
Independent authority |
Compliance and enforcement mandate on lobbying |
|
|
Canada |
Lobbying Act (1985, as amended in 2008) |
Lobbyists |
Executive Legislative |
Office of the Commissioner of Lobbying |
|
|
France |
Law No. 2013-907 on transparency in public life (2013, as amended in 2016) |
Lobbyists |
Executive Legislative Local government |
High Authority for Transparency in Public Life (HATVP) |
|
|
Ireland |
Regulation of Lobbying Act (2015) |
Lobbyists |
Executive Legislative |
Standards in Public Office Commission (SIPO) |
|
|
Lithuania |
Law No. VIII-1749 Lobbying Activities of the Republic of Lithuania (2003) |
Lobbyists and public officials |
Executive Legislative Local government |
Chief Official Ethics Commission |
|
|
Slovenia |
Integrity and Prevention of Corruption Act (2010) |
Lobbyists and public officials |
Executive Legislative Judiciary Local government |
Commission for the Prevention of Corruption |
|
|
United Kingdom |
Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act (2014) |
Lobbyists |
Executive |
Office of the Registrar of Consultant Lobbyists |
|
Source: OECD Secretariat, based on (OECD, 2021[3])
In the Dominican Republic, careful consideration will need to be given to the institutional oversight architecture of any future lobbying framework, particularly depending on: (i) the branches of government and categories of public officials covered by the framework; and (ii) whether disclosure obligations apply to lobbyists, public officials, or both:
If the Dominican Republic chooses a model in which the primary disclosure obligations fall on lobbyists, it will be essential to designate a central oversight institution with the authority to administer the lobbying framework across various branches and levels of government. Should this role be entrusted to the DIGEIG (provided that the recommended reforms in Chapter 1 to strengthen its independence are implemented), the legal framework would need to ensure that it can be vested with the necessary powers to carry out key oversight functions, including verifying disclosed information, conducting investigations and applying administrative sanctions to lobbyists, regardless of the public institution or category of public official targeted by the lobbying activity, including members of parliament and officials from constitutionally autonomous bodies. Should extending such powers and jurisdiction to DIGEIG not be feasible, the creation of a dedicated autonomous oversight body for lobbying would likely be preferable.
If the Dominican Republic instead adopts a model similar to those in Chile and Peru, where disclosure obligations primarily fall on public officials and lobbying interactions are disclosed through official meeting request systems administered separately by different branches of government and public institutions, this could result in a fragmented oversight and disclosure system, as has been observed in Chile (Box 8.8). In such a system, it would remain essential to establish a visible and credible oversight institution capable of ensuring the coherence and consistency of the framework across government. In practical terms, the DIGEIG could be designated as the primary oversight body for the Executive Branch, while also being entrusted with ensuring the coherence and harmonisation of disclosure and registration systems across branches and public institutions, including through the development of common technical standards, reporting procedures and guidance applicable throughout government. For constitutionally autonomous and non-executive branches, including the Legislative and Judicial Branches, the framework would need to establish tailored and enforceable oversight arrangements. This could include designating competent bodies within these branches to investigate and sanction breaches of lobbying rules involving their respective officials. Within the Judiciary, this role could potentially be performed by the Ethical Conduct Committee (Comité de Comportamiento Ético), while within the Legislative Branch it could be entrusted to the specialised body recommended in Sections 2.1.1 and 2.2.3 of Chapter 2, in relation to conflict-of-interest and gift disclosure requirements.
Box 8.8. Challenges related to the oversight of the lobbying framework in Chile
Copy link to Box 8.8. Challenges related to the oversight of the lobbying framework in ChileIn Chile, the lobbying disclosure regime is decentralised and administered through multiple public agenda registers, reflecting the constitutional autonomy of certain state bodies. Responsibility for administering the registers, providing guidance and training, investigating potential breaches and applying sanctions is therefore dispersed across multiple institutions, with separate procedures and enforcement arrangements depending on the category of public official concerned.
Administration of the registers, provision of guidance and training
While ministries, regional and local administrations, the armed forces and other entities use registers maintained under the general framework established by the Ministry General Secretariat of the Presidency (SEGPRES), constitutionally autonomous institutions – including the Office of the Comptroller General, the Central Bank, the National Congress, the Public Prosecutor’s Office and the Judiciary – each administer their own register and adopt their own implementing regulations. As a result, lobbyists and representatives of private interests must register through six separate platforms, each with its own technical and procedural requirements.
The Transparency Council centralises the information from these registers and publishes it through a single transparency portal, InfoLobby. However, the absence of a unified “one-stop-shop” registration system has emerged as a key implementation challenge. Stakeholders have highlighted that the use of multiple platforms and non-harmonised registration procedures increases the administrative burden for lobbyists and complicates the overall understanding of the framework for citizens, public officials and interest representatives.
Oversight and enforcement
Investigations and sanctions are handled by different bodies across the executive, Congress, the Central Bank, the Public Prosecutor’s Office, the Judiciary and the Office of the Comptroller General, resulting in multiple parallel oversight systems with differing procedures, institutional practices and levels of enforcement.
While this multi-layered system is understandable with respect to investigations and sanctions, in order to preserve the constitutional autonomy of certain bodies and branches of government, the fragmentation of responsibilities on the administrative, preventive and co-ordination aspects of the framework has emerged as a significant challenge. In particular, no single institution is responsible for ensuring the overall coherence and consistency of the system through functions such as administering and harmonising the registers, centralising disclosures, issuing guidance, supporting implementation, and verifying the accuracy and completeness of information across all institutions concerned. In addition, concerns have been raised regarding the effectiveness of enforcement in practice, with few sanctions applied in practice.
As a result, the OECD recommended revising the institutional architecture for oversight of the lobbying framework, including by entrusting broader implementation, co-ordination and preventive responsibilities to the Transparency Council, or by institutionalising the Presidential Advisory Commission for Public Integrity and Transparency (within the SEGPRES) with a sufficient level of independence and a broader mandate to ensure greater coherence and consistency across branches of government.
Source: (OECD, 2024[21])
In practice, several countries combine disclosure obligations for both lobbyists and public officials, as recommended in Section 8.2.2, in order to strengthen the completeness, accuracy and verifiability of disclosures. Should the Dominican Republic adopt such a dual-disclosure model, the institutional considerations outlined above will need to be carefully integrated into the design of the oversight framework. Examples of oversight arrangements in countries operating dual-disclosure systems, such as Slovenia and Lithuania, are provided in Box 8.9.
In any case, and regardless of which institution or institutions are ultimately designated to oversee the implementation of a future lobbying regulatory framework, it will be essential to ensure that oversight functions related to monitoring, investigations and enforcement benefit from sufficient institutional independence, a clearly defined legal mandate, and adequate human, technical and financial capacity to operate effectively and credibly. The In this regard, any role entrusted to the future DIGEIG within the oversight architecture of a lobbying regulatory framework should be conditional upon the effective implementation of the recommendations set out in Section 1.2.1 of Chapter 1 to strengthen its independence through a robust legal and institutional reform framework. Lastly, the oversight function should also clearly be vested with a mandate to provide training and awareness-raising (OECD, 2010[2]).
Box 8.9. Oversight of the lobbying framework in Lithuania and Slovenia
Copy link to Box 8.9. Oversight of the lobbying framework in Lithuania and SloveniaThe Chief Official Ethics Commission (VTEK) In Lithuania
The Chief Official Ethics Commission (VTEK) is the central oversight authority responsible for supervising the implementation and enforcement of Lithuania’s Law on Lobbying Activities, which provides for a “cross-declaration” system, under which lobbyists must disclose lobbying activities and public officials (“lobbied persons”) must also declare meetings and communications with lobbyists. As a result VTEK’s mandate covers both lobbyists and public officials subject to lobbying transparency obligations.
VTEK’s jurisdiction over lobbyists applies regardless of which public institution or official was targeted by the lobbying activity, including where lobbying involved members of parliament or other constitutionally autonomous institutions. It can: review and verify lobbying registrations and reports; request documents, explanations and supporting information from lobbyists; investigate suspected violations; determine whether illegal or unregistered lobbying occurred; suspend lobbying activities; remove lobbyists from the register; and apply administrative sanctions provided under the legal framework.
VTEK also oversees compliance by public officials with lobbying-related transparency and ethics obligations. It can: verify whether public officials submitted required declarations; cross-check disclosures against lobbyists’ reports; request explanations, information and supporting documents from public officials; investigate potential breaches or undeclared lobbying contacts; and issue findings regarding non-compliance. The applicable enforcement mechanism depends on the institutional status of the official concerned. For civil servants, executive branch officials, and many public administration officials, VTEK findings may directly support administrative liability proceedings, disciplinary measures, ethics sanctions, or conflict-of-interest enforcement procedures. For elected officials and officials belonging to constitutionally autonomous bodies VTEK may investigate and transmit findings to the competent parliamentary or institutional ethics body.
The Commission for the Prevention of Corruption (KPK) in Slovenia
Oversight of lobbying in Slovenia is entrusted to the Commission for the Prevention of Corruption (KPK), an independent anti-corruption authority established under the Integrity and Prevention of Corruption Act (IPCA), which also provides for a dual disclosure model, under which lobbyists must disclose lobbying activities and public officials (“lobbied persons”) must also report lobbying contacts to the KPK.
The KPK’s jurisdiction extends broadly across the institutions covered by the Act, including the executive, legislative and judicial branches, local authorities, the Bank of Slovenia and holders of public authority. It is the primary authority responsible for initiating and applying sanctions under the lobbying framework, particularly through misdemeanour proceedings. Where conduct may also amount to a disciplinary or professional ethics breach, the KPK may transmit findings or recommendations to the competent constitutionally autonomous institution for further action under sector-specific rules.
The KPK also has an educational and preventive role, including issuing guidance and promoting awareness of lobbying obligations.
Source: Research by the OECD Secretariat, based on (OECD, 2021[3])
8.4.2. The Dominican Government could ensure there are adequate administrative and criminal sanctions for violations of the lobbying regulatory framework
Sanctions should constitute a core element of the enforcement framework, functioning primarily as a deterrent and, where necessary, as a corrective mechanism. A future lobbying regulatory framework in the Dominican Republic could therefore establish a clear and graduated catalogue of offences, together with proportionate sanctions applicable to both public officials and lobbyists. Sanctions should cover breaches of transparency obligations (such as failure to register as a lobbyist, failure to disclose required information, or the submission of inaccurate or incomplete disclosures) as well as violations of integrity standards, including non-compliance with codes of conduct or ethical rules applicable to public officials and/or lobbyists.
International good practice highlights the importance of applying sanctions that are objective, proportionate, timely, and dissuasive. Experience shows that a graduated system of administrative penalties for lobbyists is preferable, which can range from warnings and reprimands to monetary fines, temporary or permanent suspension from the register, and prohibitions on engaging in lobbying activities. A few jurisdictions, including Canada, France, Ireland, Peru, and the United Kingdom, have also introduced criminal penalties for more serious violations, including the possibility of imprisonment. In these systems, effective enforcement generally relies on an independent oversight body empowered to apply administrative sanctions for less serious violations rather than systematically referring minor offences to judicial authorities, where procedures and investigations are typically longer and more resource intensive.
Importantly, sanctions for lobbyists should be targeted at lobbying entities rather than only individual lobbyists. This approach introduces the clear responsibility of entities towards the people they employ and their managers. It can also encourage entities to adopt internal compliance rules, thereby raising the degree of professionalism with which lobbying activities should be carried out (OECD, 2021[3]).
8.4.3. The Dominican Government could promote stakeholder engagement in the design, implementation and review of the lobbying regulatory framework
Involving stakeholders in the design of lobbying regulations is essential to ensure that the framework reflects the practical realities of lobbying activities and garners broad-based support. Early engagement helps build understanding, legitimacy, and buy-in from those affected, increasing the likelihood of compliance and effective implementation. It also allows regulators to identify potential challenges and design rules and procedures that are workable in practice.
Once lobbying regulations are in place and operational, periodically reviewing, in consultation with relevant stakeholders, the functioning and impact of a legal framework on lobbying is crucial to ensure alignment with evolving lobbying and influence practices, make necessary improvements and seek convergence towards best practices (OECD, 2010[2]). OECD practice shows that involving relevant stakeholders in the revision process of lobbying-related rules and guidelines is key to create ownership and ensure a common understanding of the requirements and expected behaviours for both lobbyists and public officials (OECD, 2021[3]).
As such, the Dominican Government, through the strengthened DIGEIG, could work with stakeholders and citizens to communicate and involve them not only throughout the drafting process, but also in its implementation and subsequent revisions (including, for example, the drafting and revision of codes of conducts or guidelines), following the examples of Ireland and Canada (Box 8.10).
Box 8.10. Consultations on the drafting and revision processes of lobbying regulations in Ireland and Canada
Copy link to Box 8.10. Consultations on the drafting and revision processes of lobbying regulations in Ireland and CanadaSupporting a cultural shift towards the regulation of lobbying in Ireland through public consultation
In Ireland, the Standards in Public Office Commission established an advisory group of stakeholders in both the public and private sectors to help ensure effective planning and implementation of the Regulation of Lobbying Act. This forum has served to inform communications, information products and the development of the online registry itself.
Consultation on future changes to the Lobbyists’ Code of Conduct in Canada
In Canada, the Office of the Commissioner of Lobbying launched a series of consultations in 2021 and 2022 to collect views on improving and clarifying the standards of conduct for lobbyists to update the Lobbyists’ Code of Conduct.
An initial consultation was held in late 2020 to obtain the views and perspectives of stakeholders in relation to the existing Lobbyists’ Code of Conduct. A second consultation (15 December 2021 to 18 February 2022) aimed to collect views on a preliminary draft of the revised Code. A final and third consultation on changes to the Code was conducted in May-June 2022. The new Code was published in the Canada Gazette and came into force on 1 July 2023.
Lastly, the legal framework could incorporate a mechanism for the periodic review of the lobbying regulatory framework to ensure that it remains effective, coherent and responsive to evolving lobbying practices and influence strategies. Across the OECD, countries have adopted different approaches to such reviews, including reviews conducted by dedicated parliamentary committees, independent oversight bodies or ministerial authorities. The examples of Ireland and Canada are again presented in Box 8.11.
Box 8.11. Review of the lobbying framework in Canada and Ireland
Copy link to Box 8.11. Review of the lobbying framework in Canada and IrelandMandatory review of the Regulation of Lobbying Act in Ireland
Section 2 of Ireland’s Regulation of Lobbying Act 2015 provides for the periodic review of the operation and effectiveness of the Act. Under the legislation, the Minister for Public Expenditure, National Development Plan Delivery and Reform is responsible for initiating these reviews and presenting a report to Parliament, taking into account consultations with relevant stakeholders, including persons carrying out lobbying activities, representative bodies and the Standards in Public Office Commission (SIPO), which oversees the implementation of the Act. To date, Ireland has conducted three statutory reviews of the framework:
The first review, completed in 2016 and published in 2017, found generally high levels of compliance with the legislation, while stakeholders highlighted the need for additional education, guidance and support. In response, SIPO strengthened its communication and guidance activities directed at lobbyists.
The second statutory review, published in 2020, concluded that the framework was functioning effectively overall while identifying areas requiring clarification and operational improvements.
A third review was conducted in 2021-2022 and informed the adoption of the Regulation of Lobbying and Oireachtas (Allowances to Members) (Amendment) Act 2023, which introduced several amendments to the framework, including extending the interval between statutory reviews from three to five years.
In addition, the Code of Conduct for persons carrying out lobbying activities, which entered into force on 1 January 2019, is also subject to periodic review.
Mandatory review of the Lobbying Act in Canada
The Canadian federal lobbying framework provides for a mandatory statutory review of the Lobbying Act (Canada) every five years. Under Section 14.1 of the Act, a comprehensive review of both the provisions and the operation of the Act must be undertaken by a committee of the Senate, the House of Commons, or a joint parliamentary committee designated for that purpose. The committee conducting the review must subsequently report to Parliament, including any recommendations for legislative or operational changes to the framework.
In practice, the review process is generally carried out by the House of Commons Standing Committee on Access to Information, Privacy and Ethics (ETHI Committee), which hears testimony from the Commissioner of Lobbying, public officials, lobbyists, academics, civil society representatives and other stakeholders. The review typically examines whether the legislation remains effective, coherent and adapted to evolving lobbying practices, including disclosure requirements, registration thresholds, investigatory powers, post-employment restrictions and enforcement mechanisms. The Commissioner of Lobbying usually plays a central advisory role in the process by submitting formal recommendations based on operational experience administering and enforcing the Act.
The last completed statutory review took place in 2012 and resulted in several recommendations from Parliament, although no legislative amendments followed. Reviews expected in 2017 and 2022 were not carried out within the statutory timeline. A new parliamentary review was relaunched in 2026.
Source: Adapted from (OECD, 2021[3])
8.5. Proposals for Action
Copy link to 8.5. Proposals for ActionBuilding a coherent framework for transparency and integrity in lobbying and influence activities aimed at influencing government decision-making processes
The Dominican Government could adopt a lobbying regulatory framework in primary legislation that clearly specifies definitions and transparency requirements for lobbying activities.
The proposed lobbying regulatory framework could enhance transparency through a range of complementary transparency tools.
Transparency and integrity rules could be established for government advisory and expert groups, including lobbying activities targeting these groups.
Establishing a public integrity framework adapted to the risks of lobbying and influence activities for both lobbyists and public officials
The Dominican Republic could develop specific rules, standards and guidelines for public officials on their interactions with lobbyists.
The advisory bodies or units recommended in Chapter 1 could also support public officials on lobbying-related ethical dilemmas and the application of lobbying rules.
The Dominican Republic could consider developing and adopting standards of conduct which would apply to all lobbyists.
The Dominican Republic could adopt specific incentives to encourage more responsible and transparent engagement in the policymaking from companies and business associations.
Ensuring effective compliance and review of the lobbying regulatory framework
The monitoring and enforcement of a future lobbying regulatory framework could be entrusted to an oversight body with functional independence.
The Dominican Government could ensure there are adequate administrative and criminal sanctions for violations of the lobbying regulatory framework.
The Dominican Government could promote stakeholder engagement in the design, implementation and review of the lobbying regulatory framework.
References
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[11] Presidency of the Dominican Republic (2024), Constitución de la República Dominicana 2024, ConsultorÍa JurÍdica del Poder Ejecutivo, https://www.consultoria.gov.do/Services/Constitutions.
[19] Senate of the Dominican Republic (2020), 00360-2020- Proyecto De Ley Regula el Lobbusmo La República Dominicana, https://memoriahistorica.senadord.gob.do/items/4f0626f6-d38a-420d-a9b1-7b0294bb6f32.