This chapter focuses on the third priority area of Sweden’s 2024-2027 Action Plan Against Corruption and Unauthorised Influence. It provides recommendations for establishing a comprehensive legislative framework on lobbying and enhancing transparency and accountability in political financing. The chapter also examines measures to strengthen Sweden’s existing system for managing risks associated with post-public employment. Drawing on planned reforms outlined in the Action Plan and key findings from the Inquiry on Transitional Restrictions in the Public Sector and the Inquiry on Party Finance and Lobbying, it identifies strategic priorities to advance integrity and transparency in public decision-making processes.
OECD Integrity Review of Sweden
Abstract
When designing and implementing public policies, governments need to acknowledge the existence of diverse interest groups and consider the potential impacts — both favourable and adverse — on each. In practice, a variety of private interests aim to influence public policies through lobbying and other influence practices. By providing valuable insights, expertise, and perspectives, businesses, civil society, think tanks, and other interested stakeholders can provide governments with valuable information on which to base their decisions. These interactions between the public and private sector, when conducted with transparency and integrity, enhance public decision-making by helping governments understand stakeholder needs, assess policy options, and design more inclusive and effective policies. This contributes to better outcomes and strengthens the legitimacy of public institutions. Likewise, movement in and out of the public sector allows governments to benefit from a greater transfer of skills and knowledge, a process which is particularly valuable in the context of emerging and complicated global issues.
However, without adequate safeguards, public policymaking processes can be abused by interest groups in a way that seeks to manipulate or mislead decision-makers or the broader public, potentially resulting in unbalanced representation, abuse of power, unequal access to opportunities, and policies that do not always benefit our societies. These challenges are further amplified in an era of digital influence and increased geopolitical tensions where new channels, including social media and AI tools, as well as influence by foreign malign actors, pose complex risks to policymaking and electoral integrity (OECD, 2021[1]). If left unchecked, the “revolving door” phenomenon can lead to conflicts of interest among public office holders, undue influence over public policymaking, and unfair commercial advantages, particularly where public office holders move into sectors for which they were formerly responsible, or lobbyists take up positions in organisations they previously lobbied.
The OECD Recommendation on Public Integrity (OECD, 2017[2]) and the OECD Recommendation on Transparency and Integrity in Lobbying and Influence (OECD, 2010[3]) set out the main pillars for building or strengthening a coherent, comprehensive, effective and enforceable transparency and integrity system in public decision-making processes, and ensuring effective implementation and compliance. This includes granting all stakeholders, including the private sector, civil society and individuals, access to the development and implementation of public policies, instilling transparency in lobbying activities and in the financing of political parties and election campaigns, as well as 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.
Sweden maintains strong traditions of transparency and open government. Regulations establish that political parties have the obligation to report their finances regularly and to make their financial reports public, including all contributions exceeding a fixed ceiling. The Public Access to Information and Secrecy Act and the Freedom of the Press Act (1949:105) enshrine the principle of public access official documents (offentlighetsprincipen), promoting transparency and accountability in government decision-making. In practice, there is proactive disclosure of integrity-related datasets, including consolidated versions of all primary laws, the state budget for the current calendar year, the results of the last national elections, legislative proposals of the government and Government meeting agendas. Under the current Transitions Act, ministers and state secretaries are required to notify the Board for the Examination of Transitional Restrictions for Ministers and State Secretaries (Karensnämnden) when accepting employment outside the public sector.
Within this framework, significant gaps remain in the regulation of lobbying, political finance, and post-public employment. This chapter reviews strengths and opportunities for improvement with respect to strengthening transparency and integrity in public decision-making processes in Sweden. It analyses the third priority area of Sweden’s APACUI and recommends that:
The Government of Sweden could consider adopting a dedicated lobbying law to enhance transparency around influence activities, including from foreign state interests.
Ministries and agencies could be encouraged to adopt regulations setting minimum rules and transparency requirements for expert groups supporting policymaking.
Lobbying disclosure requirements could be designed to include key information such as the specific policy issue or regulatory measure targeted, the intended objectives of the lobbying activity, and any supporting materials or documentation submitted by lobbyists.
The Legal, Financial and Administrative Services Agency could be entrusted with responsibilities for overseeing and enforcing lobbying regulations and be given a mandate to conduct educational activities on lobbying activities, develop guidance on offences and corresponding sanctions.
The Transparency Act could be amended to ban anonymous and foreign donations to political parties and candidates, introduce specific third-party campaigning regulations and accounting rules, and include an explicit requirement for political parties and organisations receiving political donations to check their permissibility upon receipt.
Sweden could enhance the audit and review of the accounts of entities currently required to keep accounts under the Transparency Act, while the content of the annual financial reports could be expanded beyond revenues while political parties could be required to file separate financial reports about election campaigns.
Sweden could adopt a risk-based approach to determine the scope of public officials that should be covered by Swedish law 2018:676 (commonly referred to as the Restrictions Act).
To ensure consistency and transparency, administrations could refer cases to the Board for the Examination of Transitional Restrictions for Ministers and State Secretaries (Karensnämnden) for advice, and its decisions could be made public.
The maximum length during which restrictions may be enforced could be expanded to allow better modulation according to at-risk positions, activities and behaviors.
The data collection exercise conducted for the purpose of the Inquiry on post-public employment restrictions could be sustained and carried out at regular intervals to ensure the rules on revolving door are being observed and identify at-risk categories.
Sweden is encouraged to keep under review the use of sanctions for public officials for violations of post-public employment restrictions and could consider encouraging compliance by the private sector with post-public employment restrictions.
Sweden is a global leader on transparency and accountability of public policymaking, thereby ensuring high levels of trust in the rule of law (OECD, 2023[4]). Civil society organisations interviewed for this report confirmed that Sweden maintains a broad civic space, with strong access to information about government decision-making. They reported being frequently invited to consultations, inquiries and expert groups, including the drafting of the APACUI and 2021-2023 Action Plan. They also reported that engaging with ministries, including high-level officials, is relatively easy – for example, meeting requests with the Chair of the Constitutional Committee in Parliament are typically accepted. These groups have built a level of trust with public institutions, though they recognise it remains fragile and requires a constructively critical approach.
Interviewees also noted that Sweden’s civic space is evolving, marked by increasing professionalisation among civil society organisations (CSOs). Public funding has enabled these groups to grow and engage more effectively in shaping public policy beyond public consultations, though these consultations are increasingly seen as merely confirmatory rather than genuine opportunities for dialogue and input. The Statskontoret-led Forum for Collaboration Against Corruption was also highlighted as a good practice for public-private dialogue on anti-corruption and integrity issues, including on emerging issues related to risk areas at the interface between the public and private sectors, such as conflict-of-interest and lobbying.
While perceptions of government integrity are more positive in Sweden than the average across OECD countries, the 2023 OECD Survey on Drivers of Trust in Public Institutions shows there is still room for improvement. Although better than the OECD average (48%), 42% of respondents in Sweden believed a high-level official would likely grant a political favour in exchange for a well-paid private sector job. Only around four in ten Swedes (38%) expect that government would refuse a corporation’s demand that could be harmful to society as a whole, compared to 30% on average across OECD countries (OECD, 2024[5]; OECD, 2024[6]).
Specific elements of Sweden’s mechanisms for managing lobbying and influence could also be improved (Figure 4.1). In particular, as measured against OECD standards on political finance, Sweden fulfils 40% of criteria on regulations on political finance and 29% of criteria in practice, compared to the OECD averages of 73% and 57%, respectively. On lobbying, Sweden does not fulfil any criteria on regulations and fulfils 11% on practice, compared to the OECD average of 38% and 35%, respectively (Figure 4.2).
Note: Data from 2022. The OECD Public Integrity Indicators measure, amongst others, the quality of frameworks for accountability of public policymaking (Principle 13 of the OECD Recommendation on Public Integrity). The criteria for each indicator were established by the OECD Working Party on Public Integrity and Anti-Corruption (WP-PIAC).
Source: OECD Public Integrity Indicators, https://oecd-public-integrity-indicators.org/
Note: Data from 2022. The OECD Public Integrity Indicators measure, amongst others, the quality of frameworks for accountability of public policymaking (Principle 13 of the OECD Recommendation on Public Integrity). The criteria for each indicator were established by the OECD Working Party on Public Integrity and Anti-Corruption (WP-PIAC).
Source: OECD Public Integrity Indicators, https://oecd-public-integrity-indicators.org/
In addition, Sweden faces growing challenges from foreign interference, particularly through malign information campaigns aimed at undermining democratic institutions and public trust. According to the Swedish Psychological Defence Agency, antagonistic foreign powers employ disinformation, propaganda, and misleading narratives to sway public opinion, disrupt societal cohesion, and weaken national resilience. These threats are amplified by digital platforms and often target elections, public health, and national security debates. In response, Sweden has re-established its Psychological Defence Agency to co-ordinate efforts across government, civil society, and the media, focusing on strengthening public awareness and institutional preparedness to detect and counteract such malign influence operations (Swedish Psychological Agency, 2024[7]).
In recent years, several cases involving opaque lobbying practices, misuse of confidential information, and attempts to circumvent political finance regulations have raised concerns and underscored the need for further reforms and oversight. For example, in 2022, an investigative report by Kalla fakta, a prominent Swedish investigative journalism television programme produced by TV4, revealed that several of Sweden’s parliamentary parties were willing to suggest ways to circumvent political donation laws, which require the disclosure of donor identities for contributions above a certain threshold. Suggested tactics included splitting large donations into smaller amounts, channeling funds through intermediaries, or using foundations to keep donors anonymous. However, some parties declined to facilitate such practices and upheld the transparency rules (International IDEA, 2022[8]; The Local, 2022[9]).
Various interviewed stakeholders also highlighted recent cases that have drawn public attention due to potential risks to public integrity. One example involved a former high-ranking official serving on the board of a company that was awarded a public contract, despite not offering the most cost-efficient bid. Many such cases occur at the subnational level: interviewees mentioned cases concerning individuals serving on municipal boards while simultaneously receiving payments from lobbyists, or involving politicians facilitating the privatisation of public assets, profiting from the process, and then transitioning into the private sector after leaving office.
These cases and challenges, along with Sweden’s downward trajectory in the Corruption Perceptions Index (CPI) since 2022, have contributed to shift the political discourse on these matters, with several political parties calling for a national debate on strengthening preventative measures against corruption and undue influence. They also prompted the Swedish Government to review several aspects of its framework related to conflicts of interest, lobbying and political finance, and reflect the Government’s willingness to address particular contextual issues that have been identified in Sweden. The Swedish Inquiry on Transitional Restrictions in the Public Sector (Utredningen om övergångsrestriktioner) was established by the government in December 2022 to examine rules governing the movement of public officials to the private sector. The final report, titled Övergångsrestriktioner – ökat förtroende för offentlig verksamhet (SOU 2023:45), was published on 28 August 2023 and included proposals for cooling-off periods and clearer guidelines on post-employment restrictions for senior public officials (Government of Sweden, 2023[10]). In addition, an Inquiry Strengthening Transparency in Political Decision-Making Processes (Utredningen om partifinansiering och lobbying) was launched by the government in June 2023 to review and strengthen the regulatory framework for political financing and lobbying. The inquiry was tasked with reviewing the current regulations on transparency in party financing and to consider whether there is a need for regulations that require transparency in contacts between political decision-makers and lobbyists. The final report, titled Ökad insyn i politiska processer (SOU 2025:52), was published on 8 May 2025 (Government of Sweden, 2025[11]).
The rest of this is chapter reviews the reforms on revolving doors, lobbying, and political finance proposed in the final reports from both public inquiries. As emphasised in both reports, reforms should not hinder democratic engagement, including financial donations to political parties, efforts to influence policy decisions, or movements between the public and private sectors, but they should establish safeguards and standards to ensure that relevant interests are represented fairly and effectively in policymaking.
Lobbying enables public officials to better understand and respond to citizens and stakeholders’ evolving needs, to leverage knowledge and resources from beyond the public administration, develop innovative solutions to policy problems and their implementation, as well as achieve greater acceptance and better compliance with decisions reached’ (OECD, 2021[1]). As such, and as emphasised in the Inquiry report on increased transparency in political processes, lobbying regulations should not aim to prevent or reduce lobbying, 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[3]).
In Sweden, lobbying as a legitimate act of political participation is grounded in Chapter 2, Articles 1 to 3 of the Instrument of Government (Regeringsformen), which protects the constitutional rights of freedom of expression (yttrandefrihet) and freedom of association (föreningsfrihet). These rights ensure individuals and groups can organise, express opinions, and influence political decisions. The principle of openness (offentlighetsprincipen) further underpins transparency in public administration, allowing for scrutiny of government processes. Several legislative sources also touch upon the principles of integrity and transparency in decision-making processes, including:
The Instrument of Government (Regeringsformen) outlines the principles of public administration, emphasising the values of legality, objectivity, and impartiality in the exercise of public power.
The Public Access to Information and Secrecy Act (2009:400) and the Freedom of the Press Act (1949:105) enshrine the principle of public access official documents (offentlighetsprincipen), promoting transparency and accountability in government decision-making.
The Administrative Procedure Act (2017:900) requires objectivity and impartiality in decision-making by public authorities, helping to limit undue influence.
The Local Government Act (2017:725) regulates ethical conduct, transparency, and accountability in municipal and regional governance, addressing integrity risks at the subnational level.
The Code of Conduct for Members of the Riksdag provides ethical guidelines that apply to members of parliament, including on conflicts of interests and receiving gifts and hospitalities (Riksdag, 2022[12]).
Beyond these general legal provisions, Sweden currently lacks a specific framework that defines lobbying and lobbying activities and that could provide for transparency in lobbying. This section evaluates the relevant recommendations on the introduction of a lobbying framework in Sweden put forward in the Inquiry report and presents targeted suggestions to reinforce and enhance the proposed provisions.
4.3.1. The Government of Sweden could adopt a dedicated law and ensure the transparency of lobbying activities
Sweden currently has no law regulating lobbying activities despite its strong cultural emphasis on transparency and open governance. The principle of public access to official documents (offentlighetsprincipen), enshrined in the Public Access to Information and Secrecy Act, has long been considered sufficient to ensure public scrutiny and transparency in public decision-making processes. This cultural and legal framework fostered a belief that formal lobbying regulations were unnecessary, as open access to information was thought to mitigate undue influence (Government of Sweden, 2025[11]).
Additionally, previous governmental reports – including two inquiries in 2000 and 2016 – and parliamentary discussions concluded that lobbying itself did not pose significant challenges to democracy and that implementing formal lobbying regulations might be counterproductive. Concerns included the potential creation of an “exclusive” group of registered lobbyists, which could inadvertently limit access to decision-makers and infringe upon democratic principles such as freedom of expression and equal participation. Practical challenges related to defining lobbying activities and enforcing regulations were also cited as reasons against formal legislation. As such, the Riksdag has repeatedly rejected bills proposing a registration system for lobbyists (Government of Sweden, 2025[11]).
Since then, debates on lobbying have occurred intermittently in Sweden, reflecting significant changes in society. Notably, the public relations and public affairs industries have developed substantially, with many former public officials transitioning into lobbying roles. Additionally, growing concerns have emerged around possible conflicts of interest particularly the issue of a 'dual mandate' when MPs are involved with interest groups, and the broader role that such groups play in shaping the work of public institutions. Civil society organisations have actively engaged in these debates, including a parliamentary hearing in May 2024 focused on lobbying and health, conducted in co-operation with members of Parliament. The government’s appointment of a dedicated Committee further underscored the importance of the issue.
GRECO, in its Fifth Evaluation Round, recommended that Sweden introduce rules and guidance on how persons entrusted with top executive functions engage with lobbyists and other third parties seeking to influence governmental processes and decisions. It further advised that sufficient information be disclosed about the purpose of such contacts, including the identity of the individuals or organisations involved and the specific subject matters discussed. However, the GRECO compliance reports noted that these recommendations had not been addressed by the Swedish authorities (GRECO, 2019[13]).
In this regard, the SOU 2025:52 report marks a significant shift in Sweden's approach to lobbying regulation. Based on a survey conducted with policy makers in the Riksdag and Government and their staff, as well as consultations with professional lobbyists and stakeholder organisations, the report notes stakeholder advocacy, including contacts with policymakers, has taken on an increasingly significant role in policymaking in Sweden, and that these interactions can be exploited by certain actors to unduly influence policymaking processes. The report also notes that the principle of public access to official documents provides limited transparency over contacts between lobbyists and policymakers (Government of Sweden, 2025[11]).
Acknowledging the evolving landscape of political influence and international recommendations, the report proposes the introduction of an Act on Transparency in Communications Aimed at Influencing Policy Decisions (hereafter, “the proposed Lobbying Act”). The purpose of the proposed Lobbying Act would be to promote transparency in communications between organised stakeholders and political decision-makers in Parliament and the Government, along with their staff, when such communications aim to influence political decisions. (Article 1 – “Purpose of the law”).
In formulating its recommendations, the report draws on the experience of lobbying regulations in other countries, notably Finland, to identify best practices and potential pitfalls. It also acknowledges the need to balance increased transparency with the protection of individual privacy rights, ensuring that measures do not infringe upon freedoms of association and expression (Box 4.1). It is also commendable that the proposal draws on stakeholder surveys, government reports, and consultations with key actors to identify the categories of public officials most frequently targeted by lobbying efforts. This evidence-based approach will help ensure that the regulation is risk-focused, covers the appropriate public officials, and minimises the risk of loopholes.
Definitions (Article 2)
To avoid misunderstandings or preconceived notions of what lobbying is, the proposed Lobbying Act uses the term advocacy communications (påverkanskommunikation), defined as “contacting a policy maker or employee of a policy maker on one’s own behalf, with the aim of influencing the preparation or decisions on a case to promote a particular interest or outcome”. The definition would also cover such contacts on behalf of another person or providing advice or support to someone who has such contact if this is performed as a service in the course of business operations. Journalistic or one-off citizen contacts would be excluded to protect free expression and democratic participation.
Scope of officials covered (Article 3)
The framework would cover lobbying activities targeting Government ministers, Members of Riksdag, political secretaries to a Member of Parliament or other persons working in a party group office in Parliament, State Secretaries, certain political and non-political officials in the Government Offices of Sweden and the Riksdag Administration, as well as certain participants in special inquiries or committees of inquiry convened by the Government.
Transparency tools
The report recommends that stakeholders engaged in advocacy communication should be required to disclose certain information about their activities no later than 30 days after starting to engage in advocacy communication. This would include:
Initial registration: contact details and a general description of activities.
Quarterly activity reports, including: (i) the topics covered by the advocacy communication, (ii) the policy makers or staff members with whom the stakeholder has been in contact, (iii) the main method of contact and the approximate extent of the contact, (iv) the name of clients, if applicable.
Once a year: information on the resources used for advocacy communication during the year in terms of the number of individuals involved and the number of person-years used, as well as the cost of services purchased.
Sanctions and enforcement
The implementation of the Act would be overseen by the Legal, Financial and Administrative Services Agency. The proposal does not foresee the introduction of sanctions. As with the Transparency Act, the report considers that compliance with the Act should primarily be monitored by the public, and that any monitoring by a supervisory authority responsible for compliance with the Act should be limited. However, the proposal nonetheless includes the possibility for the supervisory authority to issue orders, including those imposing fines, in case of late registrations or incomplete or incorrect information.
Integrity standards and codes of conduct
The report states that the primary responsibility for developing ethical guidelines for those engaged in advocacy communication should rest with the professional associations representing companies in the public relations and public affairs sector. Likewise, it suggests that the Riksdag Administration and the Government Offices of Sweden should determine the extent to which members of the Riksdag, government ministers, and relevant agency staff should be subject to codes of conduct.
Source: (Government of Sweden, 2025[11])
The proposal to regulate lobbying through a dedicated law is a positive step forward and reflects a recognition that such measures are not aimed at restricting individuals’ ability to engage in lobbying activities, but rather at enhancing transparency and enforcing the right for the public to know who is trying to influence public decisions, much like the Transparency Act for Political Parties was designed to promote openness without limiting political engagement.
If Sweden adopted the Inquiry’s recommendation to introduce a dedicated lobbying law, it would bring Sweden in line with other OECD countries’ practices and with the principles embedded in the OECD Recommendation on Transparency and Integrity in Lobbying and Influence. The introduction of lobbying regulation in Sweden also presents a valuable opportunity to clearly distinguish between legal efforts to influence public policy – through transparent, accountable lobbying – and illicit practices such as influence peddling and trading in influence, which are covered in Chapter 3 of this report. By setting clear rules for disclosure and registration, such regulation will help draw a legal and normative boundary between acceptable lobbying practices and corrupt influence. However, this distinction does not fully eliminate the risk of undue influence occurring within legal lobbying practices, especially where access is unequal, transparency is limited, or informal lobbying practices are abused by means of providing covert, deceptive or misleading evidence or data, or manipulating public officials by hiding the origin of the influence (OECD, 2010[3]).
Currently, around half of OECD countries have defined lobbying activities and which actors are considered lobbyists in their regulatory framework, and 17 OECD countries have a publicly available lobbying register (OECD, 2024[14]). The experience from these countries shows that well-designed lobbying regulations do not inhibit civic space or the legitimate activities of stakeholders, and can offer benefits including enhanced public awareness of lobbyists’ efforts to raise certain interests. (OECD, 2021[1]). Indeed, the OECD's interviews with various civil society and private-sector stakeholders in Sweden suggested a consensus on the need to strengthen transparency in lobbying activities in Sweden. In particular, none of the private sector or civil society representatives interviewed in Sweden for this report opposed the proposal to establish a lobbying register. Some even expressed strong support for this proposal.
4.3.2. The proposed Lobbying Act could include a periodic review mechanism to respond to developments in lobbying and progressively expand its scope to cover a wider range of relevant influence actors, activities and targets
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[3]). The proposed Act could therefore establish a periodic and mandatory review process of the Act as well as a representation and consultation mechanism that would allow the supervisory body to make timely recommendations to a committee or any appropriate body of the Riksdag.
This mandatory review process is particularly important as the Inquiry report considers that certain aspects of the Act – such as coverage of the local level or the introduction or sanctions – should be examined or re-assessed at a later stage, based on a robust monitoring of developments in this area and taking into account the lessons learned from the implementation of the initial regulation. Inspiration could be drawn from the Canadian and Irish legislation, which incorporates provisions for a regular review mechanism (Box 4.2).
Canada
In Canada, Article 14 of the Lobbying Act requires a comprehensive review of the provisions and operation of the Act every five years by a committee of the Senate, of the House of Commons, or of both Houses of Parliament, that may be designated or established for that purpose. The Committee must, within a year after the review is undertaken, submit a report on the review to Parliament that includes a statement of any changes to the Act or its operation that the Committee recommends.
Ireland
In Ireland, Section 2 of Regulation of Lobbying Act provides for regular reviews of the operation of the Act by the Minister for Public Expenditure, National Development Delivery and Reform. When conducting the review, the Minister must engage in consultations with key stakeholders, including persons carrying out lobbying activities and the bodies representing them.
The first review of the Act took place in 2016 when the Act had been in operation for a year. The report found a high level of compliance with legislative requirements and no recommendations were made by the government for amendments of the Lobbying Act. However, lobbyists highlighted the need for further education, guidance and assistance, which led the oversight authority, the Standards in Public Office Commission, to review its communication activities and guidance to lobbyists.
A second review took place in 2019, and a third review in 2022 following which the Minister proposed a Lobbying Amendment Bill 2022. Following the passing of the bill in June 2023, subsequent reviews must take place every five years.
Source: Canada Lobbying Act, https://laws-lois.justice.gc.ca/eng/acts/l-12.4/; Ireland Regulation of Lobbying Act, https://www.irishstatutebook.ie/eli/2015/act/5/enacted/en/html
Ultimately, these regular reviews of the proposed Lobbying Act should aim to ensure all relevant actors, activities and targets are kept within scope of the law. Indeed, the proposed Lobbying Act includes a definition of “advocacy communications” and specifies the targets of these communications (Box 4.1); however, in some important respects, these provisions could be expanded to avoid the risk that certain lobbying and influencing activities will not be captured under the framework.
Experience from other countries has found that providing effective definitions remains a challenge, in particular because those who seek to influence the policy-making process are not necessarily what might typically be considered lobbyists. Indeed, avenues by which interest groups influence governments extend beyond the classical definition of lobbying and moreover, have evolved in recent years, not only in terms of the actors and practices involved but also in terms of the context in which they operate (OECD, 2021[1]). To address this challenge, when setting up lobbying regulation, it is essential that the definition of lobbying activities be both specifically tailored and sufficiently clear, comprehensive, and robust to prevent misinterpretation and close potential loopholes (OECD, 2010[3]). This includes clarifying: (i) who is considered a lobbyist / interest representative; (ii) what types of activities are considered as lobbying / interest representation; (iii) the types of decisions that are targeted by lobbying; and (iv) the categories of public officials that are targeted by lobbying.
The inquiry report notes that, in several respects, the cautious design of the framework is intentional, given that such regulation would be new in Sweden. It recommends that these aspects be re-evaluated after the legislation has been in force for some time, to determine whether amendments or an expansion of scope are warranted. As such, the following recommendations could be incorporated into the proposed Lobbying Act to be presented to Parliament, or included in future revisions, in line with the OECD Recommendation and to reflect evolving lobbying and influence practices.
Levels and branches of government covered by the Act
In terms of institutional scope, the proposed Lobbying Act does not extend to the local level or the judiciary. This is consistent with international practice, as few countries include these branches in their lobbying regulations. Among OECD countries, only 5 – Austria, Chile, Greece, Lithuania, and Slovenia – require transparency for lobbying activities directed at the judiciary. Only six OECD countries – Austria, Chile, France, Ireland, Lithuania, and Slovenia – have national lobbying regulations that also apply at the regional and local levels.
In Sweden, the Committee considered that since the legislation would be introduced in a previously unregulated space, representatives of administrative authorities, state-owned companies or courts, as well as policymakers at regional and local level, should not immediately be included in the regulatory framework as recipients of advocacy, but could be at a later stage after the regulatory framework has been in force for some time. It is recommended that the Government of Sweden consider including these actors in future revisions of the Act as these types of office holder also maintain extensive contacts with influence actors, and the risks of conflicts of interest and inappropriate behaviour are just as significant for these actors as those currently in scope of the draft law.
Establishing an institutional framework that applies equally to lobbying activities directed at both the national and local or municipal levels would ensure that public decision-makers, lobbyists, and citizens across Sweden are subject to a consistent legal framework. This would enhance coherence, improve clarity, and help prevent the emergence of fragmented or divergent regulations at different levels. France has adopted this approach by extending its lobbying regulatory framework – initially introduced in 2016 and implemented in 2017 – to the local level as of 1 July 2022. This extension includes regional presidents and mayors of cities with more than 100 000 inhabitants. As a result of this broader scope, the French lobbying register has become one of the largest in the world, ultimately encompassing around 18 000 public officials (HATVP, 2022[15]).
The application of the proposed Lobbying Act could then be modulated according to various institutional levels. For example, activities relating to individualised decisions (grants, permits, licences, certificates or other authorisations) could be excluded in small municipalities in favour of decisions of general application (normative acts, standards, guidelines, programmes and action plans). In a less restrictive approach, consideration could be given to establishing thresholds for contracts, financial contributions, permits or other authorisations granted by a municipal body, such as representations made as part of an administrative process established under a defined programme for obtaining a grant, financial assistance, loan, loan guarantee or bond in an amount below a pre-determined threshold.
Lastly, there is increasing evidence from OECD countries that lobbying activities target specific categories of judicial officials, including members of supreme courts, administrative courts, and, where applicable, elected judges (OECD, 2021[1]). While there have been no recent cases indicating that lobbying activities in Sweden explicitly target judges or judicial nominations to exert undue influence, it would be prudent to monitor lobbying practices and consider extending coverage to certain actors if the risks or practices evolve (for example members of the Supreme Court of Sweden (Högsta domstolen) or the Supreme Administrative Court of Sweden (Högsta förvaltningsdomstolen).
Public officials targeted by advocacy communications
With regards to public officials targeted by advocacy communications, the definition in the proposed Lobbying Act provides a coherent approach to transparency as it would cover Ministers, Members of Parliament, as well as their staff and political advisors. 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[16]).
However, certain categories of public officials mentioned in the proposed Lobbying Act, such as “other employees in the Riksdag Administration,” “other employees in the Government Offices,” and “political experts or other political officials in the Government Offices”, are not clearly defined. These categories could benefit from further clarification, either within the draft legislation itself or through subsequent implementing regulations. In addition, given the prominence of government agencies in the Swedish public administration and their broad role and autonomy in policy execution, heads of agencies and other relevant high-risk positions within these bodies could be included in the framework from the outset. Agencies could also be given the possibility to determine which categories of public officials within their bodies should, by virtue of their function or position, be covered by the framework. Such a system exists in Chile and allows the transparency framework to be adapted to sensitive sectors and at-risk roles within the public administration, such as procurement officials in specific ministries (Box 4.3).
To 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[17])
Public decisions targeted by advocacy communications
With regard to public decisions targeted by advocacy communications, the proposed Lobbying Act could be clarified, as the proposal only mentions the preparation or decisions on a case, without further defining the terms “decisions” or “case”. In other OECD countries relevant public decisions include:
The amendment, defeat, repeal, implementation and evaluation of primary legislation and legislation, as well as policies and programmes;
The awarding of any grant, contribution or other financial benefit, as well as the awarding of any government contract (OECD, 2021[1]).
Indeed, influence 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. While rules for transparency and integrity in lobbying and influencing do not need to cover all the risks set out in Table 4.1 (as other policies and regulations can contribute to a culture of transparency and integrity in public policymaking processes), a comprehensive legislative framework mitigates the risk of undue influence at all stages of the policy cycle. As such, the proposed definition could be revised to more clearly specify which specific public decisions and phases of the policy cycle would be covered. The examples of Canada and Chile are provided in Box 4.4.
Note: The blank square reflects that the legislature is not involved in policy implementation.
Source: (OECD, 2017[18])
Canada Lobbying Act
Development of any legislative proposal.
Introduction, defeat or amendment of any Bill or resolution.
Making or amendment of any regulation.
Development or amendment of any policy or programme.
Awarding of any grant, contribution or other financial benefit.
Awarding of any contract (Consultant lobbyists only).
Chile Lobbying Act
The drafting, enactment, modification, repeal or rejection of administrative acts, bills and laws, as well as the decisions adopted by designated public officials.
The elaboration, processing, approval, modification, repeal or rejection of agreements, declarations or decisions of the National Congress or its members, including its commissions/committees.
The conclusion, modification or termination in any way of contracts entered into by the designated public official and which are necessary for their operation.
The design, implementation and evaluation of policies, plans and programmes carried out by designated public officials.
Source: (OECD, 2021[1])
Covering the appointment of certain persons to a key position within government is also good international practice and could be included in Sweden’s framework. Indeed, decisions on the appointment of certain public officials can 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. To mitigate risks of undue influence from powerful interest groups in the nomination process, e.g. in France, the appointment of certain public officials – usually appointments to a position subject to confirmation by Parliament – is considered a type of decision covered by lobbying activities and is therefore covered by transparency requirements (OECD, 2021[1]). In Sweden, this could cover the appointment of the Prime Minister, specific high-level positions (e.g., Supreme Court and Supreme Administrative Court Justices, Auditor General, Chancellor of Justice) as well as heads of agencies. This list could be aligned with Chapter 1, Section 9 of the Act (2017:630) on Measures Against Money Laundering and Terrorist Financing, which identifies specific categories of public officials holding “prominent public functions.”
Regarding the awarding of public contracts, it might not necessarily be relevant to advocacy communications targeting all phases of award and tendering processes, provided these phases are covered by specific regulations and transparency requirements (as further analysed in Chapter 7 of this report). At a minimum, the needs definition and procurement planning stages are usually covered, as shown by the French example in Box 4.5.
In France, certain communications relating to competitive tendering procedures on the basis of Article 42 of Order No 2015-899 of 23 July 2015 on public contracts or Article 36 of Order No 2016-65 of 29 January 2016 on concession contracts are not covered by the framework regime.
Thus, the head of a company specialising in IT security, who approaches the office of the Minister of Defence to convince him of the need to launch a public procurement contract for the acquisition of data encryption technology with a view to reinforcing the security of the ministry's information systems, is carrying out an action of representation of interests. On the other hand, once the Ministry launches the competitive tendering procedure, its relations with this company and with the other candidates, until the contract is signed, are excluded from the scope of representation of interests, as are the relations that will be established with the selected candidate for the execution of the contract.
Source: (OECD, 2022[19])
Actors conducting advocacy communications
While the proposed Lobbying Act does not explicitly provide a definition of lobbyists, Article 4 mentions that any legal person or self-employed lobbyist engaging in advocacy communications would be required to register. The proposed Lobbying Act is drafted in a way that would be sufficiently broad to capture comprehensively and equally all the actors who aim to influence decision-making processes, whether for-profit or not-for-profit. However, the Inquiry report also specifies that only advocates with a certain degree of organisation and long-term engagement should be covered, and Article 1 of the proposed Lobbying Act refers to “organised stakeholders”. It is unclear from this statement whether this means that only professional lobbyists or individuals who are specifically remunerated to conduct lobbying activities would be covered by the Act.
The OECD Recommendation on Transparency and Integrity in Lobbying and Influence encourages a broad definition of lobbyists, extending beyond professional or paid actors to include a wider range of individuals and organisations engaged in influencing public decision-making (OECD, 2010[3]). 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.
Accordingly, the proposal could clearly define the scope of actors covered and allow for the inclusion of a broad range of stakeholders, not only those traditionally seen as organised “lobbyists”, as well as both remunerated and non-remunerated lobbying activities.
This does not preclude the Act from incorporating exceptions or tailored disclosure requirements that take into account the capacities and resources of different interest groups. Such adaptations will be essential, should the Act be expanded at the local level at a later stage, to ensure that compliance does not impose an undue administrative burden, particularly on small citizen organisations with limited resources or those made up primarily of volunteers, thereby safeguarding fair and equitable access to government. To that end, specific thresholds could be established and assessed at the level of the entity conducting lobbying activities – such as the number of employees or the time devoted to preparing, organising, executing, and following up on such activities. However, it is crucial that these thresholds are clearly defined to avoid excessive ambiguity, are not easily circumvented, and do not inadvertently exclude infrequent but potentially highly influential lobbying efforts.
Activities considered as advocacy communications
In terms of communications considered as lobbying activities, the current definition in the proposed Lobbying Act would be limited to “contacts”, although the proposal does not specify whether such contacts would be both planned oral communications – such as planned meetings – as well as more informal or ad hoc communications, such as written communications (email exchanges, WhatsApp messages) or impromptu meetings in which interest representation activities subsequently take place. In addition, a narrow focus on lobbying contacts would also leave out other new forms of influence, such as the use of social media and other communications campaigns as a lobbying tool.
Indeed, indirect forms of lobbying, often referred to as “grassroots lobbying”, which involves mobilising public pressure on policymakers, is often conducted and funded by well-resourced actors, and can be as influential as, or even more than, direct lobbying. While few lobbying regulations currently cover these activities across the OECD, many countries are considering whether these activities should be included in the framework, given their prevalence in the current lobbying and influence landscape, and their impact. In addition, regulating such activities would not infringe on freedom of expression or assembly; rather, it would promote transparency by requiring disclosure of who is behind campaigns aimed at influencing public policy (OECD, 2021[1]). As such, the OECD Recommendation encourages countries to encompass all forms of lobbying – including indirect and influence-driven activities – to ensure consistent standards of accountability and to prevent regulatory loopholes (OECD, 2010[3]).
Business and civil society representatives interviewed for this report confirmed that the rise of social media has significantly transformed how influence is exerted in Sweden. Social media platforms are increasingly used to mobilise public support, amplify advocacy campaigns, and directly engage with policymakers. This digital shift has lowered barriers to participation, enabling a broader range of actors, from grassroots movements to corporate stakeholders, to shape policy debates in real time and with greater immediacy than traditional lobbying methods. In subsequent revisions, consideration should therefore be given to the expansion of advocacy communications to indirect forms of lobbying, going beyond direct contacts. Box 4.6 provides an overview of OECD member experience in setting out clear and comprehensive definitions on lobbying.
Canada
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 mean 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[1])
Exceptions and exemptions
Definitions should clearly specify the type of communications with public officials that are not considered “lobbying”, as well as the type of “actors” that are not considered as “lobbyists”. For example, diplomatic and consular officials, natural persons acting in a strictly personal capacity and not in association with others, journalists or contributors publishing content under the editor-in-chief’s responsibility of any print or digital publication, public officials acting in their official capacity, as well as political parties acting within the framework of political party regulations, should not be covered by the scope of lobbying regulations. Similarly, communications already subject to a legal framework that ensures transparency, such as participation in a public consultation where relevant information is published, could be excluded from the lobbying framework. Influence activities exercised by foreign governments through formal diplomatic channels, communications between public authorities, as well as the provision of legal advice and representation by lawyers or any other professionals when advising clients about administrative or judicial proceedings, should also not be covered (OECD, 2021[1]).
All these exceptions are included in Article 4 of the proposed Lobbying Act, which aligns with OECD standards. The proposed Lobbying Act would also exclude contacts whose disclosure could jeopardise national security, public order and safety, or the life or health of an individual, which aligns with good international practice.
However, there are certain exceptions and exemptions in the proposed Lobbying Act that could be revised or clarified. For example, the Committee proposes that normal errands carried out by an individual or a company at a government agency be excluded from the obligation to provide information. The Act does not specify, though, what a “normal errand” means. If this means requests for factual information by individuals or companies, for example, when they consist of enquiring about the interpretation of a law, or when they are intended to inform a client on a general legal situation or on his specific legal situation, then this could be more clearly specified.
4.3.3. The proposed Lobbying Act could explicitly cover advocacy communications conducted on behalf of foreign state interests
An increasing number of foreign governments rely on lobbyists and other lobbying actors to promote their policy objectives instead of relying on traditional and formal diplomatic channels. The actors and activities involved are in many ways similar to “traditional” lobbying and influence practices from businesses and other interest groups. For example, foreign governments may engage lobbying, law and public relations firms, or former public officials of the country, to conduct lobbying and influence on their behalf. They may also fund grassroots organisations, foundations, academic institutions and think tanks to produce evidence supporting their goals, as well as provide gifts and other benefits (such as sponsored trips) to journalists and decision makers. Foreign governments may also use affiliations to state-sponsored media services or state-owned corporations as channels of influence (OECD, 2021[1]).
Foreign influence, much like traditional lobbying, can be a legitimate and constructive part of public policymaking, provided it is carried out transparently and accountably. However, in the absence of appropriate safeguards, it can also serve as a conduit for foreign interference. In recent years, concerns about deceptive or covert lobbying and influence efforts have brought this issue back into the spotlight (OECD, 2021[1]; OECD, 2024[20]). In response, many OECD countries have taken steps to increase transparency over lobbying and influence activities conducted on behalf of foreign governments as part of their broader efforts to counter covert foreign influence and foreign interference. Certain lobbying registers in force in OECD jurisdictions already cover some of the lobbying and influence activities carried out on behalf of foreign governments or entities linked to them. Other countries have opted for a separate transparency register covering a wider range of influence actors and activities (Box 4.7).
United States
The Foreign Agents Registration Act (FARA), in place since 1938, is often referred to as the oldest lobbying law. It aims to ensure transparency around foreign efforts to influence U.S. policy and public opinion through lobbyists or other intermediaries, and to help the public and lawmakers understand who is behind such activities and assess potential national security risks. The Department of Justice maintains the FARA register, which is separate from the Lobbying Disclosure Act (LDA) register.
Australia
Australia's Foreign Influence Transparency Scheme (FITS), introduced in 2018, requires public disclosure of activities undertaken on behalf of foreign state interests that aim to influence federal politics or government. The scheme is not intended to restrict, deter or criminalise lawful activities but makes such foreign-linked efforts visible. It operates separately from the lobbying register established under the Lobbying Code of Conduct, but both are administered by the Attorney-General’s Department.
United Kingdom
The Foreign Influence Registration Scheme (FIRS), created under the National Security Act 2023, aims to enhance transparency and protect national interests by requiring disclosure of certain activities carried out on behalf of foreign powers. Launching on 1 July 2025, it will be managed by a Home Office unit and operate separately from the lobbying register established under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014, managed by the Office of the Registrar of Consultant Lobbyists.
Canada
Any person who, for a fee, engages in lobbying activities – within the meaning of the Canadian Lobbying Act – on behalf of “any government other than that of Canada”, is required to register in the Registry of Lobbyists. The creation of a specific Canadian Foreign Influence Transparency and Accountability Act (FITAA) was included as Part IV of Bill C-70, the Countering Foreign Interference Act, enacted in June 2024. The FITAA itself has not yet entered into force.
France
France's Foreign Interference Law, promulgated on 1 July 2024, introduces a Foreign Influence Register managed by the High Authority for transparency in public life (HATVP), which also manages the existing register of interest representatives. The register is scheduled to become operational on 1 October 2025.
European Union
The 2021 Interinstitutional Agreement on a common transparency register excludes third-country authorities, including their diplomatic missions and embassies, unless they are represented by “legal entities, offices or networks without diplomatic status or are represented by an intermediary”, who must register and disclose their interest representation activities targeting EU institutions.
In December 2023, the European Union also presented a proposal for a Directive that would establish harmonised requirements in the internal market regarding the transparency of interest representation activities carried on behalf of third countries. As of May 2025, the Directive remains under negotiation and the adoption timeline remains uncertain.
Source: (OECD, 2024[20])
Building on these evolving international good practices, the OECD Recommendation encourages countries to strengthen transparency and openness of lobbying and influence activities in public decision-making processes, including from foreign state interest actors (OECD, 2010[3]). As with “traditional lobbying”, transparency obligations are not intended to restrict, deter, criminalise or punish legal foreign influence activities. On the contrary, transparency aims to highlight legal activities carried out for the benefit of foreign interests, and thus avoid any opacity or risk of interference.
The proposed Lobbying Act specifies that advocacy communications conducted by foreign governments and international intergovernmental organisations should be exempted from disclosure requirements when advocacy communications take place within the context of such co-operation or normal diplomatic relations. This is aligned with international best practices and the OECD Recommendation, which explicitly excludes influence activities exercised by foreign governments through formal diplomatic channels.
However, the exemption could be revised to clarify that when advocacy communications on behalf of foreign governments are conducted by legal entities, offices or networks without diplomatic status or by an intermediary, they should be registered in the lobbying register. This will ensure some level of transparency over advocacy communications conducted on behalf of foreign governments and support the Swedish Government’s recent efforts to address foreign interference risks. This includes the 2023 Foreign Direct Investment Act, which introduces a screening mechanism for foreign investments in sensitive sectors, and a 2024 proposal requiring non-EEA entities to obtain permits for acquiring strategically located properties. Additionally, the 2023 Foreign Espionage Act criminalises sharing sensitive information that could harm Sweden’s international relations, and the 2022 re-launch of the Psychological Defence Agency aims to counter foreign disinformation.
Alternatively, the Swedish Government could also consider establishing a separate foreign influence register alongside the register of interest representatives suggested in the proposed Lobbying Act. This approach would allow for a clear distinction between a register of interest representatives and a foreign influence register, the latter being more explicitly focused on national security and potentially encompassing a wider range of influence actors and activities.
4.3.4. To implement the Lobbying Act’s provision on working group participation, ministries and agencies could adopt regulations setting minimum transparency rules for expert groups supporting policy making
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 (OECD, 2021[1]; OECD, 2010[3]). These groups can be permanent or set up on an ad hoc basis to respond to needs in a specific period.
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.
In Sweden, the government frequently engages external experts through various advisory and expert groups to inform policymaking. These include temporary Government Commissions of Inquiry (SOU) composed of academics and specialists tasked with investigating specific issues, as well as standing bodies like the Swedish Climate Policy Council and advisory boards within agencies such as the Public Health Agency. Additionally, temporary expert panels are formed to address emerging challenges, exemplified by COVID-19 response groups.
The proposed Lobbying Act would include exceptions on registration requirements for participation in a working group, inquiry or similar appointed by the Government or Riksdag in which participation is documented in a separate system, with the opportunity for the public to access the documentation. Sweden is encouraged as part of this step to include provisions in the law that balance safeguards against special interest groups capturing or imparting biased advice to government with the right of external parties to represent their interests, preserving the valuable contributions such participation brings to policymaking. To ensure effective implementation and compliance, ministries and agencies could be encouraged to adopt implementation regulations (föreskrifter) or guidelines establishing minimum procedural rules and transparency requirements aligned with the law’s broader provisions. The Transparency Code for working groups in Ireland (Box 4.8) may serve as a useful example.
In 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
4.3.5. The disclosure requirements in the proposed Lobbying Act could be expanded to include the policy issue or regulatory act concerned, the objectives, and any supporting documentation received from lobbyists
A critical element for enhancing transparency in public decision-making, as strongly emphasised in the Inquiry report, is to provide mechanisms and tools through which public officials, business and civil society can obtain sufficient information regarding who has had access to public decision-making processes and on what issues. Such mechanisms should ensure that sufficient, pertinent information on key aspects of lobbying activities is disclosed in a timely manner, with the aim of enhancing public oversight of the information, advice, and influence shaping policymakers’ decisions (OECD, 2010[3]). This is particularly important in the context of Sweden, where public scrutiny has been proposed as the primary enforcement mechanism. For this to be effective, sufficient information must be available in the public domain.
The transparency measures introduced by OECD countries generally assign the burden of disclosure to lobbyists through a lobbying registry, which is also the suggested approach in the proposed Lobbying Law. The requirement to submit quarterly reports is consistent with international good practices. Mandating quarterly or semi-annual disclosures of lobbying activities strikes a reasonable balance between ensuring transparency and minimising the compliance burden for lobbyists. Canada remains the only jurisdiction where lobbyists are required to file monthly reports. Additionally, the obligation in the proposed Lobbying Act to submit annual information on the resources allocated to advocacy communications is a sound approach: it reduces the administrative burden on interest representatives while enabling alignment with their financial reporting cycles.
These provisions could be strengthened further by expanding the content of the quarterly reports to include the specific policy issue or regulatory act concerned, the objectives, and any supporting documentation received from lobbying and influence actors (OECD, 2010[3]). This would enable stakeholders – including civil society organisations, businesses, the media and the public – to fully grasp the scope and depth of these activities. Requiring the disclosure of expert reports and position papers submitted by interest representatives to public officials, as is the case in Germany, would also be fully consistent with Sweden’s longstanding principles of openness and transparency. These principles are foundational to the functioning of Swedish public administration, ensuring that the public and the media have meaningful access to information about the activities of state and municipal authorities.
Additional disclosures could include, for natural persons and individual lobbyists listed in the register, any previous government employment – detailing the position title, the ministry or agency, the specific branch, unit, or department, and the period of service. Such information is already disclosed in countries like Canada, Ireland, and Germany. Requiring this would enhance transparency and facilitate better tracking of the "revolving door" between the public and private sectors.
Another important disclosure could relate to sources of financing, including funding from government (both domestic and foreign). For example, Canada’s Lobbying Act requires lobbyists to disclose “any government funding received, the name of the government or agency providing funding, and the amount of funding received”. Expanding transparency to include private sources of funding would help distinguish genuine grassroots advocacy from astroturfing – a practice of creating or funding citizens' associations or organisations to give the false appearance of broad public support for a policy, thereby indirectly influencing decision-making. These campaigns often present themselves as spontaneous and citizen-led, while actually promoting positions aligned with specific industries or interest groups. To counter this, the EU Transparency Register requires think tanks, research centres, and academic institutions to declare their sources of funding. Organisations must either link to a webpage with this information or disclose it directly in the register if not otherwise publicly available. Requiring similar disclosures would help ensure a clearer understanding, for the Swedish government and public alike, of the interests behind advocacy efforts and enhance the credibility of the lobbying register.
Lastly, given that contributions to political parties and candidates by legal persons are permitted in Sweden, interest representatives could also be required to disclose any political contributions. Similar requirements exist in countries such as Slovenia, where they enable cross-checking to ensure consistency between data in lobbying registers and reports from political parties and candidates. For example, Germany’s lobbying register, which includes detailed information that aims to reveal the nature of the influence that interest representatives seek to exert, could serve as an example for Sweden (Box 4.9).
On 1 January 2022, Germany’s first lobbying register at the federal level entered into force. Building on this, the German Bundestag agreed on a reform of the Lobbying Register Act in 2023, which entered into force on 1 March 2024. A key aim of the reform was to reveal the substance of lobbying efforts. To that end, the Act provides for the following disclosure of information:
Information on the specific policy or act targeted: registrants must provide particulars of all current, planned or intended federal or EU regulatory proposals to which lobbying of the German Bundestag or the Federal Government relates.
Written comments and expert opinions: registrants must disclose essential written comments and expert opinions on the specified regulatory projects which have been submitted to the German Bundestag or the Federal Government. The documents are to be anonymised and uploaded as PDF files, in addition to which their text is to be machine-readable. Comments and expert opinions are exempted from the uploading requirement if they are published as part of formal involvement processes administered by the Federal Government or the Bundestag, the aim being to avoid duplication of effort on the part of representatives of special interests. The disclosed information will remain visible for eight years.
Lobbying expenditures: persons and organisations included in the register are obligated, without exception, to disclose their financial expenditure related to interest representation activities. This includes details on grants and subsidies from the public sector and donations and other lifetime benefits from third parties.
Gifts with sponsoring benefits are now incorporated and the aggregate sum of donations received must be reported in EUR 10 000 increments. The naming of individual donors is only required if the donations of a donor exceed the total annual value of EUR 10 000 and at the same time 10% of the total donation amount.
Revolving door information: individuals listed must provide details of their current or previous affiliations with the German Bundestag or government offices as well as employment relationships in the federal administration.
Source: (German Bundestag, 2025[21])
4.3.6. The Legal, Financial and Administrative Services Agency could enforce the proposed Lobbying Act, and be given an educational mandate
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[3]). At the OECD level, all countries with a transparency register on lobbying activities have one or several institutions responsible for monitoring compliance. While the institutional set-up varies greatly among countries, most of these bodies or functions monitor compliance with disclosure obligations and whether the information submitted is accurate, presented in a timely fashion and complete (OECD, 2021[1]).
The proposed Lobbying Act designates the Legal, Financial and Administrative Services Agency (Kammarkollegiet) as the primary oversight body. This is a logical and appropriate choice, given the agency’s well-established operational independence from ministerial control, consistent with Sweden’s administrative tradition of autonomous public authorities. Moreover, the agency’s existing responsibilities in areas such as financial oversight and legal administration position it well to facilitate cross-checks between lobbying disclosures and political finance data, thereby strengthening transparency and accountability across related domains.
To support effective implementation of the Lobbying Act, and in line with the OECD Recommendation, the Legal, Financial and Administrative Services Agency (Kammarkollegiet) could also be given an explicit educational mandate. This would enable the agency to raise awareness of lobbying rules and ethical standards among both lobbyists and public officials. By providing guidance, training, and informational resources, the agency will be able help ensure that all stakeholders understand their obligations, reduce the risk of non-compliance, and promote a culture of integrity and transparency in lobbying practices (OECD, 2010[3]).
4.3.7. The proposed Lobbying Act could include a gradual system of administrative sanctions but provide for a familiarisation period during which the sanctions would not apply
Sanctions should be an inherent part of the enforcement and compliance setup and should first serve as a deterrent and second as a last resort solution in case of a breach of the lobbying regulation. The proposed Lobbying Act currently does not foresee the introduction of sanctions, as the Committee considered that compliance with the Act should primarily be monitored by the public. However, the proposal nonetheless includes the possibility for the supervisory authority to issue orders, including imposing fines, in case of late registrations or incomplete or incorrect information. This is aligned with good practice and the experience from OECD countries, which shows that formal notices sent to lobbyists encourages compliance without the need to resort to enforcement, and helps to create a common understanding of expected disclosure requirements. Administrative monetary penalties also help to promote compliance and resolve cases of late submission or failure to register (OECD, 2021[1]).
To further strengthen the proposed framework, the Lobbying Act could benefit from a more detailed and clearly defined list of offences. It could also mandate the Legal, Financial and Administrative Services Agency to develop guidance on offences and corresponding sanctions. International experience from OECD countries, shows that public scrutiny alone is insufficient to ensure compliance; effective enforcement requires sanctions that are fair, objective, proportionate, timely, and above all, dissuasive. Sanctions must carry a sufficient deterrent effect to encourage compliance, as overly lenient penalties are often perceived as inconsequential by those subject to them, a common challenge across OECD jurisdictions. Given that lobbying regulation would be a new development in Sweden, the Act could also provide for a transitional or familiarisation period of at least one year during which sanctions would not be applied. This would give lobbyists and other stakeholders adequate time to understand and adjust to the new requirements without the immediate risk of penalties, helping to build compliance through education and engagement rather than enforcement alone.
Like lobbying, political finance is a legitimate and necessary component of the democratic process through enabling the expression of political support and competition in elections. It is also a necessary resource for candidates and parties to run for office and diffuse ideas and manifestos. However, without the necessary guardrails, efforts to influence election processes through political contributions can also pose significant risks to the integrity of decision making, as money may become an instrument of undue influence and policy capture (OECD, 2017[18]). As such, ensuring transparency and integrity in the financing of political parties and electoral campaigns is crucial to effective policymaking and strong democracies (OECD, 2017[2]).
Until 2014, transparency in the financing of political parties in Sweden was governed by voluntary agreements between the parties and the Riksdag. That year, a more formal framework was introduced through the Act on Transparency in the Financing of Political Parties (2014:105), which required political parties participating in elections to the Riksdag or European Parliament or receiving public funding under the law on state support to political parties (1972:625), to report on the sources of their political financing. In 2018, this legislation was replaced by a more comprehensive framework through the Act on Transparency in the Financing of Political Parties (2018:90). The new Act extended the reporting obligations to parties operating at regional and local levels, as well as to affiliated side organisations. It also introduced a ban on anonymous donations exceeding 0.05 of the price base amount1, strengthening safeguards against opaque political financing.
A political debate on party financing rules was nevertheless sparked by a media investigation revealing that five of the eight political parties were willing to circumvent the current regulations on anonymous donations (International IDEA, 2022[8]). The 2023 OECD Survey on Drivers of Trust in Public Institutions showed that political parties are the least trusted institution in Sweden, with only 31% expressing confidence in them, significantly lower than trust in the police (69%), judiciary (64%), and the national government (43%) (OECD, 2024[6]).
The lack of transparency around political finance has previously been highlighted by GRECO, and Sweden has since been found to be non-compliant with GRECO’s recommendations (GRECO, 2019[13]). The OECD Public Integrity Indicators also show that Sweden remains behind many other OECD countries in this area, fulfilling only 40% of the OECD standards on regulations and 29% of the criteria in practice—well below the OECD averages of 73% and 58%, respectively (Figure 4.3).
Note: This set of indicators covers regulations and practice related to political finance. The criteria are from the OECD Public Integrity Indicators’ datasets on “Regulatory framework for transparency in lobbying, conflict-of-interest and political finance” and “Use of oversight and prevention mechanisms for financing of political parties and election campaigns”. Data is currently available for 2022 and 2023 for OECD members and 2024 for non-OECD members. The criteria for each indicator were established by the OECD Working Party on Public Integrity and Anti-Corruption in Government (WP-PIAC).
Source: OECD Public Integrity Indicators, https://oecd-public-integrity-indicators.org/
In light of these challenges, the Inquiry Committee reviewed the current Act on Transparency in Political Party Financing (2018:90) to assess whether there is a need to clarify the ban on anonymous donations, require separate fundraising organisations to maintain accounts, require accounts to include records of expenditures, assets, and liabilities, amend regulations on independent auditing, prohibit or specially regulate foreign donations, and introduce specific transparency or consent requirements for donations made by labour market organisations to political parties (Government of Sweden, 2025[11]). This section reviews the above-mentioned proposals by the Committee and provides recommendations to better align Sweden’s framework for political finance transparency with OECD standards and international best practices.
4.4.1. The Transparency Act could be amended to ban anonymous and foreign donations
Anonymous contributions, particularly in countries like Sweden where private donations are a major part of political funding, raise the risk of policy capture and undue influence as they do not allow for scrutiny of the sources of funding nor an assessment of the lawfulness of donations. They also prevent thorough scrutiny and analysis of donation patterns, such as tracking donation volumes by sector or assessing the proportion of funding certain donors provide to political parties (OECD, 2016[22]).
Under Sweden's Transparency Act, parties and candidates cannot accept anonymous donations over 0.05 price base amounts (SEK 2 940 in 2025). Donations are considered anonymous if the donor’s identity is unknown and hard to determine. Donations over SEK 29 400 (0.5 price base amounts) must be reported with the donor’s name and ID or address. Multiple donations from the same person in a year must be combined and reported as one. Records must be kept to track and aggregate donations, including small anonymous ones below the threshold. Donations under SEK 294 (0.005 price base amounts) are exempt from reporting. In practice, most donations to political parties and candidates are made through Swish2 or bank transfers, which usually reveal the donor’s identity, making anonymous donations rare in practice. If an anonymous donation cannot be returned to the donor, it must be transferred to the Legal, Financial and Administrative Services Agency. Since the Transparency Act took effect in January 2019, this has occurred only once.
GRECO recommended Sweden implement a full ban on donations from unidentified donors, warning that the existing rules could be bypassed (GRECO, 2019[13]). The idea behind requiring the identity of private donors to be unveiled is to foster social accountability through transparency.
While the Swedish government had previously presented proposals concerning anonymous contributions, the Inquiry Committee recommended prohibiting parties and candidates from accepting any anonymous donations, while maintaining simplified rules for very small donations and the existing disclosure threshold for larger donations. The ban would also cover party sub-organisations but not extend to companies, foundations, or other legal entities linked to the party, as this could have unpredictable effects and current rules already ensure transparency for their funding.
The Committee also recommended introducing a ban on foreign donations to political parties, candidates, and their sub-organisations, recognising that Sweden remains one of the few countries without such restrictions. Indeed, bans on contributions to political parties from foreign states or enterprises are relatively standard regulations among OECD countries and are essential to prevent foreign actors from unduly influencing domestic politics (Figure 4.4).
While current data from the Legal, Financial and Administrative Services Agency suggests that foreign donations to political parties are not widespread, the Committee views the lack of regulation as a vulnerability, particularly in light of growing international concerns over foreign interference in democratic processes. To that end, the proposed ban would apply to donations from individuals who are not Swedish citizens or registered residents, as well as from non-Swedish legal entities. Exceptions would be made for small donations intended to cover expenditure in the context of international co-operation between political parties, especially within the European Union. The proposed ban would also duly respect international obligations including the obligations emanating from membership of the European Union. To enforce the ban, recipients of prohibited foreign donations would be required to return the funds to the donor or transfer them to the Legal, Financial and Administrative Services Agency within three months. Failure to do so would result in a penalty equal to twice the amount of the donation.
Both proposals are a welcome development, aligning with international standards and recommendations from bodies such as GRECO and the OSCE. Sweden is therefore encouraged to move forward with these amendments. Most importantly, the proposed changes on anonymous donations would not require individuals to publicly disclose their political views or party affiliations, as the existing disclosure threshold of 0.5 price base amounts would remain in place.
Note: The following OECD countries impose a threshold but not a complete ban on anonymous donations: Australia, Austria, Canada, Denmark, Finland, Greece, Ireland, Japan, Korea, Netherlands, Poland, Portugal, Sweden, United Kingdom and United States. Australia imposes a threshold on financial contributions from foreign states and foreign enterprises. Ireland imposes a threshold on financial contributions from publicly owned enterprises. Italy did not provide information for the criterion regarding “publicly owned enterprises”. Data for Belgium, Colombia, Germany, Hungary and New Zealand were not provided.
How to read: Regulations in Chile impose a complete ban on political parties from receiving financial contributions from anonymous donations, foreign states and foreign enterprises, and publicly owned enterprises.
Source: (OECD, 2024[14])
4.4.2. Sweden could consider introducing specific third-party campaigning regulations and accounting rules
The lack of transparency around the funding sources and political activities of third parties has become a growing concern among OECD countries. Third parties refer to stakeholders and interest groups that are involved in election campaigning but do not formally run in elections as political parties or candidates. These may include charities, faith groups, individuals or private firms that campaign in the run-up to elections. But while their activities have the potential to affect electoral processes significantly, these actors are often subject to less stringent reporting obligations, and in many cases, are not required to disclose their funding sources (OECD, 2021[1]).
These loopholes allow donors who may be restricted in how much they can contribute directly to parties or candidates to instead channel money through third-party organisations. In some cases, foreign actors exploit these gaps, using third parties as intermediaries to covertly influence election outcomes. Additionally, these groups can engage in unregulated political advertising, including social media advocacy and public events, without facing the same restrictions imposed on political parties or candidates (OECD, 2021[1]).
The Committee, which refers to these organisations in Sweden as “independent fundraising organisations” and defines them as bodies formed for the purpose of supporting a party or an election candidate but entirely outside the control or influence of the party or election candidate, considered that they should not be subject to the Transparency Act’s accounting rule. However, the Committee recommended clarifying that donations passed through separate fundraising organisations should only be accepted by political parties if the original donor’s identity is disclosed. Under the proposed clarification, anyone donating to an independent fundraising organisation with the intent or knowledge that the money will reach a party or candidate is considered the original donor, and if their identity is not revealed, the donation must be treated as anonymous and rejected.
However, this provision may be difficult to implement in practice as it implies that any donation passed on by a fundraising organisation originates from a specific individual with the intent to support a particular party or candidate. In reality, such donations are often made from the organisation’s general funds, which may be comprised of contributions from multiple donors, none of whom explicitly directed their donation toward political support. As a result, tracing a single “original donor” with clear intent is not always possible or accurate. In addition, the proposed provision would primarily apply to individuals or entities that openly designate their donations to third parties as intended for the benefit of a political party, essentially capturing only the more transparent or compliant actors. However, those seeking to circumvent the rules could simply refrain from specifying the political purpose of their contributions, thereby avoiding disclosure and escaping regulatory oversight. A more practical and transparent solution would be to require the fundraising organisations themselves to disclose their donors and funding sources, rather than requiring parties or candidates to retroactively identify individual donors behind collective contributions.
Additionally, the proposed provision focuses solely on revealing donor identities, while third-party regulations could also address rules on permitted donations, such as anonymous or foreign contributions, as well as set limits on activities, expenditures, and overall spending. As such, the Transparency Act could introduce clear definitions and rules governing the funding and political activities of independent fundraising organisations. At a minimum, independent fundraising organisations should be subject to the proposed prohibitions on anonymous and foreign donations. Additionally, they could be required to disclose information on both their donors and expenditures during election periods.
An increasing number of OECD countries are adopting stricter regulations on third-party political activities, emphasising transparency in expenditures and donor identities, especially during election periods. Table 4.2 presents examples that may serve as a reference framework for Sweden.
Note: On 13 February 2025, the Australian Parliament passed the Electoral Legislation Amendment (Electoral Reform) Act 2025. This Act will reduce the timeframes for lodgement of annual disclosure returns to 8 weeks for reporting entities, with effect from 1 July 2026, and change annual returns reporting timeframes from a financial year to a calendar year.
Source: (OECD, 2022[23]) and Australian Electoral Commission, Financial Disclosures, https://www.aec.gov.au/Parties_and_Representatives/financial_disclosure/
4.4.3. Sweden could enhance the audit and review of the accounts of entities currently required to keep accounts under the Transparency Act
Responsibility for oversight and implementation of Sweden’s political financing rules rests with the Legal, Financial and Administrative Services Authority (Kammarkollegiet). Its key duties include collecting and publishing annual financial reports from political parties, monitoring compliance with the Transparency Act (this includes verifying that reports are submitted on time and contain the required information), and enforcing regulations through sanctions in cases of non-compliance. To that end, the authority has powers to issue orders, impose fines, and initiate investigations if prompted by reports or specific circumstances.
While Kammarkollegiet ensures that reports are submitted and publicly accessible, its verification process primarily relies on the accuracy and completeness of the information provided by the parties and their auditors. There is currently no systematic auditing or cross-checking of the submitted data by Kammarkollegiet itself, as the agency does not have certified auditors on its payroll. To verify that these reports contain the required information, Kammarkollegiet provides a standardised template for auditors. This template requires auditors to comment on each item in the income statement. If no discrepancies are observed, auditors note “no deviations to report”. If irregularities are found they must be described in the report.
However, the current legal framework does not require all entities that are required to submit annual financial reports to the Kammarkollegiet to have their accounts audited. This requirement only applies to organisations that are legally or statutorily required to appoint an auditor. During the Inquiry process, party secretaries noted that most party-affiliated associations rely on lay auditors, but few are legally required to engage certified auditors, while the Kammarkollegiet reported that approximately two-thirds of submitted accounts already include an auditor's statement. In its recommendations to Sweden, GRECO has recommended that all parties receiving donations above the disclosure threshold should be subject to mandatory auditing, regardless of their legal status. After reviewing the issue, the Committee proposed that all entities subject to the Transparency Act be required to have their revenue recognition statements reviewed either by a regular auditor or, where not otherwise mandated, by a specially appointed auditor.
This reform is particularly significant given that Kammarkollegiet currently does not employ certified auditors to oversee the financing of political parties and election campaigns. While the Inquiry report acknowledges that expanding audit requirements could impose substantial financial and administrative burdens, an alternative approach would be for Kammarkollegiet to adopt a more proactive role in verifying and auditing financial reports. By employing certified auditors, the Agency could more effectively detect irregularities in political financial flows, as in other OECD countries (Box 4.10) – around half of OECD countries employ certified auditors in their bodies mandated to oversee the financing of political parties and election campaigns (OECD, 2024[14]). Although this would go beyond the Committee’s preference to maintain the Agency’s current focus, it may offer a more efficient and robust means of reviewing and auditing political finance disclosures.
Norway
In Norway, the Partilovnemnda (the Party Law Committee) is an independent administrative body responsible for, among other things, checking that the funding provisions in the Parties Act are complied with. The Party Law Committee may demand that a party or a party branch present all documentation of importance for checking compliance with financial duties within the Act. If the Committee deems it necessary, it may order control activities to be carried out by a specially appointed control body, the Party Audit Committee. The Party Audit Committee can demand that the party or party branch present any documentation to support the control activity. To ensure the effectiveness of this audit work, the Party Law Committee employs auditors as part of its Partirevisjonsutvalget (Committee for the Revision of Parties).
Canada
In Canada, the Chief Electoral Officer of Canada is the institution responsible for overseeing political financing of political parties and election campaigns. Based in the Office of the Chief Electoral Officer, Elections Canada is responsible for electoral administration and political financing oversight, according to the powers it receives from the Canada Elections Act. To ensure specialised expertise of personnel and methodologies to discover illegal funding of political parties and candidates, Elections Canada’s Political Financing branch employs auditors in the course of its activities.
Source: Based on (OECD, 2024[14]), OECD Public Integrity Indicators Database, https://data-explorer.oecd.org
4.4.4. The Transparency Act could include an explicit requirement for political parties and organisations receiving political donations to check their permissibility upon receipt
Even with a mandatory audit requirement, as proposed by the Inquiry, there remains a risk that political parties could, even inadvertently, accept and use impermissible donations before an audit identifies them as such, potentially after the funds have already influenced political discourse or affected the outcome of a campaign. Acknowledging this concern, the Inquiry has recommended clarifying that entities subject to the Transparency Act’s accounting obligations must act when there is reason to suspect that a donation has been funnelled through an intermediary or when the donor’s identity is unclear. This duty should also apply in cases where a donor appears to have made multiple small contributions that, when combined, exceed the disclosure threshold. In such situations, the party or candidate would be required to investigate, and if the donor’s identity cannot be sufficiently verified, the donation should be classified as anonymous.
To strengthen its framework in line with practices in other OECD countries, Sweden should consider amending the Transparency Act to establish a statutory obligation for political parties to take reasonable steps to verify the source of donations before accepting and using the funds (Box 4.11).
In the United Kingdom the Political Parties, Elections and Referendums Act 2000 (PPERA) states that:
“Where:
- a donation is received by a registered party, and
- it is not immediately decided that the party should (for whatever reason) refuse the donation
all reasonable steps must be taken forthwith by or on behalf of the party to verify (or, so far as any of the following is not apparent, ascertain) the identity of the donor, whether he is a permissible donor, and (if that appears to be the case) all such details in respect of him as are required by [Schedule 6 of the PPERA, relating to Details to be Given in Donations Reports] to be given in respect of the donor of a recordable donation.”
Source: UK Government (2000[24]), Political Parties, Elections and Referendums Act 2000, https://www.legislation.gov.uk/ukpga/2000/41/section/56.
4.4.5. The content of the annual financial reports could be expanded beyond revenues while political parties could be required to file separate financial reports about election campaigns
Effective reporting of political financing is essential for responsible authorities to assess compliance and act where necessary. Transparent political financing builds trust in democratic processes, by enabling scrutiny of donations and political relationships, and helps responsible authorities uphold the rules. In Sweden, the Transparency Act establishes that political parties have the obligation to submit financial reports annually to the Legal, Financial and Administrative Services Authority (Kammarkollegiet). However, the financial reports only include revenues, as there is no requirement in the legislation for political parties to report on their expenditures.
As such, the Committee recommended extending the obligation to keep accounts under the Transparency Act to include not only revenue but also expenditure, assets, and liabilities. This aligns with recommendations from international bodies such as GRECO, which views this expansion as essential for Sweden to meet European standards on political finance transparency. This would provide a more comprehensive view of party financing and help strengthen public confidence in the integrity of the political system. Given that Swedish parliamentary parties receive public funding, there is also a compelling case that the use of taxpayers’ money by political parties should be subject to transparent public accountability (International IDEA, 2022[8]). The Committee also recommended extending existing enforcement measures to include the imposition of special fees for the omission of costs, assets, or liabilities – mirroring the current provisions applied to unreported revenue. This approach would be a logical and necessary complement should the proposed changes to accounting requirements be implemented.
To enhance financial transparency and provide a clearer distinction between routine party finances and campaign-specific funding, political parties could be required to submit separate financial reports for each election campaign. This would ensure that the public and oversight bodies have a precise understanding of how parties raise and spend funds during electoral periods, distinct from their annual operations. According to data from the International Institute for Democracy and Electoral Assistance (IDEA), nearly three-quarters of European countries already mandate such election-specific financial reporting, reflecting a widely accepted standard for promoting accountability and trust in the democratic process (International IDEA, 2022[8]).
The movement of individuals between the public and private sectors, often referred to as “revolving doors”, can bring significant value, as recognised in the APACUI. This mobility supports a flexible labour market, fosters competence development, and enhances the attractiveness of public sector employment. Sweden has a long-standing tradition of encouraging such flexibility, with ease of transition between sectors seen as a strength of its labour model (Government of Sweden, 2023[10]). When properly managed, these transitions can facilitate the exchange of knowledge and expertise, contribute to innovation in public administration, and improve policy outcomes (OECD, 2003[25]).
However, without proper guardrails, they can also allow public officials to further their own interests or those of a past or future employer. This could include, for example, granting a former employer privileged access to non-public information or using past connections to secure access to such information or influence policymaking after leaving the public sector. To that end, measures to promote integrity in pre- and post-public employment must balance encouraging knowledge exchange between the public and private sectors while also protecting the public interest (OECD/World Bank/UNODC, 2020[26]). A comprehensive framework to promote integrity in pre- and post-public employment should involve measures to support officials in upholding integrity upon entering public office, during their tenure and after they leave. The framework can also include measures to support non-governmental actors, particularly the private sector, in respecting governments’ pre- and post-public employment rules (OECD, 2010[27]).
The Act on Restrictions on the Transfer of Ministers and State Secretaries to Other than State Activities of 2018 (2018: 676), commonly referred to as the Transitions Act or Restrictions Act, regulates the transition of ministers and state secretaries to positions outside the state sector. In response to several high-profile cases involving revolving doors, as well as recommendations from international organisations, Sweden has recognised the need to strengthen safeguards for integrity in post-public employment. To address this, the government has established a dedicated Inquiry Committee tasked with reviewing existing regulations and proposing measures to enhance transparency, accountability, and public trust in transitions from public office to private sector roles.
The assignment has been to evaluate the Transitions Act comprehensively, with particular focus on determining whether the scope of individuals subject to the regulation should be broadened. This also included assessing if the restriction period should be extended and whether sanctions should be introduced for non-compliance. Additionally, the task involved proposing a generally applicable regulatory framework on post-public employment restrictions. The evaluation also considered whether such regulations should extend beyond ministers and state secretaries to include employees in state and municipal operations, members of state boards and municipal company boards, as well as certain elected officials within municipalities, regions, and municipal associations (Government of Sweden, 2023[10]).
Drawing on OECD standards and good practices from OECD Member countries, this section reviews the conclusions of the Inquiry in detail and provides recommendations to support Sweden in strengthening pre- and post-public employment regulations and their implementation, thereby mitigating conflict-of-interest risks posed by public officials’ movement between the public and private sectors.
4.5.1. Sweden could adopt a risk-based approach to determine the scope of public officials that should be covered by the Restrictions Act
To be effective, a post-public employment framework needs to cover all main risk areas in terms of functions, tasks and sectors. Certain categories of officials are more exposed to risks of undue influence, capture or corruption due to the nature of their position and the information they had access to while in office. These include high-level political officials (ministers, members of Parliament and political advisers), senior civil servants, chief executives and managers of SOEs, and officials involved in procurement and contract management in public-private partnerships (OECD, 2010[27]). Other categories of public officials are also at risk: this includes public officials interacting with the private sector through government functions, such as public procurement, issuing of licences and permits, or distribution of public or European funds, as well as those operating in regulatory functions or a competition authority.
Under the current Transitions Act, ministers and state secretaries are required to notify the Board for the Examination of Transitional Restrictions for Ministers and State Secretaries (Karensnämnden) before taking up a new assignment or employment outside the state sector or setting up a business. The Board assesses whether the proposed transition poses risks such as financial harm to the state, undue personal advantage, or potential damage to public trust in government institutions. If any such risks are identified, the Board may impose transitional restrictions. These may include a cooling-off period, during which the individual must delay the commencement of the new role, or a subject restriction, which prohibits involvement in certain matters related to the individual’s former duties for a defined period. Such restrictions may be enforced for up to twelve months. This model is similar to the systems adopted in France, Greece, Norway, Spain and the United Kingdom, in which laws and regulations require a public official who is leaving to pursue employment in the private sector to declare their activities and/or obtain approval from a dedicated body, which can help facilitate monitoring and enforcement.
Additionally, specific provisions apply to certain public offices: the National Audit Office Act (2020:537) governs transfer restrictions for the Auditor General and the Director of the National Audit Office; the Riksbank Act (2022:1568) mandates a one-year waiting period during which former Executive Board members, including the Governor, are prohibited from holding roles in financial companies or any other employment that could compromise their suitability; and the Railway Market Act (2022:365) requires a one-year waiting period for executives at the Swedish Transport Agency who have held supervisory responsibilities, preventing them from working or holding positions of responsibility in companies overseen by the agency following termination of employment. However, these rules are limited to cooling-off periods and there are no specific mechanisms for monitoring compliance.
The Inquiry report found that the existing legal framework for ministers and state secretaries has largely met its objectives and did not require significant amendments, as it has demonstrated a certain degree of self-regulatory effect, and the notification obligation appears to have been adequately fulfilled. However, the Committee still recommended to expand the scope of the Act to encompass heads of central government agencies, as their transition to a private activity may entail a risk of conflict of interest.
More significantly, the inquiry proposed the introduction of general regulations – mirroring those in the Transitions Act – applicable to all administrative authorities under the Government, while municipalities, regions, and local government federations would have the discretion to apply them. Moreover, it would be up to each employer to determine—based on specific criteria—which positions should be subject to the restrictions, and to include such terms in the employment contract at the time of recruitment. To that end, the report proposes to replace the existing Transitions Act with a new law consolidating the regulation on transitional restrictions for ministers, state secretaries, and heads of government agencies, as well as the generally applicable rules for other employees, into a single, coherent legal framework.
The proposed model would resemble the existing system in France, where post-employment rules are not based on fixed cooling-off periods but instead rely on a case-by-case assessment of the proposed professional activities of public officials and civil servants. However, restrictions could be extended beyond only heads of public authorities to also target high-risk positions. For instance, political advisors to ministers and state secretaries, senior management of regulatory authorities (not just the heads), as well as senior management and board members of state-owned enterprises (SOEs), could also be included under the Restrictions Act.
Good practice across the OECD suggests requiring Persons Entrusted with Top Executive Functions (PTEFs) to request approval for post-public employment activities as an extra precaution. In Sweden, PTEFs are defined in Chapter 1, Section 9 of the Act (2017:630) on Measures Against Money Laundering and Terrorist Financing, which aligns with EU Directive 2015/849 (the Fourth Anti-Money Laundering Directive). This legislation identifies specific categories of public officials holding “prominent public functions.” While not all these positions necessarily need to fall under the Restrictions Act, this list can provide a useful framework to determine which categories of public officials should be covered by its provisions.
As such, the Swedish authorities could adopt a risk-based approach to determine a broader list of categories of public officials that would be covered by the Restrictions Act. At a minimum, the requirement could be expanded to ministerial advisors, given their prominent role in decision-making processes. Such an approach was adopted in France, where certain positions require mandatory referral to the High Authority for Transparency in Public Life (HATVP) when transitioning to the private sector (Box 4.12).
Post-public employment activities of former ministers, presidents of local executive bodies and members of independent authorities (Law 2013-907 on the transparency of public life)
In France, the High Authority for transparency in public life is currently responsible for monitoring the post-public employment activities of former ministers, presidents of local executive bodies and members of independent authorities (article 23 of Law 2013-907 on the transparency of public life). For a period of three years, any person who has held one of these positions must refer the matter to the HATVP so that it can examine whether the new private activities he or she plans to pursue are compatible with his or her former positions.
The High Authority will therefore check whether the activity envisaged by the official or public servant leaving office poses difficulties: (i) of a criminal nature and/or (ii) of an ethical nature. When it identifies such difficulties, the HATVP may issue an opinion of incompatibility, which prevents the person from carrying out the envisaged activity, or of compatibility with reservations, in which the HATVP imposes precautionary measures to prevent the criminal or ethical risk.
Since the enactment of Law No. 2024-850 of 25 July 2024 aimed at preventing foreign interference in France, the HATVP also assesses the risk of foreign influence, in addition to criminal and ethical risks. When conducted in light of this risk, the review period is extended to five years. This means that the HATVP examines, for this purpose, the activities carried out during the five years preceding the public official’s exit from the public sector and during the five years following the end of their public functions
Post-public employment activities of public officials (Act 83-634 on the rights and obligations of civil servants)
The law of 6 August 2019 on the transformation of the civil service also gave the HATVP new responsibilities for monitoring the mobility of certain civil servants (Law 83-634 on the rights and obligations of civil servants). Referral to the HATVP is compulsory for members of ministerial cabinets, presidential advisors, and certain civil servants occupying the highest positions in the three civil services (this concerns over 15 000 civil servants). These positions include:
Positions subject to declaration of assets and interests (both prior and subsequent declarations), notably:
Directors General and Deputy Directors General of regional, departmental, municipal services in cities of over 40 000 inhabitants, and public inter-municipal co-operation establishments (EPCI) with their own taxation over 40 000 inhabitants.
Directors of University Hospitals (CHU) and Regional Hospitals.
Directors and Deputy Directors of public hospital institutions.
Inspectors General and members of inspection or control bodies.
Persons exercising the role of ethics referents.
Administrative magistrates (Council of State, Court of Auditors, regional audit chambers).
Decision-making positions such as heads of departments, general secretaries of prefectures, directors general of state services in departments and regions, especially those who sign public contracts or allocate aid/subsidies.
Source: Haute Autorité pour la transparence de la vie publique, https://www.hatvp.fr/la-haute-autorite/la-deontologie-des-responsables-publics/controle-mobilite/
4.5.2. To ensure consistency and transparency, administrations could refer cases to the Transitions Board for advice, and its decisions could be made public
Under the proposed generally applicable regulation for other categories of public officials, administrative authorities within the government would determine which positions should be subject to such restrictions. This decision should be based on an assessment of whether the employee is likely to gain access to sensitive information or knowledge during their employment that could, if misused, result in financial damage to the public sector, provide an undue advantage to an individual, or undermine public trust. If such a risk is identified, the relevant conditions must be clearly stated in job postings and the employment contract. Employees in these positions would be required to notify their employer if they intend to transition to a private sector role. The employer would then have three weeks to assess whether transitional restrictions should apply, using the same criteria outlined in the regulation. Recognising the principle of local self-governance, the report allows municipalities and regions to decide independently whether to implement these transition restrictions.
However, some stakeholders interviewed during the inquiry and some during the consultation on the inquiry report expressed concern that this voluntary approach may lead to inconsistent application and potential vulnerabilities in areas with higher corruption risks. There are also concerns that more restrictive employment terms, particularly without uniform application across government levels, could deter skilled professionals from entering or remaining in public service, particularly in more regulated sectors.
To address these concerns, a mechanism for the hierarchical authority of administrative authorities to refer specific cases to the Karensnämnden, could be established in the revised Transitions Act. A similar system exists in France, where most civil servants are subject to ethical control by the administration itself. Some cases may require the involvement of the High Authority for transparency and integrity in public life, in accordance with the principle of subsidiarity: if the hierarchical authority has serious doubts, it may refer the matter to the High Authority (Figure 4.5). A similar approach in Sweden would ensure consistency and avoid that public administration take arbitrary decisions – or no decisions – in case of doubt.
Source: (HATVP, 2025[28])
In addition, decisions from the Transitions Board, along with details of the decisions, could be available to the public, as suggested in the Inquiry report. This measure aims to ensure accountability and public awareness of how transition restrictions are applied, and would be particularly important given that the inquiry report does not foresee the introduction of formal sanctions for non-compliance with transition restrictions. This would mirror the existing practices in France and the United Kingdom, for example (Box 4.13).
United Kingdom
in the United Kingdom, decisions made by the Advisory Committee on Business Appointments (ACOBA) are made public. ACOBA publishes its independent advice to departments and ministers when appointments are taken up. This includes details of the application, ACOBA’s consideration, and the advice provided, which are made available on the government’s website. Additionally, failures to follow the government’s rules or ACOBA’s advice are also published in line with ACOBA’s commitment to transparency.
France
The legal framework allows the High Authority for Transparency in Public Life to publish the opinions it issues, pursuant to Article 23 of the Law of 11 October 2013, regarding the compatibility of private sector activities with the prior exercise of governmental functions, membership in independent administrative or public authorities, and certain local executive functions. The same applies, under Article 124-15 of the General Civil Service Code, to opinions it issues on the exercise of private sector activities by a civil servant or on appointments to certain public positions of individuals who have previously engaged in private sector activities. In all cases, the decision to publish is made after obtaining the observations of the individuals concerned.
Given the nature of the functions they hold, the High Authority generally publishes the opinions concerning individuals subject to its ethical oversight and whose declarations of interests are made public on its website (members of the Government, presidents of regional and departmental councils, mayors of municipalities with over 20 000 inhabitants, etc.). However, it may decide not to publish an opinion or to postpone its publication depending on the specific circumstances of the case.
The High Authority may also decide to publish the opinions it issues regarding other individuals, where the circumstances so justify.
Source: Advisory Committee on Business Appointments, https://www.gov.uk/government/organisations/advisory-committee-on-business-appointments; Haute Autorité pour la transparence de la vie publique, https://www.hatvp.fr/consulter-les-deliberations-et-avis/
4.5.3. The maximum duration of post-employment restrictions could be increased to allow better modulation according to at-risk positions, activities and behaviors
In addition to covering all at-risk categories of officials, a comprehensive pre- and post-public employment integrity framework should also cover all at-risk activities and behaviours. Not all officials, nor all post-public employment roles and behaviours, present the same level or nature of risk. Accordingly, restrictions should be designed to be fair, proportionate, and tailored to the actual risk posed (OECD, 2010[27]).
The Inquiry report did not propose changes to the current maximum duration of post-employment restrictions (12 months) for ministers, state secretaries and heads of public authorities, considering it sufficient to address potential conflicts of interest without unduly hindering career mobility. For the proposed generally applicable regulation for other categories of public officials, restrictions would be announced in the form of a waiting period and/or substance restriction for a maximum of six months, while for employees in the defence sector the recommendation is for restrictions up to 12 months.
However, this fixed limit of six or 12 months does not allow for adequate adjustment based on the specific risks associated with individual cases and may be insufficient for certain high-risk activities. For example, in the case of some senior public officials, a cooling-off period for lobbying may reasonably need to extend beyond one year until the individual's influence over former colleagues has diminished. Yet, the current rules do not permit such flexibility. Therefore, consideration should be given to removing the fixed maximum or extending it beyond 12 months, in order to allow for a more nuanced and risk-based application of restrictions.
4.5.4. The Inquiry’s data collection exercise could be maintained at regular intervals to monitor compliance with revolving door rules and identify at-risk categories
Collecting data on movements between the public and private sector allows governments to assess whether their rules on revolving door are being observed, and therefore whether they are mitigating the risks of movement in and out of public office (OECD, 2024[14]). Most OECD countries, including many with mandatory cooling-off periods, are not tracking the post-employment activities of public office holders. Only nine OECD countries collect data on the frequency within the past five years with which ministers took up positions in a private sector organisation that operates in their former area of responsibility. Only eight collect the same data for the most senior civil servants (Figure 4.6).
Note: Countries marked with an asterisk (*) have mandatory cooling-off periods for public officials.
Source: (OECD, 2024[14])
For the purpose of the Inquiry, the Committee mapped transition patterns and prevalence of employer changes from 2017 to 2021 using data from 25 government agencies, 30 municipalities, 6 regions, and 10 municipal companies, totaling 32 523 transitions. Data was sourced from Statistics Sweden’s labour market and occupational registers but lacked detail on job changes within specific activity areas, limiting the ability to identify potential conflicts of interest. Findings showed that 40% of state agency employees, 49% of municipal employees, 52% of regional employees, and 56% of municipal company employees moved to the private sector in the examined period.
Although the Inquiry report notes that the data collection process was time-consuming, such tracking could be maintained for public officials subject to the Transitions Act. To support this, public administrations could be mandated to systematically monitor and retain data on transitions of these officials into the private sector. This information could then be used by the Transition Board to prepare a report identifying key trends and patterns.
4.5.5. Sweden is encouraged to introduce sanctions for public officials and could consider encouraging compliance by the private sector with post-public employment restrictions
Currently, there are no formal sanctions for non-compliance with transition restrictions. When the Act was first introduced, it was assessed that there was no need to include formal sanction mechanisms. This conclusion was reaffirmed in the Inquiry Report. The report notes that non-compliance with the rules is likely to draw strong criticism from political parties, the media, and the public, criticism that can significantly harm an individual’s reputation and future employment prospects. These social and professional consequences are considered more impactful than formal sanctions, supporting the view that the regulations, as currently designed, offer sufficient deterrence on their own. The report suggests that, following an evaluation of the regulations' effectiveness, the introduction of sanctions could be considered if deemed necessary to ensure adherence.
As such, Sweden is encouraged to keep under review the use of sanctions in this context, as suggested in the inquiry report. Sweden could also consider introducing a "name and shame" mechanism whereby identified violations of post-public employment restrictions, or breaches of Transition Board decisions, are made public. Given Sweden’s strong emphasis on reputation, public disclosure could serve as an effective deterrent, functioning as a non-financial sanction to promote compliance.
Alternatively, Sweden could also consider encouraging compliance by the private sector with post-public employment restrictions. In particular, specific sanctions could be included for legal entities that have hired former public officials subject to such restrictions, thereby recognising that firms are responsible for behaving with integrity and should encourage former public officials to do the same. These sanctions could include fines and/or payments for damages and more targeted measures such as debarment from contracting with the state. Box 4.14 provides more information on measures Spain has taken to hold private sector actors accountable for violating post-public employment measures.
Post-public employment restrictions for senior public officials in Spain are regulated under Law 3/2015 regulating the exercise of the high office of the General Administration of the State, which establishes post-public employment restrictions for senior officials. This law establishes in Article 15 that senior officials cannot provide services to private entities affected by their decisions or enter into contracts with public bodies where they previously worked for two years following their departure from office. Members of regulatory and supervisory bodies also cannot provide services in private entities that they supervised or regulated for a period of two years. Former senior officials must declare their post-employment activities to the Conflict of Interest Office for two years following their departure from public office and the Conflict of Interest Office must then issue an authorisation within one month. It examines and verifies the content of these declarations and publishes authorisations for post-employment activities on the national transparency portal.
Sanctions for public officials include a prohibition on occupying public office for a period ranging from five to ten years in the event of a serious or very serious violation of the law. Former public officials can also be required to return compensation that they received while undergoing their cooling-off period and/or have their public service pension reduced.
The legal framework also compels companies to comply with post-public employment legislation. Law 9/2017 on public sector contracts establishes that companies contracting with the state that have hired anyone subject to the two-year cooling-off period in violation of the prohibition on providing services in private companies directly related to the competencies of their former position are prohibited from contracting with any public body if the violation has been published in the Official State Gazette. This debarment remains for as long as the person is employed, with a maximum limit of two years from their termination as a high-ranking official.
Source: (OECD, 2010[27]); Law 3/2015 of 30 March regulating the exercise of the high office of the General Administration of the State; Law 9/2017 of 8 November on Public Sector Contracts, by which the Directives of the European Parliament and of the Council 2014/23/EU and 2014/24/EU of 26 February are transposed into the Spanish legal system.
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← 1. Price base amount (prisbasbelopp) refers to the inflation-adjusted reference value determined annually by the Swedish government in accordance with the Social Insurance Code (2010:110). It is applied to calculate benefits, thresholds, and fees across multiple legislative frameworks.
← 2. Swish is a mobile payment system in Sweden enabling instant bank-to-bank transfers via a smartphone app, authenticated with BankID. Launched in 2012 by Swedish banks, it is widely used for personal and business payments.