Finland implemented its long-prepared transparency register on January 1, 2024, as the transparency register law came into effect. The transparency register is a system where lobbyists for companies and associations must disclose how they attempt to influence decision-makers. North Patrol acted as the project’s consultant partner in the preparation, requirements specifications, and tendering process.
North Patrol is a consulting firm specialized in the design of digital services and information systems. We shape ideas into a vision and service concept, find the best architectural and technological solutions, design a functional user experience, and compete to find the ideal partner for implementation work. We do not sell implementation projects, nor do we sell licenses; we are genuinely on the side of the customer.
8 February 2024
In a broader context, the aim of the Register is to improve the transparency of decision-making, combat inappropriate influencing and strengthen citizens' trust in the central government and democracy. "As the name suggests, the transparency register brings transparency to political decision-making and supports democracy", describes Sami Yläoutinen, the Managing Director at the National Audit Office in Finland in their release (in Finnish).
As an online service, the transparency register consists of two parts: a publicly accessible website where anyone can browse the information stored in the system and a service for organizations engaging in influencing activities. These organizations, involved in lobbying or its advisory, are referred to as disclosers.
The Finnish Transparency Register website defines a discloser (actor subject to the disclosure obligation) as follows:
"Legal persons and private entrepreneurs who engage in lobbying and lobbying consultancy are subject to the disclosure obligation. Of private entrepreneurs, only those who are principally engaged in lobbying or lobbying consultancy are subject to the registration obligation. The disclosers, i.e. those subject to the disclosure obligation, must submit their registration and disclosures of activities to the Finnish Transparency Register. The disclosure obligation applies always to the actor carrying out lobbying or lobbying consultancy, not the lobbying target."
Additionally, the system includes various management views and functionalities that can be utilized by the register authority.
How did the system itself come into being?
The National Audit Office of Finland (NAOF) was appointed as the administrator of the Transparency Register. In practice, this meant that the NAOF had to implement a data system that met the requirements of the law in the manner it deemed best, within the timeframe dictated by the enactment of the legislation.
North Patrol was selected as the partner for the preparation stage of the system project. The collaboration started in August 2022. The starting point for the preparation was very clear: the solution should be a completely new and unique system for which there was no suitable off-the-shelf solution. Everything had to be defined from scratch. Additionally, there was constant pressure due to the preparation of the legislation and its enactment. Three consultants from North Patrol supported the NAOF team throughout the Autumn, taking charge of the specifications, document drafting and refinement, as well as facilitating the process.
The NAOF project team had already outlined key processes in advance, and these processes were further refined during the specification phase. There were numerous details to consider, but with good collaboration, these were efficiently addressed. Defining the scope of the project was also a balancing act: Should we only implement the minimum requirements set by the law in the first phase, or should we aim to create a genuinely usable and beneficial system from the outset, one that would be pleasant for disclosers to use?
The preparation of a project description and the procurement documentation was done in a relatively tight timeframe. The procurement notice was published in HILMA in December 2022. In this regard, we have to thank the active and professional project team from the NAOF. Without such a committed and knowledgeable team, progressing within such a tight timeframe would not have been possible.
North Patrol also supported the NAOF in conduction the procurement process. Overall, the tendering process was very interesting, and partly challenging, as vendors approached the request with varying technical solutions. Eventually, Ambientia was selected as the implementation partner for the transparency register. Their solution proposal was largely based on extensive customization to meet specific customer needs, utilizing technologies such as React and Node.js. Selected off-the-shelf products, such as the Contentful content management system, were also included to support the overall solution.
The actual implementation project began immediately after the Parliament approved the content of the Transparency Register Act. This was an extremely time-critical project. The Transparency Register Act was set to come into force on January 1, 2024, and the system had to be reliably in production use by then. Not all functionalities needed to be fully ready at once, but it was essential that disclosers could make registration notifications.
System development follows an annual clock
Those engaged in lobbying activities and lobbying advisory work must register and report their activities twice a year in the Transparency Register. All entities engaged in lobbying activities had a registration period to join the system between January 1 and March 31, 2024.
The next effort is scheduled for July-August, when disclosers report their lobbying activities for the first half of the year by submitting activity disclosures. From a system development perspective, this means that the functionalities related to submitting activity disclosures must be ready by June 30, 2024. Hopefully, by that time, the views of the public website for browsing activity disclosures will also be completed.
In the future, activity disclosures will be submitted twice a year: lobbying activities from January to June will be reported in July-August, and activities from July to December will be reported in January-February. Additionally, starting in 2026, lobbyists will also include financial information related to lobbying activities from the previous year in the activity disclosure.
You can learn more about the yearly schedule and the use of the Transparency Register on the Finnish Transparency Register website.
A guide to the Transparency Register Act has been published, containing an overview of the register, key concepts related to it, procedures, and stakeholders.
