As of 1 July 2025, lobbying activities in the Czech Republic are subject to regulation for the first time. The new Regulation of Lobbying Act aims to enhance transparency by defining who qualifies as a lobbyist, identifying the targets of lobbying (primarily public officials) and introducing record-keeping obligations. A key element is the creation of a publicly accessible register, where lobbyists must disclose their identity and the parties they represent.
Registration will be required for activities such as seeking legislative amendments, changes to regulatory frameworks or individual exemptions – for instance, in the context of investment incentives, building permits or public procurement procedures. Non-compliance may result in substantial fines and reputational risks.
Companies that do not use the services of external lobbyists registered in the official list but lobby through their employees should pay increased attention to their own activities. If they wish to engage in public debate or influence legislative or administrative processes, they should introduce internal mechanisms for identifying, recording and controlling these lobbying activities. Otherwise, legal entities expose themselves to significant risks: fines of up to CZK 1 million or up to 3% of their assets, a temporary ban on activities and mandatory publication of the decision on the offence.
1. Activities considered lobbying
Lobbying is considered any activity aimed at actively and directly influencing the decision-making of a specific person in the creation of public policy – especially in the preparation, discussion or approval of legal regulations, conceptual documents, measures of a general nature or international treaties.
A typical example of lobbying is the effort to promote specific wording of a legal regulation, influence the parameters of a regulatory measure or adjust government strategy in a particular sector.
For an activity to be considered lobbying, it must be directed towards the lobbied person. According to the relevant legislation, a lobbied person is defined as a member of parliament, a senator, a member of the government, senior employees of central administrative authorities and other public officials.
According to the new law, even an apparently ordinary business meeting can be considered lobbying if its real purpose is to deliberately influence the decision-making of the lobbied person in the above-mentioned areas.
However, the law also recognises a relatively wide range of exceptions. Activities performed within the framework of public office or employment relationships with the state, a public institution or self-government; during the negotiations of public authorities; within public consultations or commentary procedures; or through the media, as well as activities related to classified information, critical infrastructure or activities whose disclosure would endanger the life or health of a natural person in a dangerous country of origin, are not considered lobbying.
2. Lobbyist in the eyes of the law – can an employee of a company fall under the definition of a lobbyist?
According to the new law, a lobbyist is any natural or legal person who continuously engages in activities aimed at influencing the decision-making of lobbied persons in areas such as the creation of legislation, conceptual documents or regulatory rules. The law does not set any limit on profitability or professional position – the key factors are the repetitiveness and purpose of the activity. Continuous activity is defined as that which is not random or one-off but occurs repeatedly on a larger scale or systematically. It is sufficient for the lobbyist’s intention to be continuous, regardless of whether it actually happens.
A lobbyist is also understood to be a legal entity that uses a lobbying intermediary, who can be, for example, its employee. Thus, a lawyer, sales director or other manager can fall under the definition of a lobbyist if they regularly engage with lobbied persons. If the employee acts repeatedly in this way, they must either be registered in the lobbyist register themselves or act on behalf of a registered company.
3. Transparency of lobbying: Legal obligations and recommended compliance procedures
The law on lobbying emphasises transparency – not only through a public register but also via specific notification and record-keeping obligations. In accordance with these provisions, lobbyists will be required to comply with the following:
- Register with the Ministry of Justice – without registration, lobbying activities cannot be legally performed.
- Inform the lobbied person in advance that they are acting as lobbyists and on whose behalf.
- Provide written confirmation on request of their role and on whose behalf they are acting.
- Publish a list of lobbying contacts twice a year, including the date, place and subject of the meeting.
If companies decide not to use external lobbyists but to lobby themselves, they too will have to be registered. Beyond legal obligations, it is advisable for such companies to introduce internal compliance measures. Recommended steps include the following:
- Adopting an internal directive that clearly defines who is authorised to lobby and under what conditions.
- Keeping internal records of meetings and discussed topics – ideally with a brief summary and the date of the meeting – so that the meeting is sufficiently documented.
- Setting up a notification system where lobbying activity is reported to the legal or compliance department in advance or subsequently.
- Ensuring that at least two people attend meetings with the lobbied person.
4. How to prepare for a possible inspection?
Compliance with the obligations under the lobbying law will be subject to supervision by the Ministry of Justice. The Ministry will be authorised to conduct inspections, assess the accuracy of registrations, verify compliance with notification obligations and impose corrective measures and sanctions in case of identified deficiencies – including fines, bans on activities or publication of the offence.
Lobbyists should therefore be prepared to demonstrate proper fulfilment of their obligations. The key is to maintain up-to-date and truthful information in the lobbyist register, submit semi-annual statements on contacts promptly and keep accurate internal records of all relevant meetings and negotiations. Internal control over compliance will also be supported by ongoing training of employees who engage with public administration – especially lawyers, public affairs managers and sales representatives.
Compliance with legal regulations is not only a matter of legal responsibility but also an important part of a company’s compliance culture, particularly in the event of administrative or criminal proceedings against it.
5. Responsibility of a legal entity for indirect lobbying or lack of compliance
The new law on lobbying not only establishes a framework for transparent communication with public administration but also introduces a sanctions regime for legal entities that breach these rules. Companies that repeatedly engage in lobbying activities without registration expose themselves to the risk of a fine of up to CZK 1 million or up to 3% of the value of their assets.
Penalties may also apply in cases where false or misleading information is provided in the register or where the company fails to submit mandatory reports on contacts with lobbied persons. The law thus effectively introduces a new compliance obligation for companies that lobby on their own behalf. They are expected to manage the compliance risks associated with lobbying; ignorance or inaction does not exempt them from these obligations.
Indirect lobbying through employees, without proper registration in the lobbyist register, will be considered unlawful during an inspection. Measures such as internal directives, record-keeping systems and training are therefore not just “best practices” but essential safeguards against financial and reputational consequences.
6. Public register of contacts: A new factor of reputational and legal risk
One of the most visible impacts of the new legislation is the creation of a publicly accessible database of lobbying contacts, which will collect detailed information on all officially reported lobbying activities. Every registered lobbyist will be required to submit a so-called Statement of Contacts to the register twice a year – always within 30 days after the end of the half-year – in which they will state:
- with whom they met (the lobbied person), including their position and organisational affiliation;
- on whose behalf they lobbied (e.g. a specific client or employer);
- whether they lobbied personally or through another individual.
The lobbied person is also recorded in the lobbyist register. Unlike the lobbyist, however, they are not required to submit data on lobbying contacts or provide documents or information on a semi-annual basis. Only if the lobbied person is in a position to influence the content of the explanatory report for legislation are they obliged to ensure that the report includes information on all lobbyists who lobbied them in relation to the matter. This information must also be provided to the relevant committee of the Chamber of Deputies or the Senate.
This data will be publicly available and will enable journalists, watchdog organisations, competitors and the general public to retrospectively analyse the flow of influence between the private sector and public administration. Records from the register may also be used as evidence in administrative or judicial proceedings.
By Jitka Logesova, Partner, and Tereza Ottova, Associate, Wolf Theiss
