What are the risks for companies that lobby without registration: fines and reputational risks
Lobbying without registration in the Czech Republic will be a breach of the law from 1 July 2025. Fines may reach CZK 1 million or a percentage of turnover, and there is also the risk of losing the trust of business partners. We will explain what the new rules mean, what risks they bring, and how to ensure your company proceeds in compliance with Czech legislation.
Article contents
- What the Lobbying Regulation Act actually means
- Errors in the statement or failure to file it
- How high the fines are and what happens to them
- When you must register as a lobbyist and when the Act does not apply to you
- Lobbying footprint – an obligation for the state
- How to avoid problems – practical tips
Quick summary
- As of 1 July 2025, a new Lobbying Regulation Act has taken effect in the Czech Republic, introducing a registration obligation for anyone who systematically influences political and legislative decision-making at the central-government level.
- Fines for illegal lobbying can reach up to CZK 1,000,000 (individuals) or up to 3% of net turnover (legal entities), and there is also a risk of a ban on activity and publication of the misdemeanour decision.
- Lobbying without registration damages a company’s reputation and leads to increased scrutiny by the state authorities in the Czech Republic of your business and its partners.
- Whether you are paid for lobbying is not decisive – even lobbying without remuneration or as part of non-profit activities requires registration if it meets the criteria of being systematic.
What the Lobbying Regulation Act actually means
The Lobbying Regulation Act took effect on 1 July 2025 and introduced the first comprehensive legal framework for lobbying in the Czech Republic. Previously, lobbying was governed only by informal rules and activities took place without coherent oversight. The new legislation defines lobbying as communication aimed at influencing the discussion, adoption, or approval of legislation and strategic materials.
The word “systematically” here means an activity that is regular, repeated, or carried out in a structured manner with the aim of achieving a specific outcome. It must therefore not be an incidental one-off contact, but a targeted effort to influence public officials. In practice, the concept of being systematic is key, and ARROWS attorneys deal with this issue routinely, because the line between ordinary communication and lobbying can be thin.
The Act contains important exemptions. Under Section 3 of the Act, lobbying does not include, for example, participation in public consultations, standard comment procedures via the ODok/eKlep portal, or the activities of political parties or trade union organisations. If you submit comments on a draft law through the official electronic system, this is not considered lobbying and you do not need to register.
The purpose of the register is transparency, so that both the public and the state authorities in the Czech Republic can clearly see who is trying to influence public officials. The register of lobbyists and lobbied persons is maintained by the Ministry of Justice (Czech Republic) and is publicly accessible. Anyone can check who is lobbying, in whose interest, and what specific steps they are taking.
What the lobbyists’ register contains
The register maintained by the Ministry of Justice (Czech Republic) contains records of registered lobbyists and, within their activity reports, also data on lobbied persons and the objectives of lobbying. The system offers search functionality and the data are retained for the period set by law, typically for several years even after a lobbyist is removed from the register.
Each lobbyist must also file an activity report in the register for each past half-year. The filing deadlines are typically by the end of the month following the end of the half-year. In the statement, they must specify which lobbied persons they engaged with, which legislation or document they sought to influence, and in whose interest they acted.
What to fear if you fail to meet the registration obligation
If your company lobbies systematically and is not entered in the register, you face significant administrative penalties under Czech law. The offence of lobbying without registration may be punished by a fine of up to CZK 1,000,000. For legal entities, the upper limit may also be based on net annual turnover (up to 3%), and a ban on activity may also be imposed.
Crucially, sanctions may be imposed regardless of whether your lobbying was successful. Even if your attempt failed, you breached the law by not registering. ARROWS attorneys address this aspect repeatedly in practice, because many business owners mistakenly believe that sanctions apply only where influence is actually achieved.
Problems with insufficient or false data in the register
This is not only about complete failure to register. If you register but provide false or incomplete information in the activity report, you may face a high fine. This includes, for example, situations where you conceal the client in whose interest you are lobbying or fail to state the subject matter of the lobbying.
Every detail matters here. If a legal entity lobbies, it is represented by a specific natural person acting on its behalf. In practice, companies often overlook the administrative details associated with reporting changes to information, which can lead to unnecessary penalties.
Errors in the statement or failure to file it
If you register correctly but then fail to submit the activity report on time or submit it incomplete, you commit an offence. The report is filed twice a year and its structure is set by implementing regulations or by the Ministry of Justice (Czech Republic) form.
It may seem straightforward, but in the real world it requires discipline. Companies often do not keep proper records of their contacts with politicians and state officials. Sometimes they are unsure which contact falls under the definition of lobbying. ARROWS attorneys assist with the preparation of individual reports to ensure they are formally correct.
How high the fines are and what happens to them
Fine levels vary depending on the seriousness of the offence. The Act distinguishes between administrative errors and deliberate circumvention of the law.
- Administrative offences: For failure to meet notification obligations or failure to file an activity report, fines in the tens to hundreds of thousands of Czech crowns may be imposed (typically up to CZK 100,000 to CZK 300,000).
- Serious offences: For lobbying without registration, individuals face a fine of up to CZK 1,000,000. For legal entities, the sanction may reach up to 3% of net annual turnover or a fixed amount in the millions of Czech crowns.
In addition, a ban on activity may be imposed, i.e., a prohibition on carrying out lobbying for a certain period. A misdemeanour decision is a publicly accessible act and, in cases of serious breaches, it may be published.
Reputational damage and consequences for business relationships
The fine is not the only problem. If the public learns about your breach of the law, it will be harder for your business partners to work with your company. Institutions with strict compliance rules may be reluctant to engage with you or continue contractual relationships.
If, for example, you are a supplier or partner of a large corporation, its legal team will also review your compliance risks during due diligence. The same applies when bidding for public contracts in the Czech Republic, where an offence may not automatically mean exclusion, but it casts the bidder in a negative light.
In addition, it may be examined whether corruption or other criminal activity is concealed behind non-transparent lobbying. The law was adopted, among other reasons, to strengthen the transparency of the legislative process in the Czech Republic. Suspicious conduct may trigger a more in-depth review by Czech law enforcement authorities.
Risk table – what happens if you do not comply with the regulation
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Risks and sanctions |
How ARROWS helps (office@arws.cz) |
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Lobbying without registration: Fine of up to CZK 1,000,000 (or a % of turnover), ban on activity |
Assistance with registration and training: Attorneys from ARROWS, a Prague-based law firm, will ensure your registration is completed correctly. |
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False information in the register: High fines, loss of credibility |
Review and completion of the register: ARROWS, a Prague-based law firm, will audit your registration. |
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Failure to submit, or incomplete activity report: Fine for an administrative offence, risk of repeated sanctions |
Preparation of reports: The Czech legal team at ARROWS, a Prague-based law firm, will help you prepare each semi-annual report. |
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Reputational damage and increased state scrutiny: Investigations, compliance issues with partners |
Prevention and advisory: ARROWS, a Prague-based law firm, provides legal advisory (compliance) under Czech legislation. |
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Uncertainty in the application of the law and its exemptions: You do not know what must be reported and what does not |
Expert legal opinions: Experts from ARROWS, a Prague-based law firm, have experience interpreting Czech legislation. |
When you must lobby and when the law does not apply to you
This raises a practical question: who exactly does the Czech lobbying regulation law apply to? The law applies to those who systematically communicate with a defined group of public officials (so-called lobbied persons) with the aim of influencing legislation or policy/conceptual documents.
Who are “lobbied persons”
Under the law, lobbied persons include in particular:
- Members of Parliament and Senators of the Parliament of the Czech Republic
- Members of the Government (ministers), their deputy ministers and state secretaries
- Heads of central administrative authorities and their deputies
- The President of the Republic and the head of the Office of the President of the Republic
- Members of the CNB Bank Board (within the scope of commenting on legal regulations)
- Members of councils of independent authorities (e.g., RRTV, ČTÚ, ÚOHS)
If you are trying to push through a change in the law with an MP or a minister, this is contact with a lobbied person. If you approach a rank-and-file officer or an assistant, the situation may be different, although lobbying often indirectly targets public officials.
What is not considered lobbying
The law contains exemptions from its scope. Lobbying is generally not:
- Inter-ministerial comment procedure – submitting comments via eKlep/ODok.
- Meetings within administrative or court proceedings – where procedural standing is governed by other laws ( etc.).
- Activities of political parties and movements.
- Social dialogue – negotiations of trade unions and employers’ organisations.
- Communication through the media – press releases, public appearances.
- Activities of professional chambers established by law.
This is where many pitfalls lie. If you believe you are participating in a public debate, but in reality you are conducting parallel non-public negotiations with ministers, it may be lobbying. The line between transparent activity and lobbying is very thin, which is why ARROWS’ Prague-based attorneys advise on how to remain compliant with Czech law.
Obligations you have as a lobbyist
If you are a lobbyist and you register, you must meet several obligations:
1. Disclose your status – when contacting a lobbied person, you must state that you are a lobbyist and whose interests you represent.
2. Keep truthful records – the data in the register and in the reports must reflect reality.
3. Submit activity reports – submit a report twice a year for the previous period.
4. Report changes – if your details in the register change, you must notify the Ministry of Justice in the Czech Republic without undue delay.
Complexities in practice
In practice, the situation is more complex. For example, if a legal entity (a company) lobbies, it does so through natural persons (employees, managing directors). Responsibility for registration and reporting lies primarily with the registered lobbyist (i.e., the company).
ARROWS’ attorneys deal with these nuances on a daily basis and can provide clients with solutions that minimise the administrative burden while maintaining full legality under Czech legislation.
Related questions on the definition of lobbying
1. If I lobby without being entitled to remuneration, do I have to register?
Yes, if the activity meets the characteristics of lobbying (in particular, systematic conduct and the aim of influencing legislation), registration is required regardless of whether it is paid.
2. Is it considered lobbying if I am only arranging a meeting with a politician?
Administrative scheduling of a meeting is generally not lobbying. Lobbying is the actual communication aimed at influencing. However, if the meeting is part of a systematic effort, it must be recorded in the activity report.
3. What if I lobby through an agency?
The agency will register as a lobbyist and list you as its client. In that case, you do not have to be registered as a lobbyist if you do not act directly yourself. The agency is responsible for reporting the activity, but it is in your interest to contractually ensure that it does so properly.
Lobbying footprint – an obligation for the state
In connection with the new law, a so-called lobbying footprint is also being introduced. It forms part of the explanatory memorandum to draft legislation. The sponsor of the bill (e.g., a ministry) is required to state in the explanatory memorandum which lobbyists it consulted when preparing the draft and what material inputs were discussed.
This means that if you meet with a minister and try to persuade them to change a law, this contact may appear in a public document. The state thus transparently acknowledges who participated in the drafting of the regulation.
How to avoid problems – practical tips
To minimise risks, it is crucial to set up internal processes so that you do not breach the law without realising it.
- Find out whether you are lobbying at all
The first step is to clearly determine whether your activity is or is not lobbying. Ask yourself whether you are trying to systematically influence a lobbied person in the preparation of regulations. If the answer is yes, you must register. If you are unsure, ARROWS, a Prague-based law firm, will prepare a legal opinion for you. - Register in time
If you have concluded that you are engaging in lobbying, register. The Register of Lobbyists is maintained by the Ministry of Justice in the Czech Republic, and the process is electronic. The Czech legal team at ARROWS can assist you with the registration process and ensure that all details are correct. - Keep documentation
Even before you start lobbying, keep internal records of your activities. Record who you met with, when and where the meeting took place, and what it concerned. These records will be essential when completing the semi-annual activity report. - Prepare your activity report correctly
You must submit the report within the statutory deadlines, typically within 30 days after the end of the half-year period. The report must contain specific information, and if you omit it or submit it incomplete, you may face sanctions under Czech law. ARROWS regularly assists clients with preparing these reports. - Communicate your status clearly
When dealing with a public official, act transparently. The lobbied person has the right—and sometimes the obligation—to know who they are dealing with. - Monitor the interpretation of the law
The Lobbying Regulation Act is new, and its interpretation may be further clarified through methodologies issued by the Ministry of Justice in the Czech Republic. The attorneys at ARROWS monitor all legislative changes and can keep you informed on an ongoing basis.
Risk table – practical scenarios you may face
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Risks and sanctions |
How ARROWS helps (office@arws.cz) |
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Incorrect registration: Fine, invalidity of information |
Registration audit and remediation: ARROWS will review whether your registration is correct. |
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Failure to report changes: Fine for an administrative offence |
Management of registration data: The attorneys at ARROWS will ensure timely reporting of changes. |
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Uncertainty about the definition of lobbying: Risk of unintentional breach of the law |
Consultation and legal analysis: ARROWS will determine whether the activity constitutes lobbying under Czech legislation. |
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Incorrect or late submission of the report: Financial penalties |
Preparation and filing of reports: The attorneys at ARROWS will ensure timely and correct submission. |
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Administrative offence proceedings: Costs, sanctions, reputation |
Representation in proceedings: ARROWS will represent you in communications with the ministry. |
What happens if the ministry identifies a breach
If the Ministry of Justice in the Czech Republic identifies a suspicion of a breach of the law, it will typically initiate administrative offence proceedings. In these proceedings, the elements of the offence are assessed and a sanction is imposed. An appeal may be filed against the decision, and subsequently, if applicable, the matter can be challenged by an administrative action before the court.
A decision on an administrative offence may be recorded in the register of offences, and in the event of repeated breaches, the fine brackets increase.
The attorneys at ARROWS can represent you in any administrative proceedings and use all procedural tools available for your defence.
Specific situations – what companies often fail to clarify
- You are the initiator of legislation
If your company actively and consistently promotes a change in the law that would benefit you, and you communicate about it directly with lobbied persons, you meet the definition of lobbying under Czech law. - You work with a lobbying agency
If you hire professionals, the agency registers as the lobbyist and lists you as the client. It is important to have a contract that obliges the agency to comply with the lobbying law in the Czech Republic, so that you are not harmed by any inaction or error on its part. - Professional chamber or association
The activities of professional chambers established by law, when performing their statutory tasks, are generally exempt from lobbying regulation. However, if these entities step outside their statutory role and lobby beyond the scope of their tasks, the obligations may apply to them. - Small company
The law does not distinguish lobbyists by turnover size, but by the nature of the activity. If a small company lobbies consistently, it must register in the same way as a large corporation.
Conclusion
The Lobbying Regulation Act is a real part of the Czech legal system, and companies that lobby without registration risk fines and reputational issues. The law clearly defines the rules of the game and the transparency of the process.
The attorneys at ARROWS deal with this topic on a daily basis and can provide you with legal certainty to protect your business.
The simplest solution is to leave nothing to chance. Contact ARROWS, obtain legal advice, and find out exactly how you should proceed. ARROWS is insured for professional liability, which provides you with an additional guarantee of service quality. Email us at office@arws.cz and we will arrange a consultation.
FAQ – Most common legal questions on lobbying regulation
1. Do I have to register as a lobbyist even if I do not receive payment for it?
Yes, the law requires registration of anyone who lobbies on a sustained basis, regardless of whether the activity is paid. The decisive factors are continuity and the aim to influence regulation.
2. What happens if I do not keep records of my lobbying activities?
Without records, you will not be able to properly complete the semi-annual activity report. An incomplete report is an administrative offence for which a fine may be imposed. We recommend keeping records on an ongoing basis.
3. If I am registered but forget to submit the report – what are the consequences?
Failure to submit the report within the deadline is an administrative offence. A fine may be imposed. The ministry will likely first invite you to remedy the situation, but if you remain inactive, it will impose a sanction.
4. Can I hire an agency so that the law does not apply to me?
The agency will assume the registration and reporting obligation as the lobbyist. However, you will be listed in the register as the client. This ensures transparency, but the administrative burden of registration is borne primarily by the agency.
5. How do I know whether I have an obligation to register?
The key is sustained communication with lobbied persons for the purpose of influencing legislation. If you are unsure, it is best to consult the situation with a lawyer—ARROWS can provide you with a clear position. Write to office@arws.cz.
Notice: The information contained in this article is of a general informational nature only and is based on the legislation valid and effective as of the publication date (taking into account the status as of 2026). Legal regulations and their interpretation may change. To address your specific situation, it is necessary to contact ARROWS directly (office@arws.cz). We accept no liability for damages arising from the use of this information without individual legal advice.
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