Transparency Code for a “relevant body” (working groups etc.)

A critical element of public policy formulation is the availability to Ministers and Public Bodies of expertise, skills and knowledge from persons outside of the public service. Often this process is formalised by the establishment of a task force, working group, etc. to focus on the examination of a particular policy issue or set of related issues. These groups are representative of key stakeholders and experts in relation to the matters being reviewed.  

In light of the different nature of engagement between public officials and non-public servants in that type of forum, the Act does not seek to capture and register those interactions as lobbying communications where appropriate transparency arrangements are in place.

The Act, therefore, provides for an exception from the requirement to register in such cases once specified transparency criteria apply. The particular exception in the Act is for communications between members of certain types of such working groups, task forces, committees, etc. where the group in question complies with the Transparency Code established by the Minister for Public Expenditure and Reform.   Such groups are defined in the Act as a “relevant body”. A copy of the Code is available for reference online at

The exception in relation to Policy Working Groups only applies to a “relevant body” as defined in the Act. In order to be regarded as a relevant body the group must meet the following four conditions:

  1. The group is set up by a Minister or public service body[1], and
  2. Its membership consists of at least one Designated Public Official (DPO)[2] and at least one person who is neither employed or engaged by a public service body, and
  3. The group is reviewing, assessing or analysing any issue of public policy with a view to reporting to the Minister of the Government or the public service body on it, and

The group conducts its activities in accordance with the criteria set out in the Transparency Code.

[1] A public service body is defined in the Regulation of Lobbying Act 2015, section 7.

[2] A Designated Public Official is defined in the Regulation of Lobbying Act 2015, section 6.