Mr. János Bertók:

There are two important aspects. The first relates to the information that can go public or be made available for the public or competitors. In that sense there is no difference between what is commercially sensitive information and what is done in private that is covered by freedom of information law. Certain information remains under the scope of freedom of information law and, therefore, there is no additional legitimacy in another Act to bring it out. In concrete terms, this means that in the legislation or the reporting lobbyists are not required to provide commercially sensitive information. They can highlight an issue - for example, what the aim is - or they can report who the client is but without providing information on the actual contractual details or other details, in other words, what is commercially sensitive. This allows for the provision of more general information, even in the case of negotiations or pushing certain positions in a defence contract. It allows generally for highlighting the subject but not providing detailed commercially sensitive information. That is one aspect.

The second aspect relates to how one strikes a balance. In the legislation in some countries they have taken out exemptions because they do not consider many types of lobbying to be a source of concern or very important. I understand that in Ireland people consider the level playing field to be more important. In other countries the approach is to have certain thresholds for reporting. This can depend on time spent or certain expenses involved. Some countries do not require all small interactions with public officials to be reported or even for those involved to be registered. However, if interactions occur more frequently and go above the threshold, the people involved are automatically subject to registration and reporting.

Another aspect is keeping the burden low. The OECD survey showed that a considerable number of lobbyists showed a willingness. If the legislation specifies a period of less than half an hour, they consider this sufficient and not burdensome. The attitude was similar if the reporting did not take too much time because of its simplicity. Again, this stems from a regulatory impact analysis and a simplification process. If the process is considered not to be burdensome, it can provide sufficient incentives such that even those who are not frequently involved such as charitable organisations or churches can be subject to the legislation and reporting.