COMPARATIVE ANALYSIS OF MODELS OF LEGAL REGULATION OF LOBBYING ACTIVITIES IN FOREIGN PRACTICE
Abstract
Abstract. The article provides a comprehensive, comparative analysis of legislative lobbying activity regulation models in terms of their historical evolution, institutional design, and compliance with modern international standards. Using legal and historical legal methods, as well as functional and systemic approaches, the study identifies universal criteria for evaluating the effectiveness of lobbying legislation, including the degree of formalization of legal norms, breadth of subject coverage, level of procedural transparency, and reliability of oversight and sanctioning mechanisms. The Anglo-Saxon model demonstrates the highest level of openness, thanks to its mandatory lobbyist registries, quarterly or monthly activity reports, and independent supervisory bodies authorized to apply administrative and criminal sanctions. In contrast, the traditional continental model, which was characteristic of many European jurisdictions until the early 2000s, primarily relied on «soft law» instruments, such as codes of ethics, parliamentary rules of procedure, and fragmented anti-corruption laws. This led to narrow regulatory coverage and weak enforcement. However, the study reveals a noticeable trend toward convergence between these two models. Due to high-profile lobbying scandals, public demands for accountability, and regulatory pressure from international organizations, an increasing number of continental states are adopting strict legal solutions. France, Germany, and Ireland are cited as examples of countries that have recently introduced mandatory transparency registers, comprehensive disclosure obligations, and graduated sanction regimes. Based on this comparative analysis, the article proposes a conceptual plan to reform Ukrainian lobbying legislation. The implementation of these measures is expected to legitimize lobbying as a democratic channel for representing interests and strengthen public trust in state institutions. Thus, the article contributes to Ukrainian legal science by organizing global regulatory approaches to lobbying, identifying their strengths and weaknesses, and offering practical recommendations for reforming domestic legislation based on the best practices.
Keywords: lobbying regulation; Anglo-Saxon model; Continental model; transparency standards; Ukraine; comparative law; public integrity.
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