Written Supplementary evidence submitted by Transparency International UK



key messages

  1. The way the MPs’ interests are published does not meet good practice standards. This inhibits the ability of constituents and others to monitor potential conflicts between parliamentarians’ private and public affairs.
  2. The Committee on Standards in Public Life have been calling for the Register of Members’ Financial Interests (RMFI) be made more accessible and useable since 2009.
  3. TI-UK helped Parliament Digital Service (PDS) create a blueprint for this new system in 2017 however since then progress has stalled.


MPs must disclose a range of financial and non-financial interests in a timely manner. The purpose of these requirements is to provide transparency over interests that may reasonably be thought could have a bearing on their actions.[1] Currently there are ten categories of financial interests MPs must report against, including any donations they receive and any outside employment they have (see Annex for more details).

There are some overlaps between the reporting requirements of the Commons’ code of conduct and those for political parties, politicians and others campaigning at elections under the Political Parties, Elections and Referendums Act (PPERA). Since 2009, MPs only have to report political donations covered by PPERA to the parliamentary authorities, who then pass on details to the Electoral Commission. This arrangement is a useful case study to highlight deficiencies in the House of Commons’ current approach to publishing members’ financial interests.

Information forwarded to the Electoral Commission is published on its online search portal http://search.electoralcommission.org.uk/ This allows users to search quickly and accurately how many donations an MP has received, when and of what value. According to this data, since 2001 927 MPs have received a total of 5,153 donations totalling £ 29,537,853. To obtain these headline statistics took us less than one minute. This is because the data is downloadable as a CSV file, which you can open and analyse in Microsoft Excel.

By comparison, the Register of Members Financial Interests publishes this same information in PDF documents and on Parliament’s website as a HTML webpage. To calculate the same number we would have to:

Using a very conservative estimate of one minute per donation, we calculate that to do the same task using the current RMFI method of publication would take at least ten working days.[2]

Whilst information on political donations is published separately in a more accessible format by the Electoral Commission, other parts of MPs’ disclosures are not. For example, to answer a supposedly simple questions like how many MPs hold outside employment, how much time have they spent on these jobs, and how much have they received in return would require a punishingly time-consuming process as mentioned above.


The general approach to publishing MPs’ financial interests will remain, although the technology deployed will be more advanced and easier to use. Figure 1 below provides a high-level overview of the three steps to publication. Whilst the specifics of how this would work in practice need to be designed by Parliament Digital Service, the base technology for deploying this solution already exists.

Figure 1: Proposed new process for financial interest publication

A critical difference between the current and proposed new approach is the improved management of data input. Currently, MPs provide information in free text form, which inhibits quick and meaningful analysis of data. For example, the following record was taken from the current register of interests under 1. Employment and earnings:

From 28 September 2020 until further notice, Consultant Global Counsel (international legal services) to Withers LLP, 20 Old Bailey, London EC4M 7AN. I will receive £468,000 plus VAT annually, to be paid quarterly, in return for an expected commitment of up to 48 hours a month. (Registered 19 October 2020)

Below we outline how the same data would be collected under the proposed new approach. Note the only addition to the above is the company number. This is a unique reference identifying exactly which company employs the MP. Currently, it is a legal requirement for MPs to include company numbers in their donation reports to the Registrar, but not in relation to their employers.

Date registered: 19 October 2020

Date from: 28 September 2020

Date to:

Employed by: Withers LLP

Company number: OC301149

Position: Consultant Global Counsel (international legal services)

Employer address: 20 Old Bailey, London EC4M 7AN

Payment amount: 468,000 [field limited to numbers]

Payment currency: £ sterling [chosen from a drop-down box]

Payment frequency: quarterly [chosen from a drop-down box]

VAT incl. (true/false): False [tick box]

Time worked unit: 48 [field limited to numbers]

Time work unit type: monthly [chosen from a drop-down box]

There are a number of possible technical solutions to storing this information, but we envisage there would be separate data ‘tables’ for each reporting category. These tables would provide a standard template for MPs to report their interests against.

To help collect this data, we envisage there would be the options of using an online form or Excel template to allow MPs to report quickly and in bulk, if needs be. We use forms like these regularly in our everyday lives; for example, providing a delivery address for products bought online. They provide a quick, secure and intuitive way to gather data.

When data is ready for publication, it could be published in a variety of different formats to suit users’ needs. We have provided below some examples of what similar disclosure systems look like to the public. The first is the Electoral Commission’s online registers, which includes both an online search tool and an option for users to download data on a range of financial information, including donations, loans, spend at elections and statement of accounts.

The second is a tool produced by Transparency International Italy to help make their politicians’ financial interests more searchable and accessible, with a view to encouraging their Parliament to improve how they publish this information. The third is a similar tool developed by our colleagues in France for the same purposes.

Figure 2: Electoral Commission register of donations http://search.electoralcommission.org.uk/

Figure 3: Transparency International Italy online search tool for politicians' private interests http://www.soldiepolitica.it/interessi.php

Figure 4: Transparency International France's online search tool for politicians' financial interests https://www.integritywatch.fr/old_version/index.html


11 February 2021

Annex: RMFI reporting categories




Financial threshold for registration

1. Employment and earnings

Over £100 for individual payments


Over £300 for the total of multiple payments of whatever size from the same source in a calendar year

2. Donations and other support

Over £1,500, either as individual payment, or for the total of multiple donations of more than £500 from the same source in the course of a calendar year

3. Gifts, benefits and hospitality from UK


Over £300 for the total of benefits of whatever size from the same source in a calendar year

4. Visits outside the UK

Over £300 if not wholly borne by Member

or public funds


Threshold also applies to the total of benefits of whatever size from the same

source in a calendar year

5. Gifts and benefits from sources outside

the UK

Over £300 for the total of benefits of whatever size from the same source in a calendar year

6. Land and property in the UK and


Total value of property held: over £100,000 Income derived from property: over £10,000 in a calendar year

7. Shareholdings

Greater than 15% of issued share capital (on preceding 5 April), or if 15% or less of issued share capital (on preceding 5 April), greater in value than £70,000

8. Miscellaneous

No threshold

9. Family members employed and remunerated through parliamentary expenses

Remuneration of over £700 in a calendar year

10. Family members engaged in lobbying

No threshold



[1] House of Commons, The code of conduct together with the guide to the rules relating to the conduct of members (October 2019) Paragraph 5 page 10 https://publications.parliament.uk/pa/cm201719/cmcode/1882/1882.pdf

[2] This assumes a solid eight hour day without a break.