Good evening.

Thank you for inviting me to speak at your general assembly today.

My mission as European Ombudswoman is to promote good administration in the EU’s institutions, bodies, offices, and agencies – to ensure that EU decisions are taken in a manner that is transparent, accountable, inclusive, and always in the public interest.

This involves not only examining how specific rules and procedures were applied, but also investigating who did and did not have the opportunity to take part in the decision-making process – and what effect this might have on the outcome.

In other words, I look into influence. And whether it is undue.

I know that when this word appears in the media or in popular discourse, it tends to be considered in a negative way – to highlight the withdrawal or watering down of specific regulations due to industry pressure, or to question whether a particular decision was truly taken with the public interest in mind.

These are valid concerns. And they underscore the need for public institutions and the public affairs industry alike to maintain and enforce robust conflict of interest and ethics rules – which is precisely what brings us together today.

But I also fully recognise the importance of civil society and businesses being able to effectively express their views and participate meaningfully in the decision-making process.

Well-regulated and transparent public affairs work is not a threat to democracy – it is an expression of it. It ensures that the voices of vital economic sectors are heard and understood. It provides public officials with the expertise and data they need to adopt rules and regulations that are grounded in reality and serve the public well. And it gives legitimacy to outcomes that affect millions of people across the continent.

You, as professional lobbyists, are part of that process. And the quality of that process matters enormously.

Today I want to speak to you about three difficulties that I believe deserve our collective attention – three areas where the conditions for healthy, legitimate, and effective engagement between the public and private sectors are under strain.

The first difficulty is one you may already feel in your daily work: it has become significantly harder to participate meaningfully in EU decision-making.

I am not referring only to citizens and civil society organisations. I am also referring to businesses of all sizes and the trade associations that represent them. The space for structured, substantive engagement is narrowing – and the primary driver is speed.

The EU administration is under increasing pressure to revise existing rules rapidly in response to an increasingly uncertain geopolitical environment. But speed has a cost and that cost is often borne by those who should have had a seat at the table.

Earlier this year, my Office concluded inquiries into the European Commission’s fast-tracking of three legislative proposals – the Omnibus sustainability package, changes to the Common Agricultural Policy, and new rules on migrant smuggling. In each case, the Commission had invoked urgency to set aside normal rule-making steps: public consultations were skipped, impact assessments curtailed, and structured stakeholder dialogue compressed or eliminated.

We found that this amounted to maladministration. The Commission had not sufficiently justified the urgency to the public, nor properly documented its derogations from its own Better Regulation rules. I want to be clear: swift action is sometimes genuinely necessary. But urgency is not a blank cheque.

Excluding stakeholders – even temporarily – has serious consequences. It feeds the perception that EU decision-making is remote and technocratic. It undermines compliance, since companies respect rules far more when they believe those rules emerged from a fair process. And it creates regulatory unpredictability that produces winners and losers by accident.

Some companies you represent invested heavily in early compliance with EU sustainability rules, expecting competitors to follow. A sudden reversal feels like a penalty for doing the right thing. That is not the message the EU should be sending.

I recommended that the Commission define what genuinely constitutes urgency, document derogations properly, and ensure that even fast-tracked legislation remains transparent and evidence-based. The Commission responded constructively and my Office is finalising its conclusions.

But the broader challenge remains. The pressure to legislate fast is not going away. Which is why the integrity of the process – the assurance that all voices have a genuine opportunity to be heard – matters more than ever.

I briefly mentioned earlier the importance of robust conflict of interest and ethics rules when it comes to interest representation. Allow me to return to this point, as it connects directly to some recent work of my Office.

What often causes the deepest public unease about lobbying is not lobbying itself. It is the question of fairness. Does one company or industry have the ear of politicians far more than another? Do some actors benefit from insider knowledge about how institutions work, about the rhythms of a legislative file, about which door to knock on? Is there, in short, a level playing field?

These questions go to the heart of democratic legitimacy. And your profession has a direct stake in answering them well – because when the answer is perceived to be ‘no’, it is often the entire industry that bears the reputational cost.

One of the most common ways unfairness manifests is through revolving doors. Let me be clear about what the problem is and what it is not. This movement is not inherently wrong – it can enrich both worlds. The problem arises when transitions are not properly managed, creating channels for privileged access, allowing confidential knowledge to be monetised, or giving rise to the perception that a regulatory outcome was shaped by a future employment prospect. At that point, trust collapses.

Most recently, my Office concluded a broad own-initiative inquiry into how 15 EU agencies manage this issue, reviewing 54 specific cases. We found good practices, but also significant discrepancies. Only around half the agencies examined had adopted rules on board members’ post-mandate activities. Only about one quarter monitor former staff compliance with post-service restrictions. There was also considerable variation in training, transparency, and mitigation measures.

Inconsistency breeds suspicion. When similar cases are handled differently across institutions, neither the public nor the private sector can know what the rules actually are.

In response, my Office published good practice guidelines organised around four principles: clear procedures, consistent decision-making, transparency, and effective enforcement. I intend to apply these as a benchmark in future cases.

For you as lobbyists, stronger and more consistent ethics rules are not a constraint. They are a guarantee of your integrity. Your credibility depends on the public believing that the access you have is earned through the quality of your arguments – not only through an advantage arising from a previous role as civil servant. The current patchwork of rules serves no one well. Not the public, not public servants, and not the professionals whose business it is to engage with institutions every day.

Strong rules, however, are only as effective as the culture that surrounds them. And this brings me to my third difficulty: the challenge of building genuine prevention and awareness – of moving beyond compliance on paper to integrity in practice.

Let me illustrate this with two concrete examples.

The first concerns tobacco lobbying.

As a signatory to the World Health Organization’s Framework Convention on Tobacco Control, the EU is legally obliged to limit its interactions with the tobacco industry to those strictly necessary for regulatory purposes – and to ensure that those interactions are transparent and publicly documented.

This is not a minor procedural requirement. It reflects a considered international commitment, grounded in decades of evidence about how the tobacco industry has historically sought to shape, delay, and weaken public health regulation. Transparency here is not bureaucratic formality. It is a safeguard.

And yet, an own-initiative inquiry my Office conducted revealed a significant gap between commitment and practice. Only two European Commission departments – those responsible for health and for taxation and customs – proactively published records of EU officials’ interactions with tobacco lobbyists, regardless of the seniority of the staff involved. Other departments only proactively disclosed meetings involving senior officials or Commissioners.

This means that across much of the Commission, routine interactions with tobacco lobbyists could go undisclosed – not because anyone has decided they should be hidden, but because no one built the systems and habits to make them visible. That is precisely the problem with a culture that focuses on rules without investing equally in awareness.

Following the publication of our findings, the Commission conducted an assessment of its departments’ exposure to tobacco lobbying and reported increased awareness among staff of their compliance obligations in this area. That is a step forward. But increased awareness is a beginning, not an end.

The second example concerns the Independent EU Ethics Body – a development I have followed closely and one that I believe matters enormously for everyone in this room.

After years of discussion, this body now appears to be closer to finally becoming operational. I am genuinely hopeful that it will help raise ethics standards across the EU administration and bring greater uniformity to a landscape that, as I described earlier, is currently fragmented and inconsistent. For companies and organisations engaging with EU institutions, that consistency would also mean greater clarity – knowing that the rules are the same regardless of which door you walk through.

But we are clearly not there yet. And I want to flag one important limitation that is sometimes overlooked in discussions about this body: it will not have the power to receive complaints directly from citizens.

That role will continue to belong to my Office. And I am committed to ensuring that we remain a recognised and effective reference point on ethics and integrity – not only for citizens seeking redress, but for institutions seeking guidance. Prevention and awareness require an anchor. We intend to be one.

Before I take your questions, allow me one final thought – and it is perhaps the most important one I want to leave you with today.

Much of my work involves examining rules and procedures: whether they are strong enough, whether they are properly enforced, whether there are gaps that require attention. That is the institutional dimension of integrity.

But good governance is ultimately about more than rules. It is about individuals. About personal responsibility. About the choices people make when no one is auditing them and when the rules leave room for discretion.

This is as true for interest representatives as it is for public servants.

I said at the outset that your work, when conducted with integrity, is a genuine contribution to participatory democracy. It brings the perspective of vital industries into the room. It equips decision-makers with expertise they would not otherwise have. It can produce better laws – laws that drive innovation, employment, and long-term prosperity.

But we have also seen the other side. Well-organised and well-funded influence operations that have sought to undermine or erode essential EU regulations – on climate, on artificial intelligence, on consumer rights, on public health. Operations that, whatever their short-term success, have weakened the quality of EU law-making and damaged public trust in the institutions that produce it.

With the challenges facing our Union today – geopolitical uncertainty, the climate transition, technological disruption, democratic fragility – this is a cost we simply cannot afford to keep paying.

That is why I want to ask you, directly and sincerely, to consider your work within the larger picture. The companies and organisations you represent have entrusted you with significant responsibilities. But your obligations do not end there. You also have obligations to your fellow citizens – to the quality of the democratic process and to the faith that people place in it.

The three difficulties I have described today – the shrinking space for participation, the patchwork of ethics rules, the insufficient culture of prevention – are not problems that institutions alone can solve. They require a private sector that demands better, professionals who hold themselves to higher standards, and an industry that understands that its long-term legitimacy depends on the health of the system it operates within.

I hope you will carry that understanding into your work. And I hope that the advocacy you conduct will not only serve the interests of those you represent, but also contribute to a stronger Europe and a more sustainable future for all of us.

Thank you.