Reform Space to Watch: Strengthening Anti-Corruption Measures in the United Kingdom

This series was written in consultation with the Transparency International chapters in each country. The reforms described in this series build on priority areas identified in the 2022 Broken Links report, which was written with the support of the Global Data Barometer (GDB) and the Data for Development Network, based on GDB’s survey data.

As one of the founding governments of OGP, the United Kingdom (UK) has been a steadfast leader in innovative open government and anti-corruption reforms. At the same time, concerns have been raised about lingering corruption risks in areas like personal protective equipment procurement and standards in public life, along with core issues of transnational corruption, such as foreign ownership of real estate and strategic litigation against public participation (SLAPPs). 

In 2013, the UK became the first country to make an OGP commitment on beneficial ownership transparency. This commitment led to the creation of a beneficial ownership register and caused a ‘ripple effect’ of many more OGP members choosing to advance beneficial ownershipDisclosing beneficial owners — those who ultimately control or profit from a business — is essential for combating corruption, stemming illicit financial flows, and fighting tax evasion. Technical... reforms in their own countries.

Since that first commitment, the UK has continued to demonstrate its dedication to various anti-corruption efforts. In September 2021, the UK – along with OGP and Open Ownership – convened the Beneficial Ownership Leadership Group, and its most recent 2021-2023 OGP action plan included commitments to improving open contracting practices and tackling international illicit finance. In 2022, the UK government approved the implementation of the Beneficial Ownership Data Standard for the collection, use, and exchange of beneficial ownership data.

But issues like money laundering and illicit financial flows are anything but resolved in the UK. Following the Russian invasion of Ukraine, the spotlight fell on the laundering of illicit gains through UK property. The UK government responded by establishing a “Register of Overseas Entities” in 2022, which requires overseas companies holding UK property to identify their beneficial owners, in hopes of rooting out dirty money in UK real estate.

As the UK co-creates its sixth OGP action planAction plans are at the core of a government’s participation in OGP. They are the product of a co-creation process in which government and civil society jointly develop commitments to open governmen... with civil society, anti-corruption reforms remain a focus. Beneficial ownership and lobbyingLobbying transparency allows the public to ensure that there is diversity of participation and contribution to public decision-making. Technical specifications: Policies and actions affecting lobbying... transparencyAccording to OGP’s Articles of Governance, transparency occurs when “government-held information (including on activities and decisions) is open, comprehensive, timely, freely available to the pub... More, in particular, are two areas that stakeholders have identified as ripe for increased reform. Here is a closer look at potential opportunities in these areas.

• Beneficial Ownership Transparency: The United Kingdom has pursued beneficial ownership reforms in three of its last four OGP action plans. OGP’s 2022 Broken Links report highlights many potential improvements that could be the focus of a new beneficial ownership commitment, including requiring more detailed information on interests held by beneficiaries or improving interoperability with other key datasets, like public procurement. Transparency International UK maintains that more transparency is needed around beneficiaries of trusts that own or control registered companies, property, or overseas entities, and hopes this will form part of the UK’s next action plan.
• Lobbying Transparency: In 2014, the UK passed a major lobbying act. The act has been controversial, with some saying it leaves loopholes in key areas and others arguing it has had a chilling effect. Access to government – by lobbyists, donors and other vested interests – is currently not equal in the UK. Transparency International UK remains keen on two additional areas of reform: 1) strengthening minimum standards for meeting descriptions; and 2) extending reporting obligations so that they cover informal lobbying and apply to all lobbyists, rather than only consultant lobbyists. Across their first five OGP action plans, the UK did not make any commitments related to lobbying transparency, but they are not alone. Less than a quarter of OGP countries have made a lobbying-related commitmentOGP commitments are promises for reform co-created by governments and civil society and submitted as part of an action plan. Commitments typically include a description of the problem, concrete action.... 

Perhaps that will change in the UK’s next action plan. In July 2023, the UK’s governing party publicly committed to a number of improvements to the lobbying transparency regime, including introducing a single database for transparency returns and improving the quality of information revealed about lobbying meetings. A timeline for implementation is yet to be established. Closely related to this issue, the UK Open Government Network, Transparency International UK, and partners are keen for the Government to convene a working group of civil society organizations, experts and government officials to advance work on improving public standards and accountability.  

Which of these anti-corruption reforms will be included in the UK’s sixth OGP action plan? Whether inside or outside of the OGP process, how will the UK address these civil society priorities? These questions will begin to be answered when the UK’s next action plan is due at the end of 2023.