Sure. I might just cover this bit here about approach to implementation and that'll give some outline and I'll deal with the issues that we face at the moment. When the register was being established, there was an external need for an effective communication strategy, with the wide-ranging scope of the legislation, we needed a cultural shift, needed stakeholder buy-in, so there was a lot of building awareness of the provisions and obligations. Internally, we needed an appropriate management and administration framework, technological systems and a need to build knowledge and capacity. Back before 2015, there was early planning and preparation, devising the governance structure, developing the register and the website. There was a trial period for registrants, so during the period 2015-16, we did not impose penalties; we encouraged people to come on the register, learn how it worked, but once it came to January 2016, penalties were imposed.
There was an incremental commencement of the Act, so designated public officials were identified, and it's only now that that list is being increased. Investigation and enforcement were in force after one year, with plans of legislator reviews, of which we've had a few. There were initial and ongoing stakeholder consultations, so there was a legislative consultation process, there was consultation with departments and there was an advisory group established with a broad grouping across industry and all those representative bodies. There were extensive communications and outreach, website guidance, info events, advertising, media engagement, and we still engage with all that. And then there was a requirement to establish management, administration and strategic frameworks and delegated authorities.
So, I suppose, just going back to your original question, Vikki, there would have been a large amount of resistance, particularly in certain parts of the political sector. County councillors didn't really feel that the work that they were doing should be reported, and that would have applied to many members of the Dáil as well. But, as time has gone by, that has lessened, because a key element of the legislation is that all politicians have become aware of it, and they will frequently say to somebody who might be lobbying, 'I think you need to be on the register.' So, although the designated public officials have no obligations themselves under the Act, they will tell lobbyists that they should be on the register. Also, we have the provision under the investigatory powers to request records from politicians of meetings they have had. So, if we hear a report of unregistered lobbying, we can investigate it and find out about it.
Broadly, the register works very effectively, because it puts the onus on the individual to make the return; we're not chasing each and every one, but we review all the returns that come in and we review all the registrations that come in. Clearly, that takes time. There's a lot of phone calls, a lot of e-mails. Broadly, it works well. If I was to say where the challenge is, day to day, for the operation of the register, I think, if you were to look at it, we spend a lot of time chasing small fry when, really, we should be spending our time on bigger issues. So, as much as possible, we're trying to raise awareness amongst the smaller organisations and individuals of their obligations under the Act, so that they don't fall foul of it, and we don't have situations where people are calling us up saying, 'I only registered once to do one bit of lobbying, and now you're fining me', because they didn't make a return. We're trying to eliminate that as much as possible. As you know, we send out welcome letters, we talk to people who are new on the register, we advise them of their obligations, but many of them still forget it and ignore it, and then they get hit with a fine and we spend time dealing with that and trying to resolve it.