I have received a third reply from the Lords' Registrar. My reply is below:
"RE: RE: Subject: Request for Clarification: Registration of Interests for New Members Upon Introduction
LR
To: Alison Wright;
23/05/2025 14:26
2
Dear Ms Wright,
Thank you for your email.
My advice to members and their staff is given in confidence. It is not the role of the registrar to make public pronouncements on how the code of conduct should be interpreted.
Yours sincerely,
Nicolas Besly"
My reply:
Dear Mr Besly,
Thank you for your reply.
I appreciate that advice to individual members is given in confidence. However, the Guide to the Code of Conduct (13th Edition, September 2023) makes clear that the Registrar’s role includes providing interpretive guidance on the Code’s requirements, and that the Registrar “is available to advise members of the House, and may consult the Committee when necessary” (Guide, p. 7). The Guide further states that “a member who acts on the advice of the Registrar in determining what the member is required to register or declare as a relevant interest fully satisfies the requirements of the Code of Conduct as regards registration or declaration” (Guide, p. 8).
Given the public importance of clarity on this point, and the fact that your advice helps set standards for both members and public understanding, I respectfully request that you either:
confirm the general principle that the initial registration should reflect all interests held at the date of introduction (even if resigned within the first month), or
refer this matter to the Conduct Committee for formal clarification, as permitted by your role.
This is not a request for confidential advice, nor for you to comment on the Commissioner’s decision in a specific case, but for clarity on a matter of public and constitutional significance.
The Lords' Registrar responded quickly and I've replied.
"Subject: Request for Clarification: Registration of Interests for New Members Upon Introduction
LR
To: Alison Wright;
23/05/2025 13:02
Dear Ms Wright,
Thank you for your email.
As you state, these matters were raised by you in correspondence with the Commissioner for Standards following a complaint you made. It would not be appropriate for me to second-guess the commissioner, so I do not wish to add to what the commissioner wrote to you.
Yours sincerely,
Nicolas Besly
Registrar of Lords’ Interests"
As the Registrar he ought to be able to provide clarity on this important point, independent of the Commissioner for Standards. I have sent the following response:
Dear Mr Besly,
Thank you for your prompt reply.
I appreciate that the Commissioner for Standards has ruled on my complaint. However, as Registrar of Lords’ Interests, your published duties include advising members and their staff on their obligations under the Codes of Conduct and providing interpretive guidance on registration requirements, independent of any investigation or complaint.
Given the significance of this point for the integrity of the Register and the Code’s stated purpose of “openness and accountability,” I am seeking your expert clarification on the following matter of interpretation:
Does the obligation to register interests within one month of taking a seat require new members to declare all interests held at the date of introduction, even if those interests are resigned within the first month?
I am not seeking a review of the Commissioner’s decision, but rather your guidance as Registrar for the benefit of all members and the public. If you feel unable to provide a view, could you please confirm whether you will refer this matter to the Conduct Committee for formal clarification?
Thank you for your attention to this important point.
Yours sincerely,
Alison Wright
Citation:
Current-at-March-2025-hl-code-of-conduct.pdf, Guide to the Code of Conduct, “Advice and review,” p. 7-8.
Subject: Request for Clarification: Registration of Interests for New Members Upon Introduction
Dear Registrar,
I am writing to request formal clarification regarding the requirements for new members of the House of Lords to register their interests upon taking their seat, specifically under the 13th Edition of the Code of Conduct (September 2023), which governed introductions in July 2024.
Recent correspondence from the Commissioner for Standards’ office has stated that new members are required to submit a registration form within one month of taking their seat, but that the initial registration need not account for interests held at the moment of introduction if those interests are relinquished before the form is submitted. This interpretation appears to treat the one-month period as a grace period, rather than a deadline for declaring all interests held on the date of introduction.
However, paragraph 40 of the Guide to the Code of Conduct (13th Edition) states:
“Members of the House of Lords are required to complete a registration form and submit it to the Registrar of Lords’ Interests within one month of taking their seat.”
A reasonable reading of this provision, in line with the Code’s stated purpose of “openness and accountability” (paragraph 3), is that all relevant interests held as at the date of introduction must be declared within one month, regardless of whether they are resigned during that period. Treating the one-month period as a window in which interests can be omitted by resigning them before registration undermines transparency and creates a significant loophole.
Additionally, paragraph 46 provides that:
“All interests stay on the Register for one year after the date on which the interest ceased. An interest which is registered late and has already ceased by the time it is disclosed shall however remain on the Register for one year after the date of disclosure.”
This further supports the principle that interests held at the time of introduction should be declared, and if registered late, should remain visible for one year after disclosure.
Could you please confirm:
Is it the official position that the initial registration must include all interests held at the date of introduction, even if those interests are resigned within the first month?
If not, could you clarify the rationale and indicate whether the Conduct Committee has considered the transparency risks associated with the alternative interpretation?
I would appreciate your guidance on this point, as it is fundamental to public confidence in the Register and the standards expected of new members.
Thank you for your assistance.
Yours sincerely,
Alison Wright
(Address provided)
References:
House of Lords Code of Conduct (13th Edition, September 2023), Paragraphs 3, 40, 46.
Guide to the Code of Conduct (13th Edition, September 2023).
I have passed on your email to the Commissioner, and she has asked me to respond on her behalf.
The Guide to the Code of Conduct requires new members to submit a registration form within one month of taking their seat, it does not specify that their initial registration must account for their interests at the moment of introduction.
The Commissioner’s decision to dismiss your complaint is final and there is no right of appeal.
Kind regards,
Standards Clerk
Journal Office
House of Lords"
The House of Lords has confirmed it does not require new members to declare all interests held on the day they join—only those still held when they submit their first register, up to a month later. This means a peer can resign a directorship or interest within their first month and never have to disclose it to the public.
This lax approach creates a loophole that risks hiding conflicts of interest at the very moment a peer enters Parliament, undermining transparency and public trust.
I have received a third reply from the Lords' Registrar. My reply is below:
"RE: RE: Subject: Request for Clarification: Registration of Interests for New Members Upon Introduction
LR
To: Alison Wright;
23/05/2025 14:26
2
Dear Ms Wright,
Thank you for your email.
My advice to members and their staff is given in confidence. It is not the role of the registrar to make public pronouncements on how the code of conduct should be interpreted.
Yours sincerely,
Nicolas Besly"
My reply:
Dear Mr Besly,
Thank you for your reply.
I appreciate that advice to individual members is given in confidence. However, the Guide to the Code of Conduct (13th Edition, September 2023) makes clear that the Registrar’s role includes providing interpretive guidance on the Code’s requirements, and that the Registrar “is available to advise members of the House, and may consult the Committee when necessary” (Guide, p. 7). The Guide further states that “a member who acts on the advice of the Registrar in determining what the member is required to register or declare as a relevant interest fully satisfies the requirements of the Code of Conduct as regards registration or declaration” (Guide, p. 8).
Given the public importance of clarity on this point, and the fact that your advice helps set standards for both members and public understanding, I respectfully request that you either:
confirm the general principle that the initial registration should reflect all interests held at the date of introduction (even if resigned within the first month), or
refer this matter to the Conduct Committee for formal clarification, as permitted by your role.
This is not a request for confidential advice, nor for you to comment on the Commissioner’s decision in a specific case, but for clarity on a matter of public and constitutional significance.
Thank you for your attention.
Yours sincerely,
Alison Wright
The Lords' Registrar responded quickly and I've replied.
"Subject: Request for Clarification: Registration of Interests for New Members Upon Introduction
LR
To: Alison Wright;
23/05/2025 13:02
Dear Ms Wright,
Thank you for your email.
As you state, these matters were raised by you in correspondence with the Commissioner for Standards following a complaint you made. It would not be appropriate for me to second-guess the commissioner, so I do not wish to add to what the commissioner wrote to you.
Yours sincerely,
Nicolas Besly
Registrar of Lords’ Interests"
As the Registrar he ought to be able to provide clarity on this important point, independent of the Commissioner for Standards. I have sent the following response:
Dear Mr Besly,
Thank you for your prompt reply.
I appreciate that the Commissioner for Standards has ruled on my complaint. However, as Registrar of Lords’ Interests, your published duties include advising members and their staff on their obligations under the Codes of Conduct and providing interpretive guidance on registration requirements, independent of any investigation or complaint.
Given the significance of this point for the integrity of the Register and the Code’s stated purpose of “openness and accountability,” I am seeking your expert clarification on the following matter of interpretation:
Does the obligation to register interests within one month of taking a seat require new members to declare all interests held at the date of introduction, even if those interests are resigned within the first month?
I am not seeking a review of the Commissioner’s decision, but rather your guidance as Registrar for the benefit of all members and the public. If you feel unable to provide a view, could you please confirm whether you will refer this matter to the Conduct Committee for formal clarification?
Thank you for your attention to this important point.
Yours sincerely,
Alison Wright
Citation:
Current-at-March-2025-hl-code-of-conduct.pdf, Guide to the Code of Conduct, “Advice and review,” p. 7-8.
To:
Registrar of Lords’ Interests
House of Lords
London SW1A 0PW
23 May 2025
lordsregistrar@parliament.uk
Subject: Request for Clarification: Registration of Interests for New Members Upon Introduction
Dear Registrar,
I am writing to request formal clarification regarding the requirements for new members of the House of Lords to register their interests upon taking their seat, specifically under the 13th Edition of the Code of Conduct (September 2023), which governed introductions in July 2024.
Recent correspondence from the Commissioner for Standards’ office has stated that new members are required to submit a registration form within one month of taking their seat, but that the initial registration need not account for interests held at the moment of introduction if those interests are relinquished before the form is submitted. This interpretation appears to treat the one-month period as a grace period, rather than a deadline for declaring all interests held on the date of introduction.
However, paragraph 40 of the Guide to the Code of Conduct (13th Edition) states:
“Members of the House of Lords are required to complete a registration form and submit it to the Registrar of Lords’ Interests within one month of taking their seat.”
A reasonable reading of this provision, in line with the Code’s stated purpose of “openness and accountability” (paragraph 3), is that all relevant interests held as at the date of introduction must be declared within one month, regardless of whether they are resigned during that period. Treating the one-month period as a window in which interests can be omitted by resigning them before registration undermines transparency and creates a significant loophole.
Additionally, paragraph 46 provides that:
“All interests stay on the Register for one year after the date on which the interest ceased. An interest which is registered late and has already ceased by the time it is disclosed shall however remain on the Register for one year after the date of disclosure.”
This further supports the principle that interests held at the time of introduction should be declared, and if registered late, should remain visible for one year after disclosure.
Could you please confirm:
Is it the official position that the initial registration must include all interests held at the date of introduction, even if those interests are resigned within the first month?
If not, could you clarify the rationale and indicate whether the Conduct Committee has considered the transparency risks associated with the alternative interpretation?
I would appreciate your guidance on this point, as it is fundamental to public confidence in the Register and the standards expected of new members.
Thank you for your assistance.
Yours sincerely,
Alison Wright
(Address provided)
References:
House of Lords Code of Conduct (13th Edition, September 2023), Paragraphs 3, 40, 46.
Guide to the Code of Conduct (13th Edition, September 2023).
Response received today:
"To: Alison Wright;
22/05/2025 19:30
Dear Ms Wright,
I have passed on your email to the Commissioner, and she has asked me to respond on her behalf.
The Guide to the Code of Conduct requires new members to submit a registration form within one month of taking their seat, it does not specify that their initial registration must account for their interests at the moment of introduction.
The Commissioner’s decision to dismiss your complaint is final and there is no right of appeal.
Kind regards,
Standards Clerk
Journal Office
House of Lords"
The House of Lords has confirmed it does not require new members to declare all interests held on the day they join—only those still held when they submit their first register, up to a month later. This means a peer can resign a directorship or interest within their first month and never have to disclose it to the public.
This lax approach creates a loophole that risks hiding conflicts of interest at the very moment a peer enters Parliament, undermining transparency and public trust.
#HouseofLords #Transparency #Accountability #Parliament #PublicTrust