Shadow lobbying describes efforts to influence government by people who are not registered under the Lobbying Disclosure Act. Many former members of Congress, senior staff, and executive officials call themselves strategic advisers, consultants, or counselors. They help clients plan campaigns, tell them whom to call and what to say, and sometimes arrange meetings, but avoid making direct contacts or keep their lobbying under 20 percent of their time, so they need not register.
The practice lets former officials work for interests related to their old jobs during cooling-off periods, since the ban covers contacting former colleagues, not advising behind the scenes. The number of registered lobbyists fell for years after the 2007 disclosure reforms even as spending rose, which researchers take as a sign that many people moved into unregistered roles. Public relations campaigns, think tank funding, and grassroots mobilization also fall outside the reports.
Reformers propose lowering the 20 percent threshold, requiring registration for strategic advice, and extending lobbying bans for former members and senior officials. Opponents say broad definitions would sweep in lawyers, consultants, and citizens exercising the right to petition, and that disclosure already reveals the biggest players. Watchdog groups track shadow lobbyists through news reports and corporate filings, but no official count exists.
| Status | Active |
| Legal basis | Lobbying Disclosure Act 20 percent threshold (2 U.S.C. 1602) |
| Official site | opensecrets.org |
| Definition | Influence work by people who do not register |
| Common titles | Strategic adviser, consultant, counselor |
| Key loophole | The 20 percent time threshold |
| Official count | None |
| Reform idea | Require registration for strategic advice |
| Date | Grew after the 2007 disclosure reforms |