How many lobbyists are in Washington? Shadow lobbying and the gray market for policy advocacy


How many lobbyists are in Washington, and how common is it for them to have worked in the federal government? We assume that high-profile cases like former Senator Tom Daschle—the namesake of the so-called Daschle loophole to the Lobbying Disclosure Act (LDA) in the USA—are not isolated. In this article, we systematically account for lobbying and policy advocacy in as large an empirical scope as possible to uncover the presence of ‘shadow lobbyists.’ Using a new data set of professional biographies of both registered lobbyists and unregistered policy advocates, we estimate that there are an equal number of paid professionals in a gray market for lobbying services. We also find that registered lobbyists are more likely to have previously worked in government and are more likely to specialize in legislative advocacy. Since policymaking at the American national level has increasingly shifted to federal agencies and to the states, our results indicate that the LDA and similar lobbying regulations may be becoming increasingly obsolete. The evidence we present indicates a growing divide between transparency laws and recent changes in the marketplace for policy advocacy.

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  1. 1.

    See Accessed May 2017.

  2. 2.

    The purpose of this research is not to identify individual instances of non-compliance, but rather to evaluate the scope of lobbying disclosure avoidance based on an empirically identifiable population.

  3. 3.

    Calculated by authors from data reported at Accessed May 2016. Actual data may have been slightly revised after we calculated these results.

  4. 4.

    In September, 2012, the authors met with the publisher of the directory information, Columbia Books, and learned that there are three main avenues in which individuals are entered into the database. First, organizations such as lobbying firms, associations and companies voluntarily provide information (including information about their staff) for inclusion in the directory either as an advertising mechanism or upon request from the publisher. Such requests are routinely sent by the publisher to update existing entries or to new organizations that have purchased access. Second, the publisher retrieves information from public disclosure documents required by the Lobbying Disclosure Act of 1995. And, third, the publisher actively searches for those working in political advocacy in Washington. While Schlozman et al. (2012) identify some error as a function of the type of activity an organization engages in as well as temporal variation, they note that the publisher views the database as a “snapshot” of those engaged in Washington politics.

  5. 5.

    We do not distinguish between those who took the formal steps with the Secretary of the Senate to “deregister” and those who “deactivated” by simply ceasing to file quarterly lobbying disclosure reports.

  6. 6.

    The means of calculating LDA expenditures are subject to controversy as well. Clients choose one of three ways to account for expenditures, so they may under- or overestimate spending. We consider this problem to be a matter of measurement error that is distributed randomly across individual lobbyists, since this accounting decision is made by the organization-registrant that lists them in disclosure reports.

  7. 7.

    There was too little variation in the current sample in these specialization categories, so we collapsed them into a single, catch-all category.


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Correspondence to Herschel F. Thomas.

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Thomas, H.F., LaPira, T.M. How many lobbyists are in Washington? Shadow lobbying and the gray market for policy advocacy. Int Groups Adv 6, 199–214 (2017).

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  • Lobbying Disclosure Act
  • Lobbying
  • Policy advocacy
  • Shadow lobbyists
  • Revolving door
  • Political reform