From Lobbying to Legitimacy: Tomorrow’s influence is earned, not arranged.

By Stefan Borst, Senior Partner Advocacy Strategy

C‑suite leaders are operating in a post‑lobbying age. The old model - episodic meetings, discreet intermediaries and back‑channel deal‑making - has not simply frayed; it has been officially re-priced. In 2024 the OECD broadened the global bar for conduct by revising its “Recommendation on Transparency and Integrity in Lobbying and Influence”. It explicitly widens “lobbying” to include the full spectrum of influence - from direct lawmaker outreach to the positions taken by trade associations, think‑tank funding, digital campaigns, and even AI‑enabled engagement. A growing number of jurisdictions are experimenting with “regulatory footprints” that document who sought to shape a policy, when, and with what arguments. If you influence, you are within scope - and that means expecting public scrutiny.

The market for influence now measurably rewards organizations that demonstrate transparency, include stakeholders before positions are set, and align advocacy with clearly articulated societal goals. It penalizes those that treat policy engagement as a transactional activity detached from strategy, values, or evidence.

The consequence is profound: Public Affairs (PA) can no longer be a peripheral access function. It must operate as a legitimacy‑building capability at the core of enterprise leadership (and should be set up like this).

Disclosure is becoming hard‑wired.

In Europe, sustainability reporting standards now require companies to explain the nature and governance of their political engagement, and the region’s new due‑diligence regime adds legal force to responsible conduct across value chains. In the United States, climate‑related disclosure remains contested yet directional: regulators, investors, and courts are litigating the boundaries, but the expectation that public claims and public‑policy activity must line up grows stronger each year. Global frameworks such as the GRI standard on public policy continue to set a baseline for what credible transparency looks like.

Trust sets the ceiling for your voice.

Survey data like the Edelman Trust Barometer across markets show a stubborn mistrust of institutions and leaders - yet “my employer” remains comparatively trusted. That places a premium on companies that make their reasoning visible, show how they incorporate diverse expertise, and disclose the trade‑offs behind their positions. Conversely, any discrepancy between what a company says in reports and what it advocates in legislative corridors erodes license to operate and blunts it’s persuasive power.

Investors are no longer bystanders.

Shareholder proposals on political spending and lobbying disclosure are now routine during proxy season. Indexes and independent assessments track whether corporate advocacy aligns with climate commitments, human‑rights policies and other stated goals. Capital is therefore quietly disciplining the worst misalignments, especially where trade associations lobby in ways that contradict the enterprise’s strategy.

Alignment is becoming measurable.

Independent platforms now score companies not only on what they promise but on whether their direct and indirect policy engagement plausibly supports those promises. That measurability is the accountability frontier: it enables boards, investors, employees, and communities to test whether influence is being used responsibly - and to ask for corrective action when it is not. This also means that getting away with misconduct has become more unlikely and thus a lot more risky.

From access to legitimacy: the mandate for modern PA

Treating PA as a legitimacy function starts with governance. Board‑level oversight is essential, not as a ceremonial checkpoint but as a mechanism to tie advocacy explicitly to long‑term strategy, risk, and opportunity. The most effective boards approve a non‑partisan policy for corporate political responsibility, setting guardrails for what the company will do (and will not do) across all channels - from direct lobbying to third‑party intermediaries, election‑adjacent activity, and social or digital campaigns.

The litmus test is simple: would a reasonable stakeholder, reading the policy and the disclosures it generates, conclude that the company’s pursuit of influence is principled, proportional, and aligned with its stated purpose? Plus: are the words and actions of the company in sync?

Alignment then needs to be designed in, not inspected after the fact. Leading PA teams maintain a “North Star” issues map that clarifies which policy outcomes are material to the business and the public interest, what evidence underpins the company’s position, and where stakeholder perspectives have shaped the final ask. Because misalignment often hides in plain sight, trade associations require special attention. An annual association audit - mapping the association’s advocacy against the company’s strategy and commitments - enables constructive engagement, documented remediation, or, if necessary, a principled exit. When handled transparently, these reviews build credibility with policymakers and investors who have learned to look for discrepancies between corporate branding and association behavior.

Transparency, in turn, should be comprehensive rather than performative. A concise public “Policy Engagement Report” that explains the company’s positions, the rationale behind them, the bodies engaged, the use of third parties, and the associated spend is now the price of admission in many sectors. Where feasible, companies should adopt elements of a regulatory footprint: who was consulted, what evidence was considered, and how competing viewpoints were weighed. For climate‑material businesses, an explicit statement of how policy advocacy supports transition plans helps reconcile investor expectations, regulatory scrutiny, and internal accountability. The more pro-active this is handled the less backlash-potential is allowed to build up.

Inclusion is the discipline that keeps transparency from being mere optics. The most sophisticated operators bring workers, customers, community representatives, and independent experts into the process before a position hardens. This is not a quest for unanimity; it is a method for surfacing blind spots, refining arguments, and demonstrating that the company takes into account the people affected by its preferred outcome. Structured inclusion makes leaders better - and makes their influence more legitimate.

Finally, narrative coherence is the everyday work of legitimacy. What the company says in sustainability reports, CEO speeches, and advertising must match what it asks of policymakers and what its associations lobby for. When misalignment emerges - say, an industry body campaigning against a policy that would enable the company’s net‑zero commitment - that is not a public‑relations nuisance; it is a strategic risk that demands swift, visible resolution. Data and discipline make coherence sustainable: centralize records of engagements and positions, require pre‑clearance for high‑risk activity, and prohibit channels that cannot meet your guardrails.

Measuring what matters: a concise legitimacy scorecard

Executives should insist on a small set of metrics that can be reported to the board and - at an appropriate level of detail - externally.

• An Alignment Index tracks the share of priority topics where direct and indirect advocacy demonstrably matches enterprise strategy and commitments, along with the number of association gaps remediated or exited.

• A Transparency Index measures coverage and quality of disclosures, including the depth of the company’s regulatory footprint.

• Evidence Quality records the proportion of submissions grounded in independent analysis and summarizes when new evidence changed a stance.

• Trust Outcomes monitor movement in employer‑trust and stakeholder sentiment regarding the firm’s legitimacy to engage in public policy. Finally,

• Corrective‑Action Velocity measures the median time from identifying a misalignment (internally or via an investor/NGO alert) to a public remedy; paired with Compliance & Culture indicators (incidents, training completion in high‑risk functions), these metrics keep the system honest.

A pragmatic 90‑day plan for CEOs, GCs, and CAOs

All of this may sound like a huge challenge to implement. But as a matter of fact, this can be done within a relatively short time frame and at reasonable cost. Here is the outline of a 3-month implementation plan:

1. Map the gap. Inventory all current policy engagements - direct and via associations - alongside spend, stated asks, and evidence. Flag high‑exposure contradictions.

2. Set the guardrails. Approve a non‑partisan corporate political responsibility policy that covers scope, oversight, association governance, sanctioned channels, and red lines (including election‑adjacent activity).

3. Triage trade bodies. For your top associations, document alignment with strategy and climate or safety commitments; agree on remedies with timelines, or set an exit plan (also for associations that do not deliver added value).

4. Publish your stance. Launch a concise web page that houses your positions, annual report, association list and status, and a contact path for stakeholders.

5. Institutionalize the footprint. Pilot short, public “who we consulted / what we asked for / why it matters” notes for the next three significant submissions; align legal, PA, sustainability, and IR (potentially also Corporate Strategy) on process and tone.

6. Measure and iterate. Stand up the legitimacy scorecard and integrate it into quarterly enterprise‑risk and audit committee reviews.

Guardrails for a polarized era

The most reliable compass is principle‑led engagement anchored in long‑term value creation, not partisan identity. Apply your standards to every channel, including emerging ones; if a tactic cannot meet your transparency and accountability thresholds, it is not an acceptable shortcut. Balance “no politics at work” with civic responsibility by focusing on issues where the company has real standing and expertise. And expect scrutiny to keep rising: as disclosure expands and data improves, stakeholders will continue to test whether your behavior, your narrative and your advocacy truly cohere.

The bottom line

Influence today is a compound asset. It accrues to organizations that align what they lobby for with how they operate and what society reasonably expects; it decays quickly when access is pursued without accountability. Reframing public affairs as a legitimacy function - governed with teeth, designed for alignment, practiced with transparency and inclusion, and measured with discipline - does more than keep you on the right side of evolving rules. It earns you the benefit of the doubt from regulators, the patience of investors, and the permission of stakeholders to shape the policy choices that define your future.