The Register of Members’ Financial Interests (RMFI) has existed in its current form since 1975. It requires MPs to declare financial interests that a “reasonable, independent-minded person” would consider relevant to their parliamentary duties. The test is deliberately broad, but its application depends on self-declaration and self-assessment, creating conditions in which interests can go undisclosed without technically violating the rules.
What the Register Captures
The RMFI requires declaration across nine categories: employment and earnings; donations; gifts; hospitality; overseas visits; overseas benefits; land and property; shareholdings; and family members employed. The most commercially significant categories — employment and shareholdings — require disclosure when they exceed specific thresholds: employment paying more than £300 for fewer than 28 hours’ work, or a shareholding representing more than 15% of a company’s issued share capital.
These thresholds, set in 2012, create gaps that are exploited by structure rather than concealment. A directorship paying below the threshold need not be disclosed. A shareholding below 15% — including holdings of 10-14% that represent significant wealth or corporate influence — need not be declared. Interests held through a spouse or civil partner are not captured unless the MP is a beneficiary of a trust holding them.
The Companies House Gap
Cross-referencing the Register with Companies House director and shareholder filings reveals a consistent pattern. Of MPs who hold directorships at companies disclosed on Companies House, a proportion hold directorships that meet the disclosure threshold but are not registered in the RMFI. Of those, some represent genuine inadvertent omissions later corrected; others are disclosed with significant delay.
The Parliamentary Commissioner for Standards (PCS) investigated 43 cases relating to Register failures between 2020 and 2025. Thirty-one resulted in findings of breach, almost all characterised as inadvertent failures to register or late registration. Seven resulted in formal sanctions ranging from written apology to suspension from the House.
The challenge of cross-referencing Companies House against the RMFI is not computationally difficult — it is not being done systematically by any public body, despite the data being publicly available. The PCS office does not have resources to proactively audit the Register against external data sources; it investigates complaints made to it.
Informal Influence
Beyond the Register’s formal scope, there is a category of influence that is neither declared nor declarable: the informal networks, relationships, and social obligations that create commercial access to parliamentarians. These do not require declaration because they have no monetary value attached to them.
Research by the Good Law Project and by academic researchers at the University of Sussex has documented patterns of access — attendance at events, correspondence, shared membership of clubs and professional bodies — that correlate with subsequent government decisions, without any of the underlying relationship being captured in the Register. The issue here is not illegality; it is the gap between what the Register requires and what “a reasonable, independent-minded person” might consider relevant.
Reform Proposals
The Committee on Standards in Public Life reviewed the RMFI system in its 2021 report on upholding standards in public life, recommending lower declaration thresholds, real-time rather than periodic updating, and proactive verification against Companies House. The government accepted some recommendations and rejected others. The threshold changes were not implemented.
Following a period of high-profile RMFI controversies, the House of Commons Standards Committee published its own review in 2023. It recommended reducing the employment payment threshold from £300 to £100 per hour and eliminating the 28-hour rule entirely. The recommendations were put to a vote; they passed but were not subsequently implemented by the government in secondary legislation.