David Cameron would have had to register as a lobbyist for failed firm Greensill Capital if newly recommended transparency rules had been in place at the time of the controversy, a review said.

The former prime minister escaped punishment – despite privately lobbying ministers in efforts to secure access to an emergency coronavirus loan scheme for Greensill before its collapse – because he was classified as a company employee.

But, in the second part of a long-awaited review into the Greensill affair commissioned by Boris Johnson, it has been recommended that any former minister or civil servant should have to formally declare themselves a lobbyist in future.

Lawyer Nigel Boardman, who spearheaded the review after the Prime Minister appointed him in April, noted that if his proposals had been in force at the time, the former Conservative Party leader would have been subject to lobby rules.

Mr Cameron began his role as an adviser to Greensill in August 2018, just over two years after he resigned as prime minister in July 2016.

Correspondence published by the Commons Treasury Committee showed he bombarded ministers – including Chancellor Rishi Sunak and then Cabinet Office minister Michael Gove – and Government officials with text messages over support for Greensill, which later collapsed into administration.

However, the Registrar of Consultant Lobbyists cleared Mr Cameron of breaking lobbying rules because, as an employee of Greensill, he was not required to declare himself on the register.

Under the recommendations made by Mr Boardman, those stipulations would change, meaning someone in Mr Cameron’s position would be required to declare his efforts.

Chancellor Rishi Sunak was among the ministers David Cameron lobbied
Chancellor Rishi Sunak was among the ministers David Cameron lobbied (Toby Melville/PA)

“I note that, were these recommendations in force at the relevant time, Mr Cameron would have been required to register as a lobbyist,” Mr Boardman said in the final instalment of his review published on Thursday.

In the light of the heavy lobbying witnessed via electronic communication during the Greensill scandal, Mr Boardman also recommended that the definition of what constitutes “a meeting” should be extended beyond in-person situations.

In his 30-page report, he said it should include “all forms of non-public interactive dialogue which, were it face-to-face, would constitute a meeting”, meaning it should be declared in lobbying transparency returns.

Mr Boardman, in another of his 19 recommendations, said lobbying rules could be “strengthened” if it was declared who was funding those seeking to influence ministers and others in Government.

Lobbyists should also meet a statutory code of conduct setting minimum standards, he advised.

Prime Minister Boris Johnson commissioned Nigel Boardman to lead a review into the Greensill affair and the state of lobbying rules
Prime Minister Boris Johnson commissioned Nigel Boardman to lead a review into the Greensill affair and the state of lobbying rules (Hannah McKay/PA)

The Civil Service has been urged to brush up its own awareness of potential conflicts of interest as part of the proposed reforms.

It comes after it was disclosed that Bill Crothers, a former government chief commercial officer, became an adviser to Greensill Capital while still working as a civil servant.

Mr Boardman added that the Government should introduce pre-appointment rules which “prevent for a period of time civil servants dealing with or promoting their former employer after joining the Civil Service”.

A Cabinet Office spokesman said: “As the report recognises, the Government has committed to continually reinforcing high standards of conduct in public life so the public can have trust and confidence in the operation of government at all levels.

“We will carefully consider Mr Boardman’s recommendations, along with the ongoing work of the Committee on Standards in Public Life, and we will respond in due course.”

Deputy Labour leader Angela Rayner said the fact Mr Cameron’s “cross-government WhatsApp campaign” did not break the rules showed that they were “completely unfit for purpose”.

“The current broken system of pointless committees causes more harm than good by giving a veil of legitimacy to the rampant cronyism, sleaze and dodgy lobbying that is polluting our democracy under Boris Johnson and the Conservatives,” she said.

Labour would ban former prime ministers and ministers from taking on lobbying jobs for at least five years and appoint an “integrity and ethics commission”, she added.