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Compliance
Do Volunteers Have to Register as Lobbyists? It Depends
November 5, 2024 | Nicole Galloway, Denisse Girón, Karen Kulivan
Key Takeaways:
- With 2023 coming to an end, lobbyist registrations in 30 states, 49 localities, Puerto Rico, and Canada’s Federal jurisdiction are expiring. Re-registrations for 2024 will mostly take place in December and January.
- However, several states operating on a biennial registration schedule will not require re-registration this year. In these states, your registration will automatically continue into 2024. Be sure to terminate if you are no longer active in one of these states or disclosure reports may be required.
- Note that some states have everlasting registrations. While many states and localities require lobbyists to renew their registrations every year, a handful of jurisdictions do not require you to renew your status.
- Periodic disclosures are due in 18 states and 8 municipalities (plus Canada).
- On the campaign finance front, 19 states have campaign finance disclosure deadlines plus the District of Columbia and Federal Election Commission (FEC).
- Finally, a new legislative session means new lobbying thresholds, such as those adopted by the Texas Ethics Commission.
Lobbying Compliance
Expiring Registrations
With 2023 coming to an end, lobbyist registrations in 30 states, 49 localities, Puerto Rico, and Canada’s Federal jurisdiction are expiring. Registration renewals for 2024 will mostly take place in December and January, so you should pay very close attention to your jurisdictions to avoid missing a critical renewal deadline. The map below shows which states have expiring registrations.
You should also monitor localities and territories with upcoming expirations. The table below shows the specific jurisdictions where annual registrations will expire.
Localities and Territories with Expiring Registrations
Biennial Registrations
Several states operating on a biennial registration schedule will not require renewal this year. In these states, your registration will automatically continue into 2024. If you are no longer active in one of these states, you will need to terminate your registration; otherwise, you will be required to submit disclosure reports in 2024. See the table below for a list of states with biennial registrations.
It is important to note that while a state may be on a biennial registration schedule, localities within the state may require annual registrations. New York State is a prime example of this — New York City requires registrations every year, whereas New York State operates on a biennial schedule.
Everlasting Registrations
While many states and localities require lobbyists to renew their registrations every year, some jurisdictions do not require you to renew your status. These rare scenarios occur in Delaware, Michigan, and Minnesota. These registrations exist in perpetuity, meaning that you will remain a registered lobbyist in these states unless you officially terminate. If you are no longer lobbying in one of these states you will need to manually terminate your registration to avoid filing disclosure reports in 2024. And do so quickly — the first disclosure reports are due January 15! Fortunately, you can re-register in any of these states at any point throughout the year.
Lobbying Compliance Deadlines in December
On top of registrations expiring at the end of the year, 18 states and 8 municipalities still require periodic disclosures this month. Additionally, the Canadian Monthly Federal is due as usual. States like Florida, Georgia, Louisiana, and Washington may require multiple disclosures this reporting period depending on which state level you are registered in. Check out the map and table below for details on important compliance deadlines.
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Localities with Compliance Deadlines
States are not the only places that have lobbying regulations. Lobbying in a locality can trigger registration and reporting requirements as well. In states like New York, lobbying in a locality such as Nassau County can also require a state registration.
Campaign Finance Deadlines
In December, 19 states have campaign finance disclosure deadlines plus the District of Columbia and the Federal Election Commission (FEC). If a political committee is registered in one of these states and is required to file disclosure reports, they must do so in December. Check out the map below for the states with important deadlines this month.
Political committees should be aware of their filing schedules. Some jurisdictions (Texas, for example) give the option to report monthly or quarterly. Also, be aware that some states require a political committee to report large contributions within a set time frame of receipt. Political committees should be reviewing contributions carefully to ensure they do not miss a required contribution- or expenditure-triggered deadline.
New Year, New Thresholds
The new legislative session not only brings new bills and resolutions to watch for but also new lobbying thresholds. The Texas Ethics Commission has adopted proposed changes to several sections of the Texas Administrative Code, raising various reporting thresholds for lobbying and campaign finance reports effective January 1, 2024. Note the increase to the expenditure threshold for lobbyists at which registration is required from $880 to $940, and increase to the expenditure threshold below or at which lobbyists may file annual reports from $2,020 to $2,150, as your registration or disclosure frequency may be different going into 2024 than in 2023. Read the regulatory text here.
Get Help with Lobbying and PAC Compliance
The 2024 Legislative session is quickly approaching! Don’t miss a critical deadline — learn more about our industry-leading lobbying compliance services. We can also help if you’re running a political committee and unsure of your compliance requirements. Don’t hesitate to reach out to our team with questions.
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