Compliance
Do Volunteers Have to Register as Lobbyists? It Depends
November 5, 2024 | Nicole Galloway, Denisse Girón, Karen Kulivan
January 8, 2024 | Chase Klingensmith, Bradley Coffey
Key Takeaways:
January is another busy month in the lobbying compliance world. From reports to registrations, here’s what’s due this month and where. Forty-five states, plus the District of Columbia, Puerto Rico, and 41 localities have periodic reports due this month. In addition to the state and local jurisdictions with filing deadlines this month, there are also periodic reports due to the U.S. Federal government, Canadian Federal government, and Alberta, Canada. If you were registered in any of these jurisdictions in 2023 you will likely owe a report this month. The map below shows the states with periodic reports due this month.
The following localities also have periodic reports due in January.
Localities with Periodic Reports Due
State | Localities |
Arizona | City of Phoenix |
California | City and County of San Francisco City of Berkeley City of Los Angeles City of San Diego City of San Jose Los Angeles County Los Angeles County (Metropolitan Transit Authority) Los Angeles Unified School District San Diego County |
Colorado | City and County of Denver |
Florida | Broward County City of Fort Lauderdale City of Miami City of Naples City of Orlando City of Tampa Collier County |
Hawaii | City and County of Honolulu County of Maui |
Illinois | City of Chicago |
Indiana | City of Indianapolis |
Maryland | City of Baltimore County of Montgomery |
Massachusetts | City of Boston |
New Jersey | Jersey City |
New York | City of New York Nassau County Suffolk County |
Ohio | City of Cincinnati City of Columbus |
Oregon | City of Portland |
Pennsylvania | City of Philadelphia City of Pittsburgh |
Rhode Island | Providence |
Texas | City of Austin City of Dallas City of Houston |
Washington | City of Seattle King County |
Wisconsin | Milwaukee County |
District of Columbia | |
Puerto Rico |
At the end of 2023 lobbyist registrations in 30 states, 49 localities, Puerto Rico, and Canada’s Federal jurisdiction expired. Registration renewals for 2024 are currently underway, so you should pay very close attention to your jurisdictions to avoid missing a critical renewal deadline. The map below shows which states had expiring registrations in December 2023.
The following localities’ registrations have also expired and will need to be renewed if lobbying activity is planned to continue in 2024.
Localities with Expired Registrations
State | Locality |
Arizona | City of Phoenix |
California | City and County of San Francisco |
City of Berkley | |
City of Los Angeles | |
City of San Diego | |
City of San Jose | |
Los Angeles County | |
Los Angeles County (Metropolitan Transit Authority) | |
Los Angeles Unified School District | |
San Diego County | |
Colorado | City and County of Denver |
Florida | City of Coral Gables |
City of Doral | |
City of Hialeah | |
City of Jacksonville | |
City of Miami | |
City of Naples | |
City of Orlando | |
City of South Miami | |
City of Tampa | |
Collier County | |
Miami-Dade County | |
Orange County | |
Tampa International Airport | |
Greater Orlando Aviation Authority | |
Hawaii | City and County of Honolulu |
Illinois | City of Chicago |
Indiana | City of Indianapolis |
Maryland | City of Baltimore |
County of Montgomery | |
Massachusetts | City of Boston |
New Jersey | Jersey City |
New York | City of New York |
Nassau County | |
Suffolk County | |
Ohio | City of Cincinnati |
City of Columbus | |
Cuyahoga County | |
Oregon | City of Portland |
Pennsylvania | City of Philadelphia |
City of Pittsburgh | |
Rhode Island | Providence |
Texas | City of Austin |
City of Dallas | |
City of Houston | |
Washington | City of Seattle |
King County | |
Wisconsin | Milwaukee County |
District of Columbia | |
Puerto Rico |
In January, 42 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 January. 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.
The new legislative session not only brings new bills and resolutions to watch for but also new blackout periods for campaign contributions during the legislative session. In 2024, 25 states with legislative sessions maintain some form of blackout for contributions from PACs, lobbyists, lobbyist principals, individuals, corporations, etc. during the legislative session. If you are planning to give in Alabama, Alaska, Arizona, Arkansas, Colorado, Connecticut, Florida, Georgia, Hawaii, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Minnesota, New Mexico, North Carolina, Oklahoma, Tennessee, Utah, Vermont, Virginia, Washington, or Wisconsin, check to ensure that the blackout period has ended prior to giving a contribution.
Note that Minnesota’s PAC and lobbyist contribution ban was expanded in 2023 to include prohibitions on lobbyists, PACs, and political funds from purchasing event tickets or access to a facility run by a candidate for election if that event takes place during the legislative session.
Don’t miss a critical deadline as we enter the 2024 state legislative session season — 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.
November 5, 2024 | Nicole Galloway, Denisse Girón, Karen Kulivan
November 5, 2024 | Hilary Smith
October 29, 2024 | Chase Klingensmith, Bradley Coffey