
Compliance
Lobbying Compliance and Campaign Finance Deadlines in April 2025
April 2, 2025 | Chase Klingensmith, Dylan Busler
April 3, 2025 | Ben Seitelman
Key Takeaways:
On March 1 of every year, the New York City Lobbying Bureau publishes an annual report summarizing the past year’s lobbying activities. The extensive report gives an overview of all lobbying activity of the previous year, including the top industries involved in lobbying matters, lobbyists with the most compensation received, and the companies and organizations spending the most on paid lobbyists.
For example, most who registered to lobby in 2024 were in the real estate industry (31%), followed by the public interest/non-profit sector (21%). Lobbying targets varied, but the most common target was the City Council. 24% of lobbyists reported lobbying the fifty-one members of the New York City Council at some point in 2024. 21% of lobbyists additionally reported meeting with council staff members, and 7% met with the office of the mayor. 31% of lobbying activities in 2024 related to the city’s budget, followed by local legislation (19%), determinations of boards or commissions (14%), and determinations regarding real property (13%).
For our compliance team, this annual report is a good insight into how the lobbying bureau administers lobbying regulations, especially civil penalties issued for filing of late registration and activity reports. Here are some compliance highlights from the latest report covering 2024.
Lobbyists who are registered in New York City must also register with the State to report their activity. The NYC Lobbying Bureau works with the New York State Commission on Ethics and Lobbying in Government (COELG) to compare lobbying statements in their respective jurisdictions each year. They found that 107 entities reported to the State that they had lobbying activities in New York City, but failed to register separately with the City for 2024.
Comparing registrations with the state of New York is one way NYC ensures compliance in their jurisdiction. If caught with inaccurate registrations, the NYC Lobbying Bureau may require your company to backdate any missing registrations and reports, which can result in sizable late fees for each filing.
The report highlights civil penalties issued for filing of late registration reports and activity reports. Registrations are due annually every January 15th or within 10 days that a lobbyist or client anticipates exceeding the $5,000 compensation or expenditure threshold. Lobbyists are required to file reports every two months detailing their activity; additionally, an annual report is required for clients who retain contract lobbyists detailing the activity those lobbyists performed over the course of the past calendar year. Fundraising and consulting reports are also required to be filed by clients every two months if contributions were solicited for any candidate running for elected office in New York City, or for any city official running for state or federal office.
Overall, the NYC Lobbying Bureau identified 39 late lobbying reports for the last two months of 2023 and 321 late annual client reports, incurring a total of over $150,000 in aggregate filing penalties. For 2024, they identified 233 late filings of registrations and reports, totalling over $125,000 in aggregate filing penalties.
The Lobbying Bureau selects lobbyists at random annually for an audit of the previous year’s reports. In 2024, 45 lobbyists were randomly selected for audits. These audits resulted in 63 findings and all required corrective actions, ranging from incorrect reporting of lobbyist employee addresses to a complete failure to report all lobbying activity on certain reports. Audits in New York City can sometimes be a lengthy process since these audits involve a meeting with the Bureau and representatives from the selected lobbyist or client to discuss the Bureau’s findings, and what actions, if any, are needed to correct incorrect or inaccurate information on their filings.
Keeping up with rules, deadlines, and often confusing requirements is a daunting prospect for teams of all sizes. Let us manage your federal, state, and local registration and reporting responsibilities, or manage your Campaign Finance program. Read more about our Compliance Services here, or get in touch here.
April 2, 2025 | Chase Klingensmith, Dylan Busler
March 4, 2025 | Chase Klingensmith, Dylan Busler
February 3, 2025 | Lauren Calhoun, Dylan Busler