Arkansas Implements Hostile Foreign Influence Disclosure Law

The Arkansas Secretary of State promulgated the Combating Hostile Foreign Influence Rule to implement a 2025 state law requiring registration and disclosure by representatives of hostile foreign principals and foreign-supported political organizations. The rules expand the information that must be disclosed for foreign-supported political organizations; create a method for submitting complaints; and provide details of investigation, hearing, and enforcement procedures. The rules took effect January 18, 2026.

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The City of Austin, Texas increased campaign contribution limits for candidates for mayor and city council from $450 to $500 per contributor per election. The aggregate contribution limit to candidates from donors outside of Austin increased to $48,000 per election, and $32,000 per runoff election.

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The Arizona Legislature passed a bill adjusting the primary election date and making other election law changes. House Bill 2022 (Senate Bill 1425), permanently changes the primary election date from the first Tuesday in August to the second-to-last Tuesday in July during even numbered years; makes technical changes for the July 21, 2026 primary election; adjusts ballot signature curing deadlines for federal elections; and expands the locations where authorized party representatives may observe and challenge voting activity. The measure was passed as an emergency and will take effect immediately, if signed by Gov. Katie Hobbs.

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The Arkansas Ethics Commission has reported a website outage, due to an attack by malicious actors. Estimated full restoration time is unknown. It is recommended to reach out to the commission at (501) 324-9600 or (800) 422-7773, or email jill.barham@arkansas.gov for any specific website need. The website is ordinarily a resource for ethics rules, opinions, complaints, and guidance for campaign finance reporting entities. Website visitors are cautioned to confirm the outage is restored before attempting to navigate to the site.

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The Utah Legislature passed a bill concerning state court expansion. Senate Bill 134 increases the number of Utah Supreme Court justices from five to seven; increases the number of court of appeals judges from seven to nine; and adds three additional district court judges. The bill was signed by Gov. Spencer Cox on January 31. Senate Bill 134 is effective immediately but remains at risk of amendment if required funding during the legislative session is not approved.

At its meeting on December 19, the Oklahoma Ethics Commission agreed to reinstate and reactivate the deactivated Guardian lobbyist and campaign finance online disclosure system. The commission also agreed to terminate its contract with RFD & Associates, Inc., the contractor responsible for the Guardian 2.0 filing system, and to authorize the Office of Attorney General to pursue remedies for potential legal claims. Lobbyist renewal registrations and campaign finance reporting have been inactive or unable to be submitted online since the launch of Guardian 2.0 in beta earlier this fall. Contacting commission staff is recommended during this transition to ensure registration and reporting compliance at ethics@ethics.ok.gov.

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The Texas Ethics Commission amended, readopted, and repealed certain campaign finance rules regarding contributions and expenditures generally, and as applicable to corporations and labor organizations. These actions are part of a comprehensive review of the Texas Ethics Commission Rules to shorten, simplify, and clarify. The changes include a repeal of the rule amplifying the independent expenditure reporting requirements of a person not acting in concert with another person. The rules also clarify the prohibition on cash contributions over $100 refers to paper currency and coinage. The changes take effect December 31.

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The Colorado Supreme Court heard oral arguments in Unite for Colorado v. Colorado Department of State on the question of what constitutes a major purpose of ballot issue advocacy for purposes of requiring an organization to register and report as an issue committee. At issue was whether the statutory and constitutional legal framework permits regulators to look only at activity related to a single ballot issue or if they may consider an organization’s aggregated activities on multiple ballot issues in determining whether ballot issue advocacy is a major purpose of the organization. The General Assembly amended state statutes in 2022 to provide single and aggregate ballot issue percentage-of-total-spending major purpose thresholds but Unite contends its arguments may nevertheless have implications for the amended law.

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The Utah Legislature concluded its work in the Second Special Session of the 66th Legislature on December 9. Lawmakers repealed House Bill 267, an anti-union law passed earlier this year, to avoid an upcoming referendum vote; passed a bill adjusting qualifying provisions for prospective candidates for the office of U.S. representative in 2026, in consideration of an anticipated appeal of a court decision on congressional district maps; and passed a bill allowing such an appeal directly to the Utah Supreme Court. Other measures passed made election and political district boundary disputes more immediately appealable; and rebuked the judiciary for what the legislative majority believes was encroachment on its constitutional powers.

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Gov. J. Kevin Stitt ordered a special election to fill the vacancy in House District 92 after Rep. Forrest Bennett resigned to become President of the Oklahoma AFL-CIO. A special primary election will be held on June 16, 2026 and a special runoff election is scheduled for August 25, 2026, if necessary. The special general election is scheduled for November 3, 2026, but will be moved up if the primary or runoff election is not needed. The full term for House District 92 is also up for election on the regular 2026 election calendar, and candidates may run on both ballots.

The Utah Legislature anticipates convening in special session on December 9 for the purpose of election system clarity, according to a joint press release issued by the House and Senate. The announcement follows a trial court decision in an ongoing lawsuit on congressional district maps.

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The Oklahoma Ethics Commission approved advancing two rulemaking amendments proposed at the November 13 meeting. Requested revisions to Rule 5.16 would allow a lobbyist principal to provide meals to either chamber of the Legislature during session, rather than only to a committee or subcommittee. Amendments to Rules 5.2 and 5.6, and a repeal of Rule 5.8, would potentially loosen gift restrictions to allow for expenditures on traditional business expenses, such as meals and events, while doing away with the requirement that gifts from lobbyists come only at infrequently occurring occasions of personal significance to the recipient. The commission will also consider issuing a guidance letter on Rule 5.14 to clarify only the actual cost of the food and beverage at an event to which all members of the Legislature are invited needs to be reported. The Ethics Commission will consider the drafted revisions, and public comment, at a hearing on December 19.

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Gov. Sarah Huckabee Sanders ordered new dates for the special elections for House District 70 and Senate District 26.  The special primary elections will be held on January 6, 2026, and special runoff elections are scheduled for February 3, 2026, if necessary. The special general elections are set for March 3, 2026. Two trial court judges in separate lawsuits ordered the original dates moved forward and the Arkansas Supreme Court denied the governor’s requests to stay the orders. The new dates were set “with objection” while the cases remain open on appeal. 

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On October 28, the Oklahoma Ethics Commission launched the beta phase of Guardian 2.0, the new online lobbyist and campaign finance disclosure system. During the beta phase, filers may access the system and enter contributions and expenditures as they prepare their required reports.  For the initial phased release, official report submission is temporarily disabled to ensure the accuracy of campaign finance data before it becomes public. Users will have the opportunity to provide direct feedback on the new platform via a dedicated email address, GuardianSupport@ethics.ok.gov. The Oklahoma Ethics Commission will not penalize users for issues tied to system limitations or problems. The deadline for PAC third-quarter reports which became due on October 31 is considered extended a minimum of 30 days or longer, if necessary. Affected entities are being given priority access and support through Oklahoma Ethics Commission.

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