Q: We’re approaching the end of the year. What do I need to consider for 2025?

A: At the end of the year you will, of course, be planning which states will be your priority for the following year. A number of states having two-year registration cycles renew in odd-numbered years, so be aware you may have more registrations to file than you did last year. Additionally, Nevada’s legislature, which does not hold legislative sessions in even years, will be back in session in 2025 and will require registration if you will be lobbying there.

Registrations generally expire at the end of the year, and many states will allow registration renewals to be filed in December or January. There are a few states whose annual renewal lands earlier than expected, such as Indiana, Maine, Maryland, Massachusetts, and New Jersey, some of which have unexpected penalties for failure to renew on time.

Are you choosing not to renew in some states? Then you will need to determine how that process works. In some states your registration will naturally expire at the end of the year. Others have ongoing registrations which require you to notify the state you no longer intend to lobby. Watch out for the states, such as New Jersey, which require you to file a renewal every year, but still ask for a notice of termination when your representation ends. Regardless of the state, you will need to file a final report, either as part of the termination process or as part of the normal reporting schedule, covering the period between your last report and the date your registration terminated.

One final note: many states will allow you to file a new registration for 2025 beginning in 2024. If you accidentally file your registration early, the state will count it as a 2024 registration, which will then obligate you to file a report covering the end of 2024. Sometimes you do intend to file a 2024 registration at the end of the year, but the state will assume it is a 2025 registration. Regardless of your intentions, make sure the state has correctly filed your registration.

Further information about the lobbying laws in hundreds of cities, counties, and local agencies can be found in the Lobbying Compliance Laws section of the State and Federal Communications website.

Q: I need to lobby on the municipal level, but I’m registered with the state. Am I covered?

A: It will depend on the state, but you might not be covered. Some states, including Georgia, Illinois, Missouri, and New York, to name just a few, have lobbying laws covering both state and local governments. If you are registered in such a state, however, that does not necessarily end the analysis.

Even in states where state lobbying laws apply locally, you may still have local obligations. New York state law requires registration if you lobby locally and otherwise meet the registration requirements, but New York City has its own registration regime you will be required to follow, potentially requiring registration at both the state and local level. Illinois lobbying law covers local governments as well, but includes a carve out for lobbying in Chicago. Lobbying in Chicago requires registration with the city, but not with the state.

Whether you are or are not in a state where the lobbying laws apply locally, you will need to verify whether the city or county you are contacting has its own lobbying law. Even if it does not, be aware there may be other requirements, such as visitor logs, with which you will still need to comply.

Finally, be aware some local agencies, particularly those covering large metro areas, have their own lobbying laws as well, so registration with the city or county still may not cover your contacts with those agencies. For instance, Broward County Public Schools and the Los Angeles Metropolitan Transportation Authority (LAMTA) have adopted lobbying provisions separate from those of the counties in which they are located.

It is safest to always assume your government outreach, regardless of the level of your interaction, is covered by a lobbying law until you confirm otherwise.

Further information about the lobbying laws in hundreds of cities, counties, and local agencies can be found in the Lobbying Compliance Laws section of the State and Federal Communications website.

Gov. Lamont called the Legislature into special session to consider the nomination of Nora Dannehy to the Supreme Court.

The governor’s proclamation compels the special session to begin on September 19.

A second special session proclamation by Lamont is anticipated later this month to consider legislation changing the date for Connecticut’s presidential preference primary.

A state court has ruled the New York Commission on Ethics and Lobbying in Government violates the state’s constitution because it was formed without a constitutional amendment and it divests the governor of her authority.

The commission will need to suspend its work pending the outcome of any appeal.

While this matter works its way through the courts, the commission will continue to promote compliance with the state’s ethics and lobbying laws. 

The Commission on Governmental Ethics and Elections Practices published legislative summaries and updated guides to reflect legislation passed in 2023.

Effective October 25, the window to register as a lobbyist is decreased from 15 to 10 calendar days following triggering activities.

Penalties for lobbyist reporting violations will increase by $50 for each successive violation during a lobbying year.

Effective June 22, the ban on direct corporate contributions was reversed and now limited to $1,950 in any election for a gubernatorial candidate; $475 for a legislative candidate; $575 for a candidate for municipal office; and $975 in any election for any other candidate. 

Twelve candidates are running in the September 5, 2023, Democratic special primary for Rhode Island’s 1^st Congressional District.

The special election will take place November 7 and will be the first congressional special election in Rhode Island since the 1967.

The seat became vacant following incumbent Democratic Representative David Cicilline’s resignation to become the CEO of the Rhode Island Foundation. 

The veto session ended on July 25 with Gov. Janet Mills giving her comments on a sustained veto of a bill seeking to prohibit campaign spending by entities influenced by foreign governments.

According to Mills, the bill poorly defined what is foreign government influence and would have the unintended consequence of effectively silencing legitimate voices, including Maine based businesses, in debates that would impact their interests. 

Mills hopes to find a way to prevent foreign influence in elections by enacting a more narrowly tailored and easily understood statute. The issue has another chance to pass as a ballot measure in November. 

New York Gov. Kathy Hochul scheduled a special election following the resignation of Assemblyman Dan Rosenthal.

The election to fill the vacancy in Assembly District 27 will be held on September 12.

Rosenthal, who was first elected at 26, is backing Sam Berger who is 25 years old and the son of a Democratic district leader.

The landscape of the Pennsylvania House of Representatives shifted with the recent resignation of Democratic member Sarah Innamorato.

The resignation leaves the Legislature tied, with the partisan breakdown now sitting at 101-101.

Democratic Speaker Joanna McClinton scheduled a special election for the Allegheny County District 21 seat to take place September 19.

Lawmakers in the Democratic-controlled House and Senate completed their final session for the year and adjourned sine die on March 30.

Bills related to campaign finance and lobbying reports were passed and signed by the governor.

Senate Bill 255 requires campaign finance reports to be filed 42 days before any election instead of just general elections.

Senate Bill 1630 increases penalties for repeated late filings of lobbyist reports by $50 for each successive violation.

Both bills are effective 90 days after the adjournment.

Lawmakers passed a campaign finance bill to double contribution limits and define terms regarding in-kind donations.

Senate Bill 846 raises the individual contribution limit from $1,000 to $2,000 per year and doubles permitted anonymous donations from $100 to $200.

In an effort to police in-kind contributions, fair market value is defined as the usual and normal charge for goods and services.

The bill became effective without the governor’s signature on June 27.

State Rep. David Cote (Hillsborough District 3) resigned on Wednesday, July 5.

Cote was first elected to the state’s House of Representatives in the 1980s and was never sworn in after winning the 2022 election due to health concerns.

In 2021, he was among the plaintiffs in a federal lawsuit arguing that requiring ill lawmakers to attend in person during the coronavirus pandemic violated the Americans with Disabilities Act.

A federal judge denied the plaintiffs request for a preliminary injunction, and the case remains unsettled. With his resignation, the Legislature now has three vacant seats.

Gov. Phil Murphy appointed four new commissioners to the state’s campaign finance watchdog agency.

The Election Law Enforcement Commission (ELEC) oversees campaign spending, lobbying, and pay-to-play in the state. 

In addition to providing Murphey with the power to appoint these commissioners, Senate Bill 2866 made a number of substantial changes to ethics laws.

These changes included increasing spending and contribution limits; overhauling pay-to-play laws; and shortening how long the state’s election watchdog commission can investigate campaign finance violations. 

The New York Legislature adjourned on June 10 after the Clean Slate Act passed both houses.

The legislation, which still must be signed into law by Gov. Kathy Hochul, wipes a New Yorker’s conviction record clean three years after sentencing for misdemeanors and eight years for certain felonies.

The Senate is not expected to return to session but the Assembly will likely return in the near future to complete unfinished work.