LobbyComply Blog

On October 27,  Attorney General Doug Downey announced comprehensive proposals to change Ontario’s dates of elections, increase its political contribution limits, eliminate pre-writ spending limits for third parties, and alter other provincial campaign finance laws.

The reforms, announced in a news release by the government of Ontario, would eliminate “American-style fixed election dates” in favor of provincial elections taking place on a date determined by the lieutenant governor on the advice of the premier, but within the five-year maximum limit mandated by the province’s constitution.

Beginning in 2026, individuals’ contribution limits to a political party would be raised from $3,400 to $5,000. Future increases would be indexed to the rate of inflation.

In addition to eliminating third party and political party pre-writ spending limits, the government proposes establishing new financial penalties for those not in compliance with the Election Finances Act.

The amendments to the law would also provide new investigative powers to the Chief Electoral Officer to request information from third parties to ensure they are in compliance with political advertising rules. The proposed changes to the law also include requiring third parties to provide proof of registration status to broadcasters and publishers before placing political advertisements during an election period. 

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Question: Every six months we survey our officers and directors asking whether they have made personal political contributions. Is this sufficient for purposes of pay-to-play reporting?

Answer: Unfortunately, an after-the-fact survey is insufficient in protecting your company from running afoul of pay-to-play laws.
Surveys provide information about personal contributions after the contribution has already been made. When you sit down to complete a pay-to-play report and you consult the survey responses, the damage has already been done if the contribution was made in violation of the pay-to-play law. Furthermore, the time for corrective measures (seeking reimbursement of the contribution) has more than likely passed.
Developing an internal program whereby employees (and in some instances their immediate family members) must seek pre-approval before making a personal political contribution is the gold standard. It is the best practice to ensure compliance with the varied pay-to-play laws.
The most compelling reasons to implement a pre-clearance program are to avoid debarment, fines, and negative publicity. Moreover, having a contract rescinded because of a pay-to-play violation can result in the loss of millions of dollars in revenue.
The success of any program is directly proportional to the education provided to employees. Educating them on the need for a pre-clearance strategy results in increased participation, which in turn results in decreased risk to the company.
At its core, a thorough program must let employees know the company is not prying into their personal spending habits and requiring permission is not an attempt to invade their privacy. The message must be conveyed that the company has legitimate business reasons for requiring pre-approval. Such reasons include: maintaining the company’s ability to effectively conduct business with states and municipalities; ensuring the conduct of the company’s employees does not jeopardize the company’s reputation; and shielding the company’s employees and their family members from personal liability.
There is no one-size-fits-all compliance program, but if a pre-clearance strategy is not used, a violation of a jurisdiction’s pay-to-play law is more likely to occur.

For more information, be sure to check out the “Pay-to-Play” section for each state and local jurisdiction in the U.S. Procurement Lobbying Compliance Laws online publication. Please feel free to contact us if you have any questions. – https://stateandfed.com/contact-us/

The campaign contribution limits for city elections have been adjusted. The amount that may be contributed to mayoral candidates has increased from $3,720 to $3,980 per election cycle. The amount for City Council candidates increased from $790 to $850 per election cycle. Political action committees are no longer required to file local campaign finance reports with the city clerk pursuant to an ordinance passed by council earlier this year. State campaign finance reporting requirements are still applicable.

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 A divided panel of the U.S. Sixth Circuit Court of Appeals issued a new per curiam opinion in the OPAWL v. Yost case about the constitutionality of 2024 Special Session House Bill 1, which prohibited foreign contributions to ballot measure committees. In June 2024, the U.S. District Court for the Southern District of Ohio granted a preliminary injunction against enforcement of the prohibition finding the law was likely unconstitutional because federal law allows permanent residents to make contributions. Then on October 8, 2024, a divided three-judge panel granted the state’s motion to stay the district court’s preliminary injunction, with one judge dissenting. On September 16, a divided three-judge panel affirmed the October 8 ruling reversing the district court’s order granting the injunction and remanding the case to the District Court for further proceedings consistent with the new opinion and with that of the majority in the October 8, 2024, ruling.

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The Maine Commission on Governmental Ethics proposed rule amendments to align with statutory changes regarding contributions by lobbyists and to make uniform citations. The proposal clarifies rules relating to the ban on lobbyist contributions during legislative sessions and adds a definition for covered officials. The commission will accept written comments on the proposal until October 6 and will hold a public hearing for comments during the commission’s meeting on September 24.

A proposed ordinance would limit contributions by individuals to City Council candidates and committees to $2,600 during any election cycle. Currently, contributions are unlimited. The proposed ordinance, introduced at the August 25 City Council meeting, also requires all political committees to file a statement of organization with the clerk of the city no later than 10 days. Political committee is defined in the ordinance to include a group of persons making over $200 in contributions to candidates. If passed the ordinance will be effective immediately.

Invite them out for coffee or a steak? Make sure you know the gift restrictions of your state or municipality. Request a demo of our online guidebooks today.

The Ethics Commission announced the new campaign finance website will be launched this month. The current website will be taken down on August 15 and no further data will be able to be input into the old system. The conversion is expected to be completed by Monday, August 19. Brief video tutorials on how to use the new system will be on the website at launch. The Ethics Commission is offering in person and online trainings ahead of the next campaign finance reporting date of January 15, 2026.

Invite them out for coffee or a steak? Make sure you know the gift restrictions of your state or municipality. Request a demo of our online guidebooks today.

The 83^rd session of the Legislature adjourned sine die on June 27. Lawmakers did not pass a last-minute attempt to delay Oregon’s campaign contribution limits, established last year by House Bill 4024. The limits are set to take effect in 2027, however some legislators wanted to postpone the limits until 2031.

Monitor your registration thresholds by state, by referring to our easy to navigate online guidebooks. Request a web tour to learn more.

The New Hampshire General Court stands adjourned as of June 26 until the next call of the chair. A bill to prohibit corporate campaign contributions was voted down in committee. Lawmakers passed a budget for the next two years, which was signed by Gov. Ayotte on June 27.

Invite them out for coffee or a steak? Make sure you know the gift restrictions of your state or municipality. Request a demo of our online guidebooks today.

OHIO: The Office of Secretary of State published increased contribution limits. The contribution limits for what PACs, PCEs and individuals may contribute to statewide candidates, candidates for General Assembly, county parties, PACs, and PCEs increased from $15,499.69 to $16,615.67 per election; from $46,499.08 to $49,847.01 per calendar year to state parties; and from $23,249.54 to $24,923.51 per calendar year to legislative campaign funds. The amount of gifts corporations and labor unions may provide per year to a state political party, county political party, or legislative campaign fund for specified purposes increased from $12,751.16 to $13,669.24.

Campaign contribution limits increased in British Columbia for 2025 to $1,484.38 for contributions to registered political parties, including their candidates, nomination contestants and registered constituency associations. Additionally, individuals can also contribute up to $1,484.38 to independent candidates and leadership contestants, if a leadership contest is called in 2025. The previous limits from 2024 were $1,450.82 and $1,401.40 in 2023. Also increased to $420 is the limit of a fee paid to attend a leadership convention or other convention of a political party without counting toward the $1,484.38 contribution limit. These contribution amounts are adjusted at the start of each calendar year.

Campaign contribution limits increased in the city of Surrey, British Columbia for 2025 to $1,402.40 for local elections candidate or elector organization per campaign. For a local by-election held in 2025, unendorsed candidates may contribute an additional $1,402.40 to their own campaign, and a group of endorsed candidates may contribute an additional $1,402.40 in total to the campaign of the elector organization. The campaign contribution limit is adjusted at the start of each calendar year.

Elections Canada has published the federal contribution limits for the 2025 calendar year. In 2025, individuals may contribute up to $1,750 to independent candidates, leadership candidates, registered parties, and to, in total, all of the registered associations, nomination contestants and candidates of each registered party. The limits also apply to any unpaid balance of loans made during a contribution period and the amount of any loan guarantees made during a contribution period. The limits increase annually by $25 on January 1.

Campaign contribution limits have increased in Ontario for 2025. In a calendar year, a person individually may contribute $3,400 to each party, to each constituency association and nominations contestants of a party, and to each leadership contestant of a party. Additionally, in a campaign period, a person may contribute $3,400 to each candidate of a party, and to each independent non-party candidate. The total contribution made with respect to a single fundraising event by a contributor may not exceed $3,400 multiplied by the indexation factor. The previous contribution limits from 2024 were $3,375.