LobbyComply Blog

Sometime in 2027, New Brunswick, Canada’s new lobbying law amendments will be brought into force. Bill No. 44, An Act to Amend the Lobbyists’ Registration Act, which was introduced and passed in May and received royal assent in June, mandates monthly reporting and additional disclosures not currently required, including with whom a lobbyist met, when they met, and where they met. The new law gives the Office of the Integrity Commissioner the authority to investigate violations and to impose financial penalties. The commissioner will also create a code of conduct for lobbyists. The code, with which lobbyists must comply, will detail the expected ethical standards, behaviors and responsibilities of lobbyists.

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The Maine Commission on Governmental Ethics and Elections Practices proposed routine technical changes to update the commission’s rules after the passage of two campaign finance bills this session. Proposed updates include guidance on the disclosure required for paid communications containing misleading manipulated media of a candidate and a threshold increase for filing independent expenditure disclosure reports. The commission will hold a hearing on June 24 and will accept comments through July 8.

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The Maine Commission on Governmental Ethics and Election Practices proposed commencing a rulemaking at the upcoming meeting on May 27. The purpose is to update the commission’s rules based on newly chaptered laws from this year’s legislative session. Legislative changes to be addressed include disclosure requirements for paid communications containing manipulated images or audio of a candidate, and an increase to the spending threshold for independent expenditure reporting. If the rulemaking is commenced, an invitation to comment is expected to begin on June 1.

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The Colorado Legislature adjourned sine die on May 13. Lawmakers passed House Bill 1422, a bill addressing security measures for certain governmental entities and modifying registration requirements for political committees. The bill specifies the address of the principal place of operations listed by a political committee or small donor committee on its registration statement may be either a street address or a mailing address. If the bill is approved by Gov. Jared Polis, this provision will take effect immediately. Legislators also passed Senate Bill 147, a bill which would require legislative liaisons, judicial lobbyists, and governor’s lobbyists to register and file disclosure statements similar to professional lobbyists. Polis has not yet acted on this bill, but his office has signaled disfavor. If approved, the bill would take effect August 12.

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Today, the Federal Election Commission (FEC) published its price index adjustments for expenditure limitations and the federal lobbyist bundling disclosure threshold. The lobbyist bundling disclosure threshold has increased for 2026 from $23,300 to $24,000. This threshold amount is adjusted annually. Federal law requires authorized committees of federal candidates, leadership political action committees (PACs), and political party committees to disclose contributions bundled by lobbyists and lobbyists’ PACs. Additionally, the FEC published its adjusted Coordinated Party Expenditure Limits for political parties for 2026.

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Question

I recently began a new position with responsibility for local government relations for my employer. I’ve only previously done state work. What do I need to know?

Answer

Local government lobbying compliance is significantly more fragmented and complex than state-level lobbying, and the differences can catch even experienced state lobbyists off guard. While state lobbying laws tend to follow more standardized frameworks, local lobbying requirements vary widely by jurisdiction, population size, government entity, and even industry.

Local Lobbying Laws Are Not Universal

Unlike state lobbying, some smaller cities, towns, and special districts have no lobbying ordinances. However, the absence of a local ordinance does not necessarily mean that compliance obligations do not exist. In several states, including Alabama, Georgia, Illinois, Mississippi, and Missouri, state lobbying laws extend to local government activity, requiring lobbyists to register and report with the applicable state agency when engaging with local officials.

In New York, for example, the state lobbying statute requires disclosure of all lobbying activities before municipalities, including jurisdictional subdivisions with populations exceeding 5,000 residents.

How State Law Can Shape Local Lobbying Requirements

State law may also mandate that local governments adopt their own lobbying frameworks. Maryland does not require local lobbyists to register at the state level, but it requires counties and municipal corporations to maintain lobbying regulations that substantially mirror state lobbying rules.

Highly regulated states such as California often have robust local disclosure requirements, particularly in larger cities and counties. Florida, while somewhat less centralized than California, is also known for numerous local lobbying ordinances that govern municipal and county-level advocacy.

Industry-Specific and Entity-Specific Compliance Risks

Local lobbying requirements frequently extend beyond traditional city councils and county commissions. Special-purpose entities (SPE) often impose their own disclosure regimes. Transportation authorities, such as the Los Angeles Metropolitan Transportation Authority, and airport authorities, such as the San Diego County Regional Airport Authority, may require separate registration and reporting.

School districts also present compliance risks. Lobbying activity involving districts such as Broward County Public Schools, Los Angeles Unified School District, or Miami-Dade County Public Schools can trigger registration and periodic reporting obligations, even when activity would not be reportable at the state level.

Healthcare is another highly regulated area. Some public hospital systems impose lobbying requirements that are more stringent than local ordinances. For example, Jackson Health System, an affiliated network of hospitals in Miami-Dade County, requires all pharmaceutical representatives to register as lobbyists before visiting facilities to promote products.

No Thresholds Mean Higher Compliance Exposure

A critical difference between state and local lobbying is that many local jurisdictions impose no monetary or activity thresholds. This means registration may be required simply for engaging in conduct that meets the definition of lobbying, regardless of time spent or compensation received. As a result, even minimal outreach can create compliance obligations.

Before engaging in any local government relations activity, it is essential to independently verify applicable state laws, local ordinances, and entity-specific rules or consult with a lobbying compliance professional to reduce the risk of inadvertent noncompliance.

Note: The information in this response can be easily found on our website in the Lobbying Compliance section of the United States Lobbying Compliance Guidebook.  Please do not hesitate to contact us if you have questions.

Frequently Asked Questions About Local Lobbying Compliance

1. How can I tell whether a local jurisdiction has a lobbying ordinance?

There is no single database or universal indicator. Larger cities and counties are more likely to have lobbying ordinances, but population alone is not determinative. Each jurisdiction must be reviewed individually, including municipal codes, ethics ordinances, and administrative policies. Special districts and quasi-governmental entities should be evaluated separately.

2. Does lobbying a local official always require registration?

Not always, but many local jurisdictions define lobbying broadly. In some cases, registration is required immediately upon engaging in covered activity, regardless of compensation or frequency. Where no registration threshold exists, even introductory meetings, informational outreach, or industry-specific advocacy may trigger obligations.

3. If state law governs local lobbying, do local rules still matter?

Yes. Even when state law applies, local ordinances or entity-specific policies may impose additional requirements. These can include separate registration, local reporting schedules, gift restrictions, or cooling-off periods. State compliance should never be assumed to fully satisfy local obligations.

4. Why is the absence of a registration threshold risky?

When no threshold exists, there is little margin for error. Limited or informal activity can still require registration and reporting, increasing exposure to enforcement actions, fines, or reputational harm if obligations are overlooked. Conservative compliance analysis is strongly recommended.

5. What steps should I take before engaging in local lobbying activity?

Before engaging with local officials or entities, confirm:

• Consult with a Lobbying Compliance Firm
• Whether state law applies to your activity
• Whether the local jurisdiction has a lobbying ordinance
• Whether special entities (school districts, transit authorities, hospitals) impose independent requirements
• Whether industry-specific rules apply

When uncertainty exists, consulting with a lobbying compliance firm, like State and Federal Communications, can help ensure accurate registration, timely reporting, and reduced compliance risk.