LobbyComply Blog

We are pleased to congratulate Renae Bomba, Esq., Manager of Compliance Services at State and Federal Communications, on her 10-year anniversary with the company.

Renae began her career at State and Federal Communications in 2016 as a Research Associate. She advanced to Compliance Associate in 2017 and was promoted to Manager of Compliance Services in 2020. Throughout her tenure, Renae has been driven by a commitment to helping clients remain compliant while making their work easier and more efficient.

The Compliance team provides essential guidance to consulting clients on registrations, reporting requirements, and terminations, working closely with them to ensure compliance with lobbying and campaign contribution laws. Clear and consistent communication is critical, as state and local regulations are constantly evolving. State and Federal Communications’ continued investment in technology has also played an important role in supporting the growing and changing needs of clients.

“In the Compliance Department, you work with and learn the different filing systems and rules” Renae explained. “You talk with clients, help them to the best of your ability, and gather all the information needed to file reports correctly.”

Renae is a trusted expert within the Compliance Department, known for her deep familiarity with compliance systems and processes. She values her strong relationships with existing clients and enjoys guiding new clients as they integrate into State and Federal Communications’ systems and workflows.

When regulatory quirks or nuances create challenges during the filing process, Renae works directly with state agencies and organizations to advocate for clients and identify what may need to be fixed, clarified, or improved. Much of this work involves managing risk and understanding how differences in state rules—and changes to those rules—can impact clients.

The team at State and Federal Communications, Inc. is made up of experienced professionals you can trust. Learn more about how we support your compliance needs at https://stateandfed.com/services/.

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.

Your Question: Where do I need to register after I lobbied in a state?

Our Expertise: Deciding whether and where you need to register is already a herculean task, as you must navigate the labyrinthine world of state compliance laws. Along the way, you may encountera divergence in the path: one route leads to state registration, another to local registration, and a third requires both.
Thankfully, we at State and Federal Communications are here to offer you a ball of thread to assist with navigating the myriad paths that make up state and local compliance.

The first step in determining where registration is required is identifying who or what you are lobbying. Local lobbying generally targets city councils, county boards, and municipal authorities, while state lobbying targets state legislatures, governors, and state agencies. One potential hazard is misunderstanding which level of government oversees the entity you are lobbying.

For example, is the water authority owned by the city, county, or state? Is a local college part of the state university system? Lobbying these peripheral governmental entities may require registration with the entity itself, the local municipality, the county, or the state, depending on its governance.

Once you understand the scope of your lobbying, the next step is to review the law and verify the registration threshold. Some localities have their own reporting systems, while some states include local-level lobbying in their registration threshold. This analysis is done by delving into the registration threshold, then focusing on the definition of lobbying. If the definition concentrates on “state legislatures or agencies,” local lobbying is excluded.

Next, check to see if the local municipality you are lobbying has its own lobbying law and determine whether local registration is required. Finally, if applicable, confirm that the entity itself does not require registration.

Want to keep up with all the newest happenings in lobbying, campaign finance, and procurement lobbying compliance? Sign up for our Compliance Now newsletter and never miss a beat – https://stateandfed.com/e-newsletter/

Question: I’m a registered lobbyist in multiple states—how long do I need to keep my notes, meeting records, and receipts? Is it okay to get rid of them after the report is filed?

Answer: No. The best practice is to maintain your records for the full period required by each jurisdiction where you are registered. You should also be aware of whether any of those jurisdictions conduct regular or random audits, as you may need to produce your records during that process.

Most jurisdictions set a specific retention period for lobbying records. If you are registered in multiple states, it’s usually simplest—and safest—to follow the longest retention period among them. For example, if you are registered in both Washington and Idaho, you may choose to keep all records for five years, which matches Washington’s requirement, rather than maintaining separate timelines (three years for Idaho and five for Washington).

Registering as a lobbyist brings reporting obligations, but it also creates responsibilities for proper record maintenance, and it may subject your records to audit. Maintaining complete and accurate records helps substantiate the information included in your reports and reduces risks during an audit or investigation. Make sure to keep all required documents for the full period mandated by each jurisdiction to avoid future compliance issues.

Some states conduct regular audits. In 2025, Connecticut randomly selected 30 client lobbyist names for audit. Florida’s Legislative Auditing Committee selects a random sample of 3% of all lobbying firms each year for compensation report audits. Tennessee audits the registration statements, amendments, and lobbying reports of up to 4% of lobbyists annually.

Keeping your records organized and preserved for the required period ensures you are prepared if you are ever selected for an audit.

More information about procurement lobbying requirements can easily be found on our website in the Document Retention and Audits section of the Lobbying Compliance Guidebook. Not a subscriber yet, sign up for your free demo today.

The Bureau of Elections posted the Lobby Registration Act 2026 Reporting Thresholds, which change every year in January to reflect the change in the consumer price index for Detroit. The registration thresholds for individual lobbyist compensation and for employer expenditures on a single official remain unchanged for 2026 at $800. Exempt expenditures remain unchanged for 2026 at $16. The registration threshold for an employer making lobbying expenditures increased from $3,175 to $3,200 for any 12-month period. The financial transaction threshold between a registered employer or lobbyist and a public official remains unchanged for 2026 at $1,600. The reporting threshold for travel and lodging reimbursements increased from $1,025 to $1,050. The monthly food and beverage expenditures allowance for a public official remains unchanged for 2026 at $79, and the threshold for food and beverages purchased between January 1 and the end the reporting period increased from $475 to $500. Employee reimbursements remain unchanged for 2026 at $32, and the general gift threshold also remains unchanged for 2026 at $79. Late filing fees remain unchanged for 2026 at $32 a day up to a maximum of $960. 

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.

A representative from the Office of Secretary of State testified at a recent meeting of the Legislature’s Special Committee on Campaign Contributions and Transparency. Among the items raised was a legislative proposal to file campaign finance and lobbyist disclosure reports online and directly with the Kansas Public Disclosure Commission instead of through the Office of Secretary of State. Another proposal would have lawmakers repeal a requirement for PACs to report information about sub-vendors in reports of expenditures made directly to vendors. If viewed favorably, these reforms may be taken up for consideration in next year’s legislative session.

Stay up to date with all state and federal lobbying law. Sign up for our online guidebooks and never miss a compliance law change.

County Commissioners held a public hearing on August 5 on a repeal and reenactment of the county ethics code. Bill No. 5-2025 brings the county’s code in line with state mandates for local ethics codes. Changes include amending definitions relating to lobbying and gift terms; an additional lobbyist report due on July 31; and a new $250 lobbyist compensation threshold for registration.

Never miss a lobbying compliance deadline. Sign up for our online guidebooks today!