LobbyComply Blog

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/

Q: My company is a registered lobbyist employer in California. We are sponsoring an invitation-only reception and want to invite state officials. Are there any gift laws or other requirements we need to worry about?

A: The California gift laws allow lobbyist employers to provide gifts to an official with an aggregate total value of $630 or less each year. The gift would be reportable as an activity expense on your quarterly lobbyist employer report. Lobbyist employers must also comply with notification rules when an official receives a gift aggregating $50 or more in a calendar year.

Where notifications are required, lobbying entities must include a notice in all written or printed invitations to events at which an official will receive a reportable gift. The notice must state attendance at the event by a public official will constitute acceptance of a reportable gift. The lobbying entity must also send the official a written notice of the gift’s value after the event. The notice must be sent to an official who received a gift within 30 days following the end of the calendar quarter in which the gift was provided.

For valuation purposes, the amount of the gift to each official is the official’s pro rata share of the total cost of the food, catering services, and entertainment, plus any item provided at the event. Only those officials who attended the event should be disclosed. To determine which officials to include on the lobbyist employer report, it is a good idea to have a sign-in sheet or guest book to track attendance. Immediate family members of officials must also be disclosed if the family member attended the event.

For more information, please visit the California lobbying entry in our guidebooks. Feel free to give us a call if you have any questions. Not a guidebook subscriber yet? Request your free demo today and keep up with all lobbying, procurement lobbying, and campaign finance compliance.

The Rhode Island Ethics Commission voted to increase the maximum value of gifts public officials can receive from interested persons. The current gift limit of $25 with an aggregated limit of $75 per year will be doubled to $50 and $150 per year. Additionally, the definition of interested persons will be expanded to include lobbyists and lobbyist employers. The new limits will be effective January 1, 2026, after the commission finalizes the changes.

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

The governor signed Senate Bill 199, which will remove the requirement for legislative lobbyists to submit semi-monthly reports while the General Assembly is in session. Instead, lobbyists will be required to submit a single report due on the fifth of each month. This requirement matches the reporting requirements for lobbyists who seek to influence local governments, state agencies, and the State Transportation Board. This bill will come into effect on January 1, 2026. Until then all lobbyists are still required to submit reports on the current schedule. Additionally, Senate Bill 199 modifies the PAC reporting due dates to January 31, April 30, July 31, and October 20 of each year until the bank account has been zeroed out and the PAC has been terminated.

Q: I need to register as a lobbyist in Quebec for my company. What steps do we need to complete in the new system?

A: The Lobbyist Registry in Quebec has been replaced by Carrefour Lobby Quebec.  Previously, the senior officer was responsible for creating an account, and would list any individual lobbyists or administrators on the company’s account.  With the new system using Carrefour Lobby Quebec, the senior officer and each lobbyist must create an individual account, referred to as a professional space.  A professional space can then be linked to an organization’s account, referred to as a collective space.

To create a personal space, you first need to create your account with Carrefour Lobby Quebec.  After creating your account, you must verify it.  You can use the Verified.Me platform, which requires you to login to your financial institution.  This is the easiest method to use.  In the alternative, you can use an ID verification form managed by Lobbyisme Quebec.  With this option, you will be required to upload photo identification such a driver’s license along with a recent financial statement verifying your current address.  Once authenticated, you will have access to your professional space.

The collective space for an organization can be opened by the senior officer, an employee, or even a third party.  Once the collective space has been opened, all individuals with an authenticated professional space can request access to the collective space.  The senior officer must approve or validate these requests.  All mandates can then be published to the collective space by the senior officer, a lobbyist, or an administrator who has been granted access by the senior officer.

The information from this response can easily be found on our website in the Lobbying Compliance section of the Canada Compliance Laws publication.  Please do not hesitate to contact us if you have questions.

British Columbia’s Office of the Registrar issued a guidance document for organizations last month.

This in anticipation of the changes to the province’s lobbying laws taking effect on May 4.

The guidance document provides an overview for organizations with in-house lobbyists under the Lobbyists Transparency Act.

Beginning on May 4, the time threshold for requiring in-house lobbyists to register is reduced from 100 hours to 50 hours in the preceding 12-month period.

Time spent preparing to lobby, researching and writing reports, and strategizing would be included in calculating the time threshold required for registration.

However, activities predating a decision to lobbying would “likely not be included in the calculation,” according to the published guidance.

Organizations that are not member-based or that do not have a primary purpose to promote or oppose issues may qualify for the exception.

This is only if the organizations have fewer than six employees and the lobbying activities add up to fewer than 50 hours in the preceding 12-month period.

Examples of organizations unlikely to qualify for the exemption are unions and chambers of commerce.

Presently, a new online Lobbyists Registry is in development to replace the current Lobbyists Registry.

This registry is scheduled to launch on May 4, 2020.

Colorado lobbyist rule changes were effective June 30. Much of the changes involve recodification to ensure uniform and proper administration and implementation of state law.

Such changes clarify professional lobbyist and lobbyist firm registration and disclosure requirements as well as add or amend several lobbying definitions.

Effective January 1, 2019, a professional lobbyist must also log by date all position changes (monitoring, oppose, or support) on a bill and must file a monthly log contemporaneously with each monthly disclosure statement.

Q: I have been out of the office on an extended vacation.  I just noticed a reminder e-mail that I have a lobbying report due today that cannot be filed electronically.  What are my options?

A: You still have the ability to submit the report in a timely manner.  Your first step should be to confirm the reportable activity for your report.  If it is your lobbyist report, check your calendar or records to see whether you lobbied during the reporting period.  If the report is for your employer, you must review not only your activity, but possibly information for a contract lobbyist as well…

Click here to read the full article…

Ethics reform legislation passed the Missouri House Tuesday afternoon with wide bipartisan support.

House Bill 60 would prohibit lobbyists and lobbyist principals from making expenditures for state public officials or for their staff, spouses, or dependent children.

An exception would remain for event expenditures if all members of the Legislature or all statewide officials are invited in writing. For clarity, the bill would subsequently remove any unnecessary lobbyist reporting requirements.

The bill now moves to the Senate for consideration.

The Senate Committee on Legislative Procedure decided to table consideration of a proposed new rule to ban lobbyists from the chamber and adjacent hallways during working hours.

The measure came up for a vote yesterday and the committee voted unanimously to let the lobbyists stay. Lawmakers could decide to reconsider adoption of the proposal any time during the legislative session.

On January 1, the Rhode Island Lobbying Reform Act took effect. The Act repeals the lobbying laws in Title 22 and Title 42 in the state’s statutes and enacts a new consolidated code section covering both the legislative and executive branches of government.

Among the changes in the new law are the simplification of lobbyists’ reporting requirements, an increase in penalties for failing to comply with lobbying requirements, and the allowance for more investigative and administrative authority for enforcing the lobbying laws, including administrative subpoena power.

County commissioners approved a motion to research and draft a proposal to ban commissioners from receiving text messages from lobbyists during board meetings.

This comes on the heels of the Florida House implementing, in its rules for the upcoming session, a ban on electronic communications with lobbyists while in committee or in the House Chamber.

Commissioner Sandy Murman introduced the idea; however, no penalties for a violation were included in the proposal. Though the measure for further exploration passed 5-1, support among commissioners for an actual ban seemed less decisive during the meeting.

The Georgia Government Transparency and Campaign Finance Commission has announced the lobbyist registration renewal window for 2017.

Current lobbyists who do not owe any fees, fines, penalties, or reports may renew their registrations online beginning December 1, 2016, until 12:00 p.m. on January 13, 2017. Lobbyists who fail to timely renew their registration must register as a new lobbyist using paper forms.

Lobbyist badges are also expected to be sent much sooner than in past years. The Commission has asked lobbyists to allow up to two weeks for badges to be delivered.