LobbyComply Blog

The Nebraska Legislature adjourned its regular session sine die on April 17. Lawmakers passed Legislative Bill 1075, a bill related to campaign finance and lobbying. The bill increases committee registration fees and increases late filing fees for committee registrations, registration updates, reports, and independent expenditure reports. The bill also requires ballot question committees to include in their statements of organization a certification that no preliminary activity was directly or indirectly funded by one or more foreign nationals. The bill allows committee reports disclosing certain contributors to list a post office box address for the contributor, unless the contributor is a committee, and increases late filing fees for lobbyist and principal activity reports. The bill was passed as an emergency and takes effect immediately. This does affect lobbying reporting. An activity report is due 45 days following adjournment on June 1.

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Utah Senate Bill 145, signed by Gov. Spencer Cox on March 17, 2026, amends several provisions of the state’s lobbying laws. The changes are effective May 6, 2026, and address procurement lobbying, contingency fee restrictions, university event expenditures, and de minimis gift thresholds.

What Does Utah SB 145 Change?

SB 145 touches four distinct areas of Utah lobbying compliance. Here is a breakdown of each amendment.

Procurement Lobbying Deregulated for Local and Education Entities

SB 145 removes procurement activities from the relevant lobbying definitions that apply to local government lobbying and board of education lobbying. Under the revised definitions, local and education lobbying generally covers legislative and administrative actions, but does not include  adjudicative proceedings and purchasing and contracting decisions.

This change deregulates local and education procurement lobbying, reducing compliance obligations for those communicating with a public official for the purpose of influencing a purchasing and contracting decision  at the local government and board of education level.

Contingency Lobbying Restrictions Extended

Prior Utah law prohibited hiring a lobbyist for compensation contingent, in whole or in part, upon a specific legislative or executive outcome. SB 145 expands these restrictions to also cover local and educational actions.

Under the updated law, incentivized lobbying is prohibited when a lobbyist’s compensation is tied to:

• A government action occurring, or
• The amount appropriated for a government program

Organizations engaging lobbyists in Utah should review existing compensation structures to confirm they remain compliant under the broadened scope. Learn more on our Lobbying Compliance Consulting page

Broader Event Exemptions for University-Sponsored Events

Expenditure reporting will no longer be required for admission, attendance, and travel to or from the following types of events, provided they are hosted by public or nonprofit higher education institutions:

• Recreational events
• Sporting events
• Artistic performances
• Art exhibitions
• Other artistic events

To qualify for the exemption, the event must occur at the institution, and the purpose of the public official’s attendance must be to build a relationship with the institution.

Previously, such attendance offers were only permitted for public colleges and universities as governmental sponsors. The revision extends the exemption to nonprofit higher education institutions as well.

De Minimis Gift Thresholds Increased

SB 145 raises the threshold for de minimis expenditures that lobbyists may make for public officials without triggering reporting requirements:

Item Category	Previous Threshold	New Threshold
Nonfood items	$10	$25
Publications & commemorative items	$30	$50

The adjustment reflects higher costs for such items and responds to the prior thresholds being found overly restrictive in practice.

When Do the Changes Take Effect?

All amendments under Utah SB 145 take effect May 6, 2026.

Lobbyists and their organizations should audit current practices, particularly around contingency compensation structures, to ensure compliance before that date. Lobbyists interested in making larger value expenditures should review the updates to ensure continued compliance.

For jurisdiction-specific guidance, State and Federal Communications maintains regularly updated online compliance guidebooks covering Utah and other states.

Utah Senate Bill 145 FAQs 

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.

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.

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