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.

On January 19, the lobbyist registration threshold for organizations and corporations was lowered. Last year the Office of the Commissioner of Lobbying of Canada issued new interpretation bulletins concerning the significant part of the duties threshold for when organizations and corporations must be registered under the Lobbying Act. One bulletin lowered the lobbyist registration threshold from 32 hours per month to eight hours in a rolling four-week period. A second updated interpretation addresses the Lobbying Act’s revolving door provision and interprets a significant part of a designated public office holder’s work as eight hours or more in any given consecutive four-week period. This includes any time spent preparing for and participating in oral communications with public office holders, as well as drafting written communications to public office holders.

Want to keep up with lobbying, procurement, and corporate contribution compliance internationally? We have you covered. Learn more here.

Campaign Finance

Arizona: “Arizona Bill Aims to Shield Small-Dollar Donors’ Information” by Zachery Schmidt (Center Square) for MSN

Massachusetts: “Mass. Legislation Aims to Point Light at Dark Money in Local Politics” by Sam Drysdale (State House News Service) for Cape Cod Times

New York: “NYC Board Probes Pro-Cuomo PACs Spearheaded by Finance CEOs” by Laura Nahmias (Bloomberg) for MSN

Ethics

National: “Trump Suffers Several Defeats in Effort to Punish Opposing Lawyers” by Julian Mark (Washington Post) for MSN

National: “Pipe Bomb Suspect Told FBI He Targeted US Political Parties Because They Were ‘in Charge,’ Memo Says” by Eric Tucker (Associated Press) for MSN

National: “‘I Ultimately Had to Comply’: ’60 Minutes’ EP faces fallout after Bari Weiss shelves story” by Liam Scott and Scott Nover (Washington Post) for MSN

North Carolina: “A Company Invited Cary Staff to Dinner. The Offer Came from the Mayor.” by Dan Kane (Raleigh News and Observer) for MSN

Lobbying

New York: “Hung Jury Ends Trial of Ex-New York Governors’ Aide Accused of Selling Influence to China” by Philip Marcelo (Associated Press) for MSN

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.

The Colorado Supreme Court heard oral arguments in Unite for Colorado v. Colorado Department of State on the question of what constitutes a major purpose of ballot issue advocacy for purposes of requiring an organization to register and report as an issue committee. At issue was whether the statutory and constitutional legal framework permits regulators to look only at activity related to a single ballot issue or if they may consider an organization’s aggregated activities on multiple ballot issues in determining whether ballot issue advocacy is a major purpose of the organization. The General Assembly amended state statutes in 2022 to provide single and aggregate ballot issue percentage-of-total-spending major purpose thresholds but Unite contends its arguments may nevertheless have implications for the amended law.

Do you know if your activities are defined as lobbying? We do. Take a walkthrough demo of our guidebooks today.

Campaign Finance

Missouri: “Missouri Bill Targets ‘Misleading’ Automatic Donations Connected to Bill Eigel” by Rudi Keller (Missouri Independent) for Yahoo News

New York: “NY Gov. Hochul Accepted – and Is Now Refunding – Thousands in Donations from Appointees” by Jimmy Vielkind for Gothamist

Elections

Tennessee: “Republican Wins Special Election in Trump Country, as Democrat Gains Ground” by Dan Merica (Washington Post) for MSN

Ethics

Illinois: “Former Inspector General Joe Ferguson Fined $5K for Revealing Botched Little Village Smokestack Implosion Could Have Been Prevented” by Heather Cherone for WTTW

National: “Former President of Honduras, Convicted of Trafficking, Freed after Trump Pardon” by Tobi Raji, Shayna Jacobs, and Samantha Schmidt (Washington Post) for MSN

New Jersey: “NJ AG, Others Attack Bill That Would Combine State Watchdog Agencies” by Mike Davis and Michael Diamond (Asbury Park Press) for MSN

Lobbying

Canada: “Ontario Will Require Skills Grant Applicants to Reveal If They Hired Lobbyists” by Moira Welsh for Toronto Star

Kentucky: “Groups Spent $9M Lobbying Kentucky Executive Branch Officials in Past Fiscal Year” by Joe Sonka for Louisville Public Media

Campaign Finance

Missouri: “How a Nebraska Veteran Unwittingly Became a Repeat Donor to a Missouri County Campaign” by Rudi Keller (Missouri Independent) for Yahoo News

North Dakota: “Campaign Finance at Heart of Latest Skirmish Between Executive Branch, ND Ethics Commission” by Jacob Orledge (North Dakota Monitor) for Yahoo News

Elections

Georgia: “Georgia Prosecutor Keeps Case Against Trump Alive for Now” by Patrick Marley (Washington Post) for MSN

Ethics

National: “Judge Says Possible Errors by Lindsey Halligan Could Imperil Comey Case” by Kyle Cheney and Josh Gerstein (Politico) for MSN

National: “Trump Gives Second Pardon to Jan. 6 Participant and Pardons Two Others” by Michael Kranish (Washington Post) for MSN

National: “Former Fed Official Resigned Following Ethics Probe, Document Shows” by Victoria Guida (Politico) for MSN

Michigan: “Woodward’s Firm Gave Campaign Services to Third of Commissioners He Oversees” by Max Bryan (MediaNews Group) for MSN

Redistricting

Indiana: “Indiana Likely Will Not Push Forward with Redistricting Despite Pressure from White House” by Adam Wren and Andrew Howard (Politico) for MSN

Rep. Kaohly Her is the first woman and Hmong American elected as the mayor of St. Paul in a historic upset over incumbent Melvin Carter after a tabulation of second-choice votes. Her’s victory also marks the first time the entire leadership of the city is made up of all women. This is the last year the St. Paul mayor’s race will be held in an odd numbered year. Her’s term will run through 2028, when the city will hold its next mayoral election.

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.

Ballot Measure 6, which would have moved local elections to the same year as presidential elections has been defeated after only receiving around 46% of the vote.

Comply with state and local procurement lobbying rules. Our online guidebooks make it easy to view regulations all in one place. Learn more here.

Campaign Finance

California: “SF Eyes Subtle Spending Reform After Priciest Election Ever” by Adam Shanks for San Francisco Examiner

Elections

Michigan: “Judge Throws Out Charges Against GOP Would-Be Electors in Michigan” by Patrick Marley (Washington Post) for MSN

Ethics

National: “Trump Administration Halts I.R.S. Crackdown on Major Tax Shelters” by Jesse Drucker (New York Times) for Seattle Times

National: “Defying Past Criticism, Trump Plans G-20 Summit at His Doral Resort” by Natalie Allison and Michael Birnbaum (Washington Post) for MSN

Indiana: “Remediation Document Reveals Ethics Concerns Before Indiana Cabinet Secretary Resignation” by Casey Smith and Niki Kelly (Indiana Capital Chronicle) for Yahoo News

New Jersey: “N.J. Comptroller Alleges Conflicts of Interest Involving George Norcross’ Firm and Local Government Insurance Funds” by Andrew Seidman (Philadelphia Inquirer) for MSN

Tennessee: “Judge Acquits Casada, Cothren on 3 Charges for Insufficient Evidence, Other Counts Stand” by Vivian Jones (Tennessean) for Yahoo News

Lobbying

Rhode Island: “No Time Like the Present to Change Lobbyist Gift Rules, Open Government Advocates Tell Ethics Panel” by Alexander Castro (Rhode Island Current) for Yahoo News

The Texas Legislature adjourned the First Special Session of the 89th Legislature sine die on August 15. A congressional redistricting map and other bills were passed by the Senate, but no bills advanced through the House on account of a lack of quorum. On Gov. Greg Abbott’s call, a Second Special Session convened the same day. Legislators are being asked to address the same agenda as the First Special Session, including congressional redistricting, flooding preparedness and relief, taxpayer funded lobbying, and other matters, as well as an additional item concerning youth camp safety. The special session may last up to 30 days.

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

Q.  We have submitted a bid proposal for a contract with a state agency in Illinois. We were instructed that we must register with the Illinois State Board of Elections. Is this registration different than our existing lobbyist registration? If so, what does that mean for our company?

A. The simple answer is yes. The Illinois Procurement Code requires business entities, whose business or potential business exceeds an aggregate annual total of more than $50,000, to register with the Board of Elections and comply with the state’s Election Code. This registration must be completed prior to submitting any bid that would cause the business entity to exceed the threshold.
In addition to the business entity’s name and corporate contact information, the business entity must disclose certain affiliate entities and affiliated individuals. These affiliates include corporate parents, operating subsidiaries, operating subsidiaries of their corporate parents, persons with a significant ownership interest or distributive shares, executive employees, and spouses of any of these affiliated individuals. However, any entities or individuals prohibited by federal law from making contributions or expenditures in elections do not need to be included in the business registration.
In addition to this initial registration, the registration must be updated quarterly to account for any changes to the entities or that list of affiliates, and, if there is a bid or proposal pending, it must be updated within seven days of any changes that occur. This constant maintenance continues for up to two years following the expiration or termination of the contracts. Failure to maintain this registration could result in voiding all active contracts with the state or its agencies.
Additional requirements of the registration include providing notice to political committees in receipt of contributions from the registered entity and their affiliates, disclosures to the state agency and the Illinois Secretary of State of the register entities’ lobbying activity in the state, and certifications of your compliance with these registration requirements.
These business entity registrations are complex and contain pitfalls if not carefully and constantly maintained. So, it is important to familiarize yourself with each of these requirements and to constantly review your registration to ensure full compliance.

Comply with state and local procurement lobbying rules. Our online guidebooks make it easy to view regulations all in one place. Learn more here.

State and Federal Communications is thrilled to be celebrating its 32^nd anniversary this month. During this time there have been a wide range of changes that the company has adapted to and grown to meet. However, the one common thread that has remained steadfast throughout is our President and CEO, Elizabeth Bartz. The company is now thriving and working with some of the biggest names across many industries in the U.S., but it wasn’t always this prominent. Elizabeth had to work hard for what her company has become.

In 1993, Elizabeth was looking for a change. She was working at State and Federal Associates in Washington D.C. and was ready to move back home to Akron, Ohio. As it turns out, her employer was also looking for a change and approached Elizabeth with an interesting offer.

“They approached me because they were thinking of closing my department and asked me if I was interested in buying it and moving it to Akron. My other choice was coming back and managing a Subway store with my father. I had 10 years in managing a compliance department and I was good at it, so it was an easy decision, but a risk… and I didn’t know what I didn’t know.”

Elizabeth was up for the challenge of making something altogether new to the industry, a company solely focused on lobbying compliance. However, it was a big risk moving it back home to Akron from the hub of activity that is Washington D.C. State and Federal Communications was born, with Elizabeth at the helm, quite a few obstacles to overcome, and a small eager staff.

Through persistence and a lot of networking, Elizabeth made her company a success and began to grow a reputation as reliable and precise. As the company has grown one quality, perhaps above all others, has helped Elizabeth to make her business a success – the ability to connect with people and help fill their needs. This has manifested itself in many ways, both within business, and with philanthropic giving within the local community. This spirit of giving has become a cornerstone within the culture of State and Federal Communications with its Corporate Social Responsibility Program. The CSR program has become so integral that it has projected the company into the top 10 corporate givers to United Way within Summit County.

 “Especially now, with everything going on, we need people to help other people… We provide charitable service hours for any employee who gives .5% or 1% of their compensation. This becomes a win-win with United Way of Summit and Medina County receiving the financial benefit and the employee’s choice of charity receiving their charitable hours.”

Elizabeth’s personal giving focus is very diverse, but one of the causes closest to her heart is education. Helping to fund scholarships and grants through The John S. Knight Foundation, Akron Urban League, and Akron Press Club are among her passions. Another passion of Elizabeth is helping others to succeed both in her industry and within the local community. This passion has helped her staff develop professionally, and in turn allowed a relatively small staff of compliance professionals to make State and Federal Communications into the gold standard in lobbying, procurement lobbying, and political giving compliance.

Today, State and Federal Communications boasts a large online database of federal, state, and municipal legislative codes. The company has come a long way since Elizabeth’s scrappy start-up sent out loose-leaf binder guidebooks and helped clients in navigating the information via telephone. Through maintaining excellent relationships with clients; unwavering attention to detail in the service provided; and an uncanny ability to network with decision makers State and Federal Communications was able to make its presence felt in the industry and its services indispensable to many.

At the center of State and Federal Communications’ success is Elizabeth, keeping the company striving toward what is needed by clients and innovating to stay ahead of the curve. Today, clients have more needs, with the ever-changing compliance guidelines, and State and Federal Communications continues to adapt to being more of a full-service business partner rather than just a service provider.

The future is bright at State and Federal Communications, and Elizabeth, as always, has her eye on it. The company has begun a five-year transition into becoming an ESOP (Employee Stock Ownership Plan) with Elizabeth once more leading the way.

“I want to make sure I’m taking care of my people. Over the years I have worked hard to help many of my staff to become the future leaders this company needs to not only succeed but thrive. I am very excited to see what the future brings for State and Federal Communications.”

The Delaware General Assembly adjourned for the year on June 30. Lawmakers passed Senate Bill 60, which requires the Public Service Commission to ensure regulated utilities do not use customer funds to subsidize activities such as lobbying and political contributions. The bill would become effective immediately if approved by Gov. Matt Meyer.

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