The California Fair Political Practices Commission (FPPC) has issued an advisory encouraging people subject to lobbying registration and reporting requirements to continue to make the best efforts to timely file all legally required reports and statements.

However, it may be difficult for some to file statements and reports given the shelter-in-place order and other issues caused by the pandemic.

If circumstances caused by COVID-19 inhibit the filing of a lobbying report or statement, the filer should communicate these issues to the Office of the Secretary of State and document all attempts to file and the issues faced.

While quarterly lobbying reports are filed electronically, the law requires certain other statements be filed on paper with an original signature.

Restrictions imposed to fight the spread of COVID-19 may make the logistics of filing documents on paper with original signatures difficult or even impossible.

To the extent this is the case, people required to file lobbying forms on paper with original signatures are encouraged to make use of digital and electronic options for filing reports to ensure timely filing.

Paper statements with original signatures will need to be filed when feasible.

If a person with lobbying filing requirements makes best efforts to comply with the Political Reform Act’s lobbying registration and reporting rules but is unable to do so due to the COVID-19 pandemic, the FPPC will consider this a strong mitigating factor in determining whether an enforcement action against the person is appropriate.