Compliance
When and Where is Legislative Testimony Considered Lobbying?
November 11, 2025 | Megan Zeiss
Key Takeaways:
- December brings a relatively quiet period for lobbying disclosure requirements, with reports due in just 13 states, 5 localities, and federal Canada, making it one of the lighter months for compliance obligations.
- However, December marks the start of the busy lobbyist registration renewal season. Registrations expire in 26 states, 41 localities, Puerto Rico, DC, and Ontario, Canada, with most 2026 renewals occurring between December and January.
- Some states like Delaware, Michigan, and Minnesota have durational registrations that remain active indefinitely. Lobbyists no longer active in these states must manually terminate their status to avoid filing disclosure reports in 2026.
- Campaign finance compliance remains active with 18 states plus the FEC and DC having disclosure deadlines in December. Political committees should review their filing schedules and watch for contribution-triggered reporting requirements.
- New York has unique requirements where lobbying any locality triggers state-level registration with COELIG. This applies even if you don't lobby at the state level, helping avoid potential hefty fines for non-compliance.
Lobbying Compliance Deadlines in December 2025
December is a relatively light month when it comes to lobbying disclosure deadlines. Reports are due in 13 states, 5 localities, and at the federal level in Canada. See the map and table below to see all jurisdictions with deadlines in December.
Additionally, Georgia and Louisiana may require you to submit more than one disclosure report this month, depending on the level or branch of government you are registered in (e.g., executive, legislative, judicial, or local). Note that Georgia’s branches, or lobbying types, are slightly different (State, State Agency, State Transportation Board, Vendor, and Local).
U.S. Localities with Disclosure Reports Due in December 2025
*The City of San Jose requires weekly disclosure reporting.
As a reminder, lobbying in a locality can trigger registration and reporting requirements at the state level as well. In states like New York, lobbying any locality or municipality will require a state registration and state bi-monthly disclosure reports, even if you do not lobby at the state level. Make sure if you lobby in New York that you are registered with the New York State Commission on Ethics and Lobbying in Government (COELIG) to avoid hefty fines.
Expiring Registrations in December 2025
Despite a light month for disclosure reports, December kicks off the busy lobbyist registration season. Lobbyist registrations in 26 states, 41 localities, Puerto Rico, the District of Columbia, and Ontario, Canada. Keep in mind that states regulating lobbying by branch may have different registration periods for each branch. Renewals for 2026 will primarily occur between December and January, so it's crucial to closely monitor your jurisdictions to avoid missing any critical deadlines. The maps below highlight the states and Canadian territories with expiring registrations.
Localities and Territories with Expiring Registrations
It is important to note that some states process renewals on a biennial basis and will not require a registration to be filed this year. These states include Arizona, California, Connecticut, Hawaii, Kentucky (Legislative), Montana, New York, Oregon, Pennsylvania, Vermont, West Virginia, and Wisconsin. While a registration renewal may not be due in these states, it is important that registered lobbyists determine if they need to continue to remain registered. Remaining registered will require disclosure reports to be filed as prescribed by the respective state’s lobbying requirements.
Durational Registration
While most states and localities require lobbyists to renew their registrations periodically, some jurisdictions do not. Delaware, Michigan, and Minnesota are exceptions where lobbyist registrations remain in effect indefinitely, meaning you will remain a registered lobbyist unless you formally terminate your status. If you are no longer lobbying in any of these states, you must manually terminate your registration to avoid filing disclosure reports in 2026. Be sure to act quickly—disclosure reports are due mid-January! The good news is that you can re-register in these states at any time throughout the year.
Campaign Finance Deadlines in December 2025
In December, 18 states have campaign finance disclosure deadlines, in addition to the Federal Election Commission (FEC) and the District of Columbia. If a political committee is registered in one of these states and is required to file disclosure reports, they must do so in December. Check out the map below for the states with important deadlines this month.
Political committees should be aware of their filing schedules. Some jurisdictions (Texas, for example) give the option to report monthly or quarterly. Also, be aware that some states require a political committee to report large contributions within a set time frame of receipt. Political committees should review contributions carefully to ensure they do not miss a required contribution- or expenditure-triggered deadline.
Need Compliance Help? Get In Touch!
Keeping up with rules, deadlines, and often confusing requirements is a daunting prospect for teams of all sizes. Let us manage your federal, state, and local registration and reporting responsibilities, or manage your Campaign Finance program. Read more about our Compliance Services here, or get in touch here.
