How States Are Using AI for Compliance Enforcement in 2026

These days, artificial intelligence (AI) is everywhere. From our social media feeds to our courtrooms, AI seems to be all over the place and the world of lobbying and campaign finance compliance is not immune to its effects. From states beginning to use AI in providing advice and conducting enforcement actions to citizens and watchdogs using it as a tool to review disclosures and flag errors in filings, AI is already here and impacting your compliance efforts.

AI Implementation Insights from the COGEL Conference

In December, MultiState attended the annual Council on Government Ethics Laws (COGEL) conference and spoke with several states that are in the early stages of exploring the use of AI (California, Connecticut, Georgia, and Idaho) or already in the process of implementing an AI program for compliance (Hawaii and Montana). These states have a number of reasons for wanting to use AI in their compliance offices but the commonality among all of them was to increase efficiencies for the regulator and improve access to information for the regulated community (lobbyists and campaign finance entities).

How State Regulators Are Using AI for Compliance Enforcement

The common theme among most states at COGEL was that AI holds a lot of promise in supplementing the work of regulators in providing advice to the regulated community but the feeling among attendees was that AI is still too new to trust it to provide advice to filers. Many states indicated the need to build a closed system that would only synthesize the information provided to it rather than having it search the web for information. Ask an AI tool a question about lobbying compliance in a particular state and you may get the correct information but it’s equally likely that the tool will provide information from other states (or even the federal Lobbying Disclosure Act) making the guidance it provides incorrect.

California and Hawaii Lead Pacific Coast AI Development

California discussed the possibility of building one of the “closed” systems with one of the state universities but indicated that any launch is years in the future. This comes as California’s Secretary of State’s office is set to roll out a new reporting system in mid-to-late 2026. Another Pacific coast state, Hawaii, a state that has had its fair share of lobbying scandals recently, announced that it is using AI for investigations and enforcement actions in the Aloha State.

Connecticut Faces Resource Challenges for AI Implementation

Connecticut indicated that as a small regulator, they are likely to avoid the use of AI for the considerable future even though the state indicated that as a small agency, AI has the power to help the state better regulate filings and provide quicker advice to requestors. This is one of the ironies of AI use by government, an agency like the Fair Political Practices Commission in California is a well-staffed, well-funded agency while the Office of State Ethics in Connecticut is an understaffed agency that could benefit from the use of AI but the office is unable to implement it because of the funds and manpower required.

Montana Emerges as AI Enforcement Leader

Montana stood out at the conference as being the state that has most ardently embraced the use of AI in its enforcement efforts. Montana’s system now provides the regulators a dashboard that utilizes AI to flag filed reports for further review by the Commissioner of Political Practices (COPP). The state has also implemented a chatbot to answer questions and provide citations in its responses, in addition to using AI to write full advisory opinions on behalf of the Commissioner’s office. While the COPP is currently only using AI tools for campaign finance work, the Commissioner indicated that they are hoping to have a lobbyist AI tool available for the 2027 legislative session.

Citizens and Watchdog Groups Deploy AI for Filing Reviews

Another common theme at the conference (and indeed something that MultiState has seen in a number of states via our news tracking) is that non-regulators are using AI tools to review filed reports and file formal complaints with the regulators when the tool indicates that something was filed incorrectly. Of note, this is slightly different from the way Montana and Hawaii are using AI to flag reports. Both states use a “closed” system (or as the COPP referred to it “a glass box”) to ensure that the flags are correct and the tools do not pull in requirements from other jurisdictions. The states also use human eyes to review the flagged reports and then decide whether the filing is out of compliance and worthy of an enforcement action.

Risks and Challenges of Third-Party AI Compliance Reviews

The use of AI by citizens and watchdogs poses numerous risks for both the regulators and the regulated. Regulators from California, Colorado, and Connecticut indicated that they have received complaints from individuals or groups that used AI to review filings and have generally found the reviews to be incorrect and unhelpful (e.g. the AI tool used was referencing other state requirements) and instead of helping to aid in transparency these complaints just take up the regulator’s time. The filer whose report was flagged risks reputational damage and potentially monetary damage if they hire attorneys to fight the complaint.

With the rise of AI use by individuals and others to make formal complaints against filers, it is important to ensure that information is reported correctly and in line with the state requirements since this is one of the ways regulators discover issues with a filing and could be used by competitors to give their competition trouble with the regulators. In some states, once an enforcement action begins by the filing of a formal complaint, the regulator must see it through all the way to a resolution meaning the accused filer could be on the hook for attorney’s fees if the allegations are serious enough.

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