2026 Legislative Session Dates
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Key Takeaways:

  • Organizations can trigger state lobbying expenditure requirements even without hiring registered lobbyists if they spend money on activities like paid social media campaigns or grassroots consulting to influence legislation or regulations.
  • California requires entities to register as "$5,000 filers" when they spend $5,000 or more in a calendar quarter on lobbying-related expenses, regardless of whether they retain a lobbyist.
  • Massachusetts General Law Chapter 3, Section 44 mandates that organizations report expenditures over $250 used to influence legislation or executive action on semiannual paper filings, a unique requirement among state lobbying reporting systems.
  • Several states including Pennsylvania and New York allow principal lobbying registration without listing individual lobbyists when organizations only incur lobbying expenses rather than employing government affairs professionals.
  • Washington requires organizations to register within 24 hours and file monthly reports if their grassroots lobbying expenses exceed $1,500 in one month or $3,000 in any three-month period during certain legislative timeframes.


Across jurisdictions, lobbying statutes differ in definition and scope, outlining who qualifies as a lobbyist and how to engage with lawmakers. However, a distinct and often overlooked facet of the regulated community includes organizations that incur expenditures to influence government actions without the use of traditional, registered lobbyists or contract firms. A key reason why certain organizations fail to account for these less-than-traditional lobbying cases stems from the perception that lobbying is defined exclusively as direct interactions with officials or employees.

What Triggers Lobbying Disclosure Requirements When No Traditional Lobbyist Is Involved?

But what if an organization does not employ or retain a government affairs professional? Instead, lobbying activity may look like a paid social media campaign against a pending regulation or hiring a grassroots consultant to assist in garnering support for a bill. The expenditures, instead of an individual’s actions, may trigger lobbying disclosures. Under certain jurisdictions, these are categorized as lobbying expenses and they are directly attributable to the organization paying for the services.

In these cases, organizations are required to report appropriate lobbying expenditures to the regulating jurisdiction under a principal account without listing individual lobbyists. It is essential to understand these special cases and reporting nuances to avoid penalties, fines, and potential future disclosure issues.

Which States Require Disclosure of Lobbying Expenditures Without a Registered Lobbyist?

Although not an exhaustive list, the following are states where organizations regularly expend influential payments.

California Lobbying Expenditure Thresholds and Reporting

Some jurisdictions require registration and reporting based on expenditure thresholds, regardless of whether a lobbyist is retained for their services. In California, entities that spend $5,000 or more in a calendar quarter to influence legislative or administrative action may be required to register as a “$5,000 filer”. The $5,000 threshold is calculated on overall lobbying-related expenses, which may include lobbyist compensation, or may solely be attributable to other advocacy-related costs. Organizations that meet this threshold are required to register with the state and submit quarterly reports.

Idaho Grassroots Lobbying Expenditure Reporting

Any one-time expenditure of $100 or more for the purposes of indirect lobbying (grassroots lobbying) made by a lobbyist must be reported within forty-eight (48) hours of the activity.

Massachusetts Organizational Expenditure Reporting Requirements

In Massachusetts, General Law Chapter 3, Section 44 outlines the requirements for organizations that allocate funds over $250 to promote, oppose, or influence legislation, or to influence the decision of any executive action. The law requires these organizations to report expenditures to the state on a semiannual cycle, similar to traditional lobbying reports. Unlike other lobbying reports in the state, these are submitted on paper filings!

Pennsylvania Principal Registration and Expense Reporting

Pennsylvania requires organizations that influence legislative or administrative action and meet the threshold to submit a principal registration. This includes incurring expenses on advertising, non-lobbyist consultants, or office expenses. However, if no employee meets their individual threshold, then only principal registration and reporting is required.

New York Principal Registration for Lobbying Expenses

Similar to the other Northeastern states listed, the Empire State does not require a lobbyist to be listed if the organization is only incurring lobbying expenses. Instead, the principal registration is submitted with the intended lobbying matter and targets, along with the bimonthly reports.

Washington Grassroots Lobbying Registration and Reporting

Organizations making grassroots expenses exceeding $1,500 in a one-month period or $3,000 in any three-month period are required to register with the Public Disclosure Commission and file monthly reports. Registrations must be filed within 24 hours of the initial presentation of the messaging to the public when the threshold is crossed in the 30 days before a legislative session through the end of the session or during a special session. All other times, registrations are due within five days of initial presentation to the public. Monthly reports are due on the 10th of the month following the end of the previous month.

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.

Frequently Asked Questions

Do I need to register as a lobbyist if my organization only pays for advocacy ads and doesn't hire a lobbying firm?

In several states, you may be required to register based on expenditure thresholds alone, even without retaining a registered lobbyist. California, for example, requires registration as a "$5,000 filer" if your organization spends $5,000 or more in a calendar quarter on lobbying-related expenses, including advocacy costs. States like New York, Pennsylvania, and Massachusetts have similar principal registration requirements triggered by spending on activities like advertising, grassroots consulting, or other influence-related expenses.

What are the reporting requirements for grassroots lobbying expenditures in Washington state?

Organizations making grassroots expenses exceeding $1,500 in a one-month period or $3,000 in any three-month period must register with the Public Disclosure Commission and file monthly reports. During the 30 days before a legislative session through the end of the session, registration must be filed within 24 hours of the initial public presentation when the threshold is crossed. At all other times, registrations are due within five days of initial presentation, and monthly reports are due on the 10th of the following month.

Does Massachusetts require electronic filing for lobbying expenditure reports under General Law Chapter 3, Section 44?

No, Massachusetts requires paper filings for expenditure reports under General Law Chapter 3, Section 44. Organizations that allocate funds over $250 to promote, oppose, or influence legislation or executive action must report these expenditures on a semiannual cycle using paper submissions, unlike other lobbying reports in the state.

What is the reporting deadline for grassroots lobbying expenditures in Idaho?

Any one-time expenditure of $100 or more for indirect lobbying (grassroots lobbying) must be reported within forty-eight (48) hours of the activity. This rapid reporting requirement applies to expenditures made by a lobbyist for grassroots lobbying purposes.

Can my organization register as a principal without listing individual lobbyists in Pennsylvania?

Yes, if your organization incurs expenses on advertising, non-lobbyist consultants, or office expenses that meet the threshold for influencing legislative or administrative action, you can submit a principal registration without listing individual lobbyists. This principal-only registration and reporting is required when no employee meets the individual lobbyist threshold but the organization still engages in lobbying activities through expenditures.