Compliance
Even If You Don't Have A Lobbyist, You Might Still Be Lobbying (When Lobbying Expenses Trigger Reporting)
June 29, 2026 | Denisse Girón, Ahmed Zain
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.