About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline



GAO-26-108486 1 (June 30, 2026)

handle is hein.gao/lbbyn0001 and id is 1 raw text is: 




AO U.S. GOVERNMENT ACCOUNTABILITY OFFICE

441 G St. N.W.
Washington,  DC   20548


June  30, 2026

Congressional   Committees

2025   LOBBYING DISCLOSURE: Observations on Compliance with Requirements

Lobbyists  are paid to influence the public decision-making process.  Over time, questions about
lobbyists' influence have led to calls for more transparency in lobbying activities. To increase
awareness   of these activities, Congress passed  legislation to require lobbyists to publicly
disclose certain activities. The Lobbying Disclosure Act of 1995, as amended   (LDA),  requires
lobbyists to file quarterly lobbying disclosure (LD-2) reports and semiannual contribution (LD-
203) reports.1 Lobbyists are required to disclose lobbying income,  certain criminal convictions,
and  political contributions in these reports, among other requirements. The LDA  includes a
provision for us to annually audit the extent of lobbyists' compliance with requirements under the
act. This 19th annual  review responds  to that statutory provision.

As with our prior reviews, this report (1) determines the extent to which lobbyists demonstrated
compliance  with federal lobbying reporting requirements,  (2) identifies lobbyists' perspectives on
challenges  or potential improvements  to compliance  with quarterly reporting requirements, and
(3) describes the resources  and authorities available to the U.S. Attorney's Office for the District
of Columbia  (USAO)   and efforts the office has made to improve  enforcement.3

To determine  the extent to which lobbyists demonstrated   compliance  with reporting
requirements,  we  analyzed  a stratified random sample  of 101 quarterly lobbying disclosure
reports filed for the third and fourth quarters of calendar year 2024 and the first and second
quarters of calendar year 2025.  We  interviewed each  sampled   lobbyist to (1) confirm key



1Lobbying Disclosure Act of 1995 (LDA), Pub. L. No. 104-65 (1995), 109 State. 691, codified at 2 U.S.C. §§ 1601-
1614; Honest Leadership and Open Government Act of 2007, Pub. L. No. 110-81, 121 Stat. 735 (2007); and Justice
Against Corruption on K Street Act of 2018, Pub. L. No. 115-418, 132 Stat. 5440 (2019). The Justice Against
Corruption on K Street Act of 2018 amended the LDA and requires that lobbyists disclose in their registrations and
quarterly disclosure reports whether individual lobbyists have been convicted of certain criminal acts at the federal or
state level. Committee reports indicate that the LDA was intended to promote transparency and accountability in the
federal lobbying industry. See H. Rpt. 110-161, § 501 (2007); S. Rpt. 115-317 (2018).

22 U.S.C. § 1614. The provision does not require us to identify lobbyist organizations that failed to register and report
in accordance with LDA requirements. The provision also does not require us to determine whether reported lobbying
activity or political contributions represented the full extent of lobbying activities that took place.

3For the purposes of this report, lobbying refers to lobbying at the federal government level. Under the LDA, a
lobbyist is an individual who is employed or retained by a client for financial or other compensation for services that
include more than one lobbying contact, other than an individual whose lobbying activities constitute less than 20
percent of the time engaged in the services provided by such individual to that client over a 3-month period. For ease
of reporting, we also use the term lobbyist to include lobbying firms (including self-employed individuals who are
lobbyists), organizations with in-house lobbyists, or lobbyists' representatives who met with us during our review,
unless noted otherwise.


GAO-26-108486   2025 Lobbying  Disclosure


Page  1