What a lobbying disclosure report (LD-2) contains, and what it leaves out

The law behind it

The Lobbying Disclosure Act of 1995 requires a registrant to file a report on its lobbying activities for each quarterly period beginning in January, April, July and October. Section 1604 of title 2 sets the deadline: no later than 20 days after the end of the quarter, or the next business day if that is not one. A lobbying firm files a separate report for each client. The reports are filed with the Secretary of the Senate and the Clerk of the House, and the House side publishes the guidance and the filing system at the Clerk's lobbying disclosure site.

What an LD-2 contains

According to the statute and the Clerk's guidance, each quarterly report lists:

• The registrant and the client, and any changes to the registration (the LD-1).
• For each general issue area: the specific issues lobbied, including bill numbers and references to specific executive branch actions to the maximum extent practicable.
• The Houses of Congress and federal agencies contacted.
• The lobbyists who acted for the client.
• A description of any interest of a foreign entity in the issues.
• For a lobbying firm, a good faith estimate of income from the client; for an organization lobbying for itself, a good faith estimate of total lobbying expenses.

How amounts are reported

The guidance says the report offers boxes for income or expenses of less than $5,000 and $5,000 or more. At $5,000 or more the filer gives a good faith estimate rounded to the nearest $10,000. Its example is a firm with $5,700 of income that reports $10,000. So the amount on a report is an estimate, rounded, and shown only as "less than $5,000" below that line.

Who has to register

As revised on 28 February 2025, the guidance says an organization employing in-house lobbyists is exempt from registration if its total lobbying expenses do not exceed and are not expected to exceed $16,000 in a quarterly period, and that the income threshold for lobbying firms is $3,500. Registration is due within 45 days of the trigger. A second report, the LD-203, covers contributions and is filed twice a year, by 30 July and 30 January.

The double-counting rule

The most useful detail for reading totals is how in-house and outside spending relate. The guidance says an organization that employs in-house lobbyists and also retains outside firms lists only its own lobbyists. It must report all of its lobbying expenses, including all payments to retained firms, without regard to whether the firm separately reports. Therefore the organization's expense should be greater than the fees the firm reports from it. Adding the company's expense to its firm's income counts the same dollars twice.

OQRO handles this as its methodology describes: a company that lobbies with its own staff reports total expenses that already include its outside firms, so that figure is used as the quarter's total, and outside firms' income is added only when there is no in-house report.

Penalties

For the Act's rules, the guidance says a person who knowingly fails to correct a defective filing within 60 days after notice, or to comply with another provision, may be subject to a civil fine of not more than $200,000, and a person who knowingly and corruptly fails to comply may be imprisoned for not more than five years or fined, or both.

What a report does not show

An LD-2 records that lobbying took place on an issue, not that it influenced anything. A client name can also differ from a company's name: a one-word name must match exactly for OQRO to attach it, so that a different company sharing the first word is not included.

Related

Lobbying is one of the public records OQRO sets next to insider trades, Congress trades and federal contracts. The coverage page lists its sources and refresh rates.