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2024 Lobbying Disclosure: Observations on Compliance with Requirements

GAO-25-107523 Published: Apr 01, 2025. Publicly Released: Apr 01, 2025.
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Fast Facts

To make lobbying the federal government more transparent, paid lobbyists and firms must:

Register with Congress

File quarterly reports on who lobbied and what they did

File semiannual reports on political contributions

As in past years, we found that most registered lobbyists filed reports, but some reports were inaccurate. For example, 21% of quarterly reports listed lobbyists who didn't fully disclose their relevant prior federal jobs, as required.

From 2015-2024, Congress referred 3,566 cases to the Department of Justice for failure to file quarterly reports. About 63% of these cases were unresolved as of December 2024.

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Highlights

What GAO Found

Most lobbyists provided documentation for key elements of their disclosure reports to demonstrate compliance with the Lobbying Disclosure Act of 1995, as amended. For the third and fourth quarters of 2023 and the first and second quarters of 2024, GAO estimates that

  • 97 percent of lobbyists who filed new registrations also filed quarterly lobbying disclosure reports as required for the quarter in which they first registered,
  • 93 percent of lobbyists who filed quarterly lobbying disclosure reports provided documentation for lobbying income and expenses, and
  • 95 percent of semiannual contribution reports included all reportable political contributions.

These findings are generally consistent with GAO's findings since 2015.

Lobbyists are required to report certain criminal convictions. GAO found that, of the 258 individual lobbyists in its sample, none failed to report a conviction.

The figure below describes the typical filing and enforcement processes.

Typical Lobbying Disclosure Process

Typical Lobbying Disclosure Process

GAO found that most lobbyists surveyed reported some level of ease in complying with quarterly disclosure requirements and in understanding the definitions of terms used in quarterly lobbying disclosure reports. However, based on GAO's estimates, 21 percent of quarterly lobbying disclosure reports included individual lobbyists who had not properly disclosed covered positions—certain jobs in the executive and legislative branches—as required.

To bring lobbyists into compliance, the U.S. Attorney's Office for the District of Columbia continues to contact lobbyists who have not filed their disclosure reports. From 2015 through 2024, the office received 3,566 referrals from the Secretary of the Senate and the Clerk of the House for failure to file quarterly lobbying disclosure reports. As of December 2024, about 36 percent of these referrals were closed as in compliance, and about 63 percent were pending further action.

Why GAO Did This Study

The Lobbying Disclosure Act of 1995, as amended, requires lobbyists to file quarterly lobbying disclosure reports and semiannual contribution reports, among other requirements. The law includes a provision for GAO to annually audit the extent of lobbyists' compliance with the act.

This report (1) determines the extent to which lobbyists demonstrated compliance with disclosure requirements, (2) identifies challenges or potential improvements to compliance that lobbyists report, and (3) describes the efforts of the U.S. Attorney's Office for the District of Columbia in enforcing compliance. This report is GAO's 18th annual review under the provision.

GAO reviewed a stratified random sample of 100 quarterly lobbying disclosure reports filed for the third and fourth quarters of calendar year 2023 and the first and second quarters of calendar year 2024. GAO also reviewed a random sample of 160 contribution reports from year-end 2023 and midyear 2024. This methodology allowed GAO to generalize to the population of 67,577 quarterly disclosure reports with $5,000 or more in lobbying activity and 35,034 contribution reports. In addition, through a survey, GAO obtained the views of 99 different lobbyists on any challenges or potential improvements to aid compliance. GAO also interviewed U.S. Attorney's Office officials.

GAO provided a draft of this report to the Department of Justice for review. The Department of Justice provided technical comments, which GAO incorporated as appropriate.

For more information, contact Yvonne D. Jones at JonesY@gao.gov.

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Topics

Compliance oversightDatabase management systemsInterest groupsLobbyingLobbying activitiesLobbyistsPolitical contributionsReporting requirementsLegal counselPublic and private partnerships