2026 Updated Labor Organization Annual Financial Reports — DOL Final Rulemaking

Regulatory Topic: Labor Organization Annual Financial Reports

Regulatory Agency: Office of Labor-Management Standards, U.S. Department of Labor

Link to Regulation

Link to Comment Submission

Regulatory Comment Closed on 06/01/2026

Final Rule – Effective July 1, 2026

Summary

On June 1, 2026, the Department of Labor’s Office of Labor-Management Standards (OLMS) issued a Final Rule which updates reporting requirements under the Labor-Management Reporting and Disclosure Act. Under the new requirements, unions will be required to

separately report spending on contract negotiations and administration, organizing activities, political activities, and lobbying efforts, giving members greater visibility into how resources are allocated across core union functions
provide more detailed reporting on major asset transactions, revenue sources, officer and employee compensation, benefits, and certain foreign financial transactions, including transaction-level disclosures that identify the source, purpose, amount, and parties involved.
provide workers with a clearer understanding of how their dues are being used and how union leadership manages the organization’s financial resources.

The rule is intended to enhance transparency into labor organization financial activities for union members and regulators while also adjusting reporting thresholds and requirements to reduce administrative burdens on smaller labor organizations. Importantly, the new rule creates the “LM-2 Long Form” which applies to labor organizations with annual receipts of $40 million or more and represents a significant expansion of financial disclosure requirements beyond the existing LM-2 reporting framework. The Final Rule also increases the filing threshold for the traditional LM-2 form from $250,000 to $350,000 instead of the proposed $450,000 or even some of the commenters’ recommendations of well over $500,000.

OLMS states that the purpose of the new form is to:

Promote transparency;
Improve the ability of union members to monitor union finances;
Enhance OLMS enforcement capabilities;
Prevent circumvention or evasion of reporting requirements; and
Allow electronic reconciliation and analysis of union financial transactions.

The LM-2 Long Form portion of the Final Rule is largely adopted from the framework proposed in DOL’s 2020 Notice of Proposed Rulemaking (NPRM), though several provisions were modified or withdrawn in response to public comments. The increase in the filing threshold was adjusted from DOL’s 2025 Notice of Proposed Rulemaking to $350,000 to “better balance” the burden reduction and transparency, aligning with historic baselines and inflation, than the originally proposed amount of $450,000.

This is the most significant expansion of union financial disclosure requirements in decades for the largest labor organizations. For union members this means greater transaction-level transparency, more detailed compensation reporting, and separation of previously aggregated spending categories such as organizing, lobbying, and political activity.

Why This Matters for American Workers and Businesses

Transparency and accountability are essential to ensuring that American workers have access to meaningful information about how their dues are spent and how labor organizations manage their finances. This rule significantly expands the financial information unions must disclose, providing workers with a more detailed picture of how union funds are raised, spent, and managed. Under the new requirements, unions will be required to separately report spending on contract negotiations and administration, organizing activities, political activities, and lobbying efforts, giving members greater visibility into how resources are allocated across core union functions. The rule also requires more detailed reporting on major asset transactions, revenue sources, officer and employee compensation, benefits, and certain foreign financial transactions, including transaction-level disclosures that identify the source, purpose, amount, and parties involved. Collectively, these changes are intended to provide workers with a clearer understanding of how their dues are being used and how union leadership manages the organization’s financial resources.

Background

In addition to increasing the LM-2 filing threshold from the current $250,000—while reducing the proposed threshold from $450,000 to $350,000 in the final rule—the Department adopted a series of significant reporting reforms designed to provide union members with more detailed financial information. These changes expand disclosure requirements related to union expenditures, revenue sources, compensation, asset transactions, political and lobbying activities, and foreign financial dealings.

Separating Organizing from Contract Administration. The final rule creates separate reporting categories for organizing activities and contract negotiation and administration, which were previously reported together under the broader category of “Representational Activities.” As a result, unions will now separately disclose spending related to collective bargaining and contract enforcement[1] from spending on organizing campaigns and representation drives,[2] providing workers with greater visibility into how resources are allocated between servicing existing members and expanding representation.

Separating Political Activities from Lobbying. The final rule also requires unions to separately report political activities and lobbying expenditures, which were previously combined into a single category. Political activity reporting[3] will include expenditures related to candidates, ballot measures, and PAC activities, while lobbying disclosures[4] will cover legislative, executive branch, and regulatory advocacy, as well as related litigation expenses. This change will provide union members with a clearer understanding of how union funds are allocated between electoral activities and broader government advocacy efforts.

Separating Investment and Fixed Asset Transactions. The final rule requires unions to separately report purchases of investments and fixed assets[5] and sales of investments and fixed assets,[6] rather than combining these transactions into broader categories. By creating distinct reporting lines for investment transactions and fixed asset transactions, the rule is intended to provide a clearer picture of how union assets are acquired, managed, and disposed of, while making it easier to identify unusual transactions and potential conflicts of interest.

Expanding Transaction-Level Asset Reporting. The final rule establishes new reporting schedules requiring detailed disclosures for significant investment and asset transactions.[7] For transactions of $5,000 or more, unions must report information such as the identity of the purchaser or seller, the date of the transaction, a description of the asset, its value, and the amount paid or received. These disclosures are intended to provide greater transparency into major financial transactions and help members better evaluate how union assets are being managed to identify any potential self-dealing or conflicts of interest.

Requiring Itemized Reporting of Major Revenue Sources. The final rule also creates new reporting schedules requiring unions to itemize significant sources of revenue, including dues and agency fees, per capita taxes, fees and assessments, rental income, sales revenue, and certain pass-through receipts.[8] For receipts totaling $5,000 or more from a single source, unions must disclose the source of the funds, the purpose of the payment, the date received, and the amount. This additional reporting will provide workers with greater visibility into where union funds originate and how the organization is financed.

Compensation and Benefits Reporting Reforms. The final rule makes several changes to how unions report compensation and benefits for officers and employees. The Department eliminates the longstanding requirement that personnel allocate their work time across functional categories and instead requires unions to report total compensation through dedicated reporting lines for officers and employees.[9] The rule also expands compensation disclosures by requiring certain travel-related expenses, including airfare, lodging, and other travel costs paid directly by the union or through union credit arrangements, to be included in compensation reporting.[10] In addition, unions must now separately disclose expenditures for health benefits, retirement benefits, and other employee benefits through a dedicated benefits column.[11] Collectively, these changes are intended to provide workers with a more complete and transparent picture of the compensation and benefits received by union personnel.

Foreign Transaction Reporting. The final rule establishes a new reporting schedule dedicated to foreign financial transactions.[12] Under the new requirements, unions must disclose receipts or disbursements of $5,000 or more involving foreign individuals or entities, as well as aggregate transactions totaling $5,000 or more with a foreign source. By creating a centralized reporting mechanism for these activities, the rule is intended to provide union members with greater visibility into the nature and extent of a union’s financial dealings with foreign individuals and organizations.

Strike Fund Disclosure. While the Department originally proposed requiring unions to separately disclose strike fund balances and related financial information, the final rule does not include these requirements. The proposal was withdrawn following the public comment process.[13]

Additional Resources

Comment from the Institute for the American Worker (I4AW): https://www.regulations.gov/comment/LMSO-2025-0034-0228

Washington Post Opinion, More Transparency for the Largest Unions: https://www.washingtonpost.com/opinions/2026/05/29/new-labor-department-rule-will-mean-more-transparency-large-unions/

[7] Schedules 3 through 6

[8] Schedules 16 through 22

[9] Items 70 and 71