Labor Organization Oversight: Department of Labor Should Enhance Enforcement and Assistance Processes
Fast Facts
Unions negotiate with employers about pay, safety, and policies. The Labor Department's Office of Labor-Management Standards aims to ensure that unions are transparent in their finances and protect the democratic rights of their members. The office audits, investigates, and helps unions comply.
When the office finds a problem—such as a recordkeeping violation that could make union funds vulnerable to theft—it mostly relies on voluntary compliance to fix it and doesn't usually follow up. The office's written communications also don't consistently ensure that the unions have the guidance they need.
We recommended addressing these issues and more.
Highlights
What GAO Found
The Department of Labor undertakes several efforts to enforce the requirements of the Labor-Management Reporting and Disclosure Act (LMRDA), but it could improve its processes to ensure violations are adequately addressed. Each year, the department's Office of Labor-Management Standards (OLMS) selects some labor organizations for audits of their financial reports, based on factors such as member complaints, to ensure financial integrity. Most audits identified reporting and recordkeeping violations, but OLMS's response to addressing them varies. OLMS primarily relies on voluntary compliance—an organization's promise to maintain accurate reports and proper records in the future—to address recordkeeping violations. Some recordkeeping violations could reveal weaknesses that leave labor organizations vulnerable to theft and misuse of funds. However, OLMS has not assessed whether assurances of voluntary compliance result in corrective actions. As a result, OLMS does not know if its focus on voluntary compliance is an effective means to ensure labor organizations are adequately safeguarding members' dues.
Selected OLMS Enforcement and Compliance Assistance Activities
To support compliance, OLMS provides over 50 publications covering all sections of LMRDA requirements, but the agency does not have a mechanism to cite them in audit closing letters when relevant. Specifically, in GAO's review of 172 closing letters—which OLMS uses to summarize violations it identifies and cite available assistance—from 2023, letters did not consistently reference publications that could help labor organizations address recordkeeping violations. For example, 46 closing letters with violations were related to documenting credit card expenses, and none referenced a related publication. According to OLMS officials, investigators determine which publications to reference on a case-by-case basis. However, OLMS does not have a systematic process to help investigators consistently cite related guidance in audit closing letters. This may leave labor organizations unaware of the available resources to address violations and comply with the LMRDA.
Why GAO Did This Study
On behalf of their members, labor organizations negotiate collective bargaining agreements related to pay, safety, and workplace policies. OLMS promotes transparency and financial integrity in labor organizations through its enforcement of LMRDA. In part, this law aims to prevent improper practices by labor organizations and protect the rights and interests of their members. OLMS pursues this goal through audits, investigations, and compliance assistance.
GAO was asked to review how OLMS administers LMRDA provisions that apply to labor organizations. This report examines the extent to which OLMS (1) ensures labor organizations adhere to LMRDA requirements and (2) helps labor organizations comply with LMRDA requirements. GAO reviewed relevant federal laws, annual reports and compliance assistance publications, and all 172 compliance audit closing letters issued in calendar year 2023, the most recent available at the onset of GAO's review. GAO also analyzed fiscal year 2019 to 2023 enforcement and compliance assistance data and interviewed OLMS national and regional officials.
Recommendations
GAO is making seven recommendations, including that OLMS assess voluntary compliance results and establish a mechanism to cite related publications in audit closing letters. The Department of Labor concurred with all seven recommendations. In its comments, the agency outlined its plans to implement them.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of Labor | The Secretary of Labor should ensure the Director of OLMS establishes written criteria investigators can apply when determining whether to require an amended financial disclosure report following a compliance audit. (Recommendation 1) |
OLMS agreed with this recommendation. The agency said it would seek information from the field regarding those instances where investigators request an amended report to identify the justification leading to the requests. OLMS will then evaluate the factors and justification that investigators and managers will consider to help determine when to require an amended report and will place a stronger emphasis on this area during agency training. As of August 2026, the compliance audit team is developing written criteria to include in its procedures. We will continue to monitor progress and will consider closing the recommendation once these changes are approved and included in the agency's audit procedures.
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| Department of Labor | The Secretary of Labor should ensure the Director of OLMS assesses whether voluntary compliance results in labor organizations taking corrective action after violations are identified during a compliance audit. For example, OLMS could regularly follow up on a sample of violations to help estimate how often voluntary compliance results in an actual change of behavior. (Recommendation 2) |
OLMS agreed with this recommendation and worked to develop a method to obtain a representative sample of violations to help estimate how often voluntary compliance results in an actual change in behavior. As of August 2026, OLMS assessed a random sample of audits where a reporting violation was resolved through voluntary compliance. This analysis found that in most cases, voluntary compliance led to corrective actions. OLMS plans to repeat this analysis at regular intervals going forward.
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| Department of Labor | The Secretary of Labor should ensure the Director of OLMS establishes documented procedures to track labor organizations that OLMS officials determine merit follow up based on past violations identified during a compliance audit. (Recommendation 3) |
OLMS agreed with this recommendation. The agency recognizes the importance of establishing a consistent procedure to document when an investigation uncovers a violation warranting follow up action. As of August 2026, the agency is drafting procedures for approval and formalization. We await the completion of these efforts.
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| Department of Labor | The Secretary of Labor should ensure the Director of OLMS develops a mechanism to cite related compliance assistance publications in compliance audit closing letters. (Recommendation 4) |
OLMS agreed with this recommendation. The agency will take steps to revise the training and closing letter language guide to include prompts for documentation and distribution of relevant compliance assistance publications that correspond to violations and other issues found during investigations. The agency believes these changes will help investigators and serve as a reference to union officials and their successors. As of August 2026, the agency has created a mechanism and plans to include it in its closing letter template system. We await the completion of these efforts.
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| Department of Labor | The Secretary of Labor should ensure the Director of OLMS establishes a systematic process to regularly review and update as needed its compliance assistance publications. For example, OLMS could use information on common violations identified in its compliance audits to assess whether there are any gaps in topics covered by its publications. (Recommendation 5) |
OLMS agreed with this recommendation. The agency noted that it established a Compliance Assistance Workgroup that will meet regularly to review available OLMS compliance assistance publications to ensure they are current, relevant and available. As of August 2026, the workgroup is still working to develop a systematic process to regularly update compliance assistance publications to include a review of compliance audit violations and closing letters. We await further progress on these efforts.
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| Department of Labor | The Secretary of Labor should ensure the Director of OLMS establishes a systematic process to collect and track feedback from compliance assistance sessions, ensuring feedback is used for program improvement across all regions. (Recommendation 6) |
OLMS agreed with this recommendation. The agency noted that it created a standardized evaluation form that will ask compliance assistance attendees to provide feedback on the design, presentation and value of the session. OLMS Compliance Assistance Workgroup will then develop a systematic process to ensure feedback collected on evaluation forms is tracked, analyzed and, when appropriate, used to improve OLMS presentations and practices. As of August 2026, the evaluation form has been approved by OMB. We will continue to monitor progress and will consider closing the recommendation once the form is distributed to the agency's district offices for use.
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| Department of Labor | The Secretary of Labor should ensure the Director of OLMS develops a strategy for conducting effective outreach to members of labor organizations. This could include leveraging existing partnerships, such as the Voluntary Compliance Partnership Program, to solicit ideas on improving member engagement or informing members about their rights. (Recommendation 7) |
OLMS agreed with this recommendation and will seek to leverage existing partnerships. Regarding the Voluntary Compliance Partnership, as of August 2026, OLMS has started engaging with its partner unions annually to understand existing practices and solicit ideas on increasing members' awareness of OLMS online resources. In addition, OLMS plans to continue working with other government agencies whose reach to union members is broad and extensive, to increase outreach to union members. OLMS has already attended seminars hosted by other federal agencies to obtain contact with union members and provide information about OLMS. They will continue pairing resources with those agencies to help reach this targeted group. In March 2026, OLMS also made a data visualization tool available for the public to help make reporting data more accessible to members. We will continue to monitor progress and will consider closing the recommendation once OLMS has assessed what methods of member engagement are successful and uses that information to inform an outreach strategy.
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