2025 Lobbying Disclosure: Observations on Compliance with Requirements
Fast Facts
To make lobbying the federal government more transparent, paid lobbyists must, among other requirements:
- File quarterly reports on who lobbied and what they did
- File semiannual political contribution reports
As in past years, most registered lobbyists showed us evidence that they followed the above reporting requirements. But we also found discrepancies. For example, 22% of quarterly reports listed lobbyists who didn’t fully disclose their relevant prior federal jobs, as required.
From 2016-2025, Congress referred 12,391 cases to the Department of Justice for failure to file reports. About 46% of these cases were resolved as of December 2025.
Lobbyists walking down the steps of the U.S. Capitol building in Washington DC.
Highlights
What GAO Found
Most lobbyists demonstrated compliance with the requirements of the Lobbying Disclosure Act of 1995, as amended (LDA). For example, for the third and fourth quarters of 2024 and the first and second quarters of 2025, GAO estimates that
- 94 percent of lobbyists who filed quarterly lobbying disclosure (LD-2) reports had documentation confirming income and expenses related to lobbying,
- 84 percent of lobbyists who reported lobbying the Senate had documentation confirming related lobbying activities, and
- 93 percent of semiannual contribution (LD-203) reports included all reportable political contributions.
These findings are generally consistent with GAO’s findings since 2016.
By law, lobbyists are also required to report certain criminal convictions, such as those involving bribery or fraud, among others. None of the 247 individuals listed as lobbyists on the quarterly disclosure reports GAO reviewed appeared to have relevant convictions to disclose, based on analyzing criminal background records. Therefore, GAO did not identify any related reporting violations.
The figure below describes the typical filing and enforcement processes.
Typical Lobbying Disclosure Process
GAO found that most lobbyists reported some level of ease in complying with quarterly reporting requirements and understanding terms, such as lobbying activities, associated with these requirements.
Based on referrals from the Secretary of the Senate and the Clerk of the House of Representatives, the U.S. Attorney’s Office for the District of Columbia (USAO) contacts lobbyists who have not filed their lobbying disclosure and contribution reports. For filing years 2016 through 2025, the office received 12,391 referrals for lobbyists who failed to file these reports. As of December 2025, about 46 percent of these referrals were closed as in compliance after lobbyists filed required reports. To improve compliance, the office takes various enforcement actions, such as emailing or calling lobbyists. GAO found that the number of enforcement actions taken based on referrals, as well as the percentage of referrals brought into compliance, have generally increased in recent years after earlier declines.
Why GAO Did This Study
The LDA requires lobbyists to file LD-2 reports and LD-203 reports, among other requirements. The law includes a provision for GAO to annually audit the extent of lobbyists’ compliance with the act.
This report is GAO’s 19th annual review under the provision and (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 USAO and efforts the office has made to improve enforcement.
GAO reviewed a stratified random sample of 101 LD-2s filed for the third and fourth quarters of calendar year 2024 and the first and second quarters of calendar year 2025. GAO also reviewed a random sample of 160 contribution reports from year-end 2024 and midyear 2025. This methodology allowed GAO to generalize to the population of 71,497 quarterly disclosure reports with $5,000 or more in lobbying activity and 35,735 contribution reports, respectively. In addition, GAO interviewed 95 lobbyists from the sample of quarterly disclosure reports to obtain their views on any compliance challenges or potential improvements to aid compliance. GAO also reviewed referrals data from the USAO and interviewed officials.
GAO provided a draft of this report to the Department of Justice (DOJ) for review. DOJ did not provide comments.
For more information, contact Lisa Van Arsdale at VanarsdaleL@gao.gov.