- within Finance and Banking topic(s)
- within Insurance and Transport topic(s)
On Sept. 25, 2025, the New York State Commission on Ethics and Lobbying in Government (COELIG or Commission) conducted its third annual hearing to review the laws, regulations, and advisory opinions that govern the Commission, state public officials, and lobbyists. In conjunction with this hearing, the Commission released a Comprehensive Review Guiding Questions and Potential Proposals for Public Comment.
The topics that COELIG flagged for consideration are wide ranging, but some proposals deserve closer attention by lobbyists and clients of lobbyists due to the effect that they may have on lobbying compliance obligations, if adopted. COELIG's proposals include:
- Expanding the lobbyist reporting obligations to require
lobbyists to:
- Provide additional details on their lobbying activity, including details of time spent on each bill lobbied, in addition to the subject, and individual(s); or
- Disclose not just what they are lobbying on, but the client's position on that legislative or regulatory proposal.
- Tethering rules regarding lobbying with those pertaining to
campaign finance by either:
- Prohibiting or restricting campaign contributions from lobbyists or clients, or preventing those regulated persons from giving to public officials who they have lobbied; or
- Requiring lobbyists and clients to report their campaign contributions to COELIG.
- This proposal might require an amendment to the Lobbying Act to expand the reporting requirements for lobbyists, and/or a change to the state's campaign finance laws.
- Establishing accomplice liability for Lobbying Act violations.
- This proposal would explicitly prohibit individuals and entities from soliciting, aiding, or importuning others to engage in conduct that violates the state's ethics and lobbying laws.
- Clarifying that violations of Lobbying Regulations constitute
violations of the Lobbying Act that may trigger penalties.
- Currently, the Commission only has authority to assess lobbyists penalties for late filings. This would expand that opportunity to impose penalties for any violations of the lobbying regulations.
- Mandating that lobbyists and clients complete all filings
electronically.
- Due to the wording of the state's Technology Law, the Commission would have to obtain an amendment to the Legislative Law to implement this change.
- Requiring training not just for registered lobbyists and their clients, but also for individuals who prepare lobbying disclosure filings.
- Enhancing the review and audit of lobbying filings.
- Further increase disclosures pertaining to Sources of Funding of lobbying entities.
Oral testimony at the Commission's September hearing was limited, and COELIG's window for submitting written comments will close on Oct. 2. It remains unclear which of these proposals the Commission will actually advance – whether through a legislative agenda or a rule making process, and if any of them will be adopted. Once honed, these changes would still take months or years to adopt and implement, but if they are, it may change how lobbyists and clients manage their New York state reporting obligations.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
