By: Elizabeth Mincer
On May 29, 2026, the U.S. Department of Labor announced a final rule that provides a significant update to labor union financial reporting requirements. Issued by the DOL’s Office of Labor-Management Standards (OLMS), the rule modernizes the Form LM-2 annual financial disclosure report and creates a new enhanced “Form LM-2 Long Form” for the nation’s largest unions. The rule will be effective July 1, 2026, and applies prospectively to labor organizations whose fiscal years begin on or after that date.
The New Form LM-2 Long Form
The centerpiece of the final rule is the creation of a new Form LM-2 Long Form, which will be required for labor organizations with $40 million or more in annual receipts. The DOL estimates that approximately 99 labor organizations will be required to file this enhanced form. The Form LM-2 Long Form includes 32 schedules and substantially expands itemization and disclosure requirements for the largest unions. Among the most notable additions is a new Schedule 32 requiring disclosure of foreign transactions—any individual receipt or disbursement of $5,000 or more involving a foreign entity or individual, or total transactions with a single foreign entity aggregating to $5,000 or more during the reporting period. The Form LM-2 Long Form also adds seven new schedules requiring itemization of receipt categories that were previously reported only as aggregate lump sums, including dues and agency fees, per capita tax, fees and fines, sales of supplies, rents, and receipts on behalf of affiliates.
Key Changes to the Revised Form LM-2 and Other Forms
The revised Form LM-2 now applies to labor organizations with annual receipts between $350,000 and $39,999,999, an increase from the prior $250,000 threshold. The revised form includes 24 schedules and shares many of the structural improvements found in the Long Form. The rule also requires disclosure of subcategories of information previously set forth as combined reporting categories—such as by splitting “Representational Activities” into “Contract Negotiation and Administration” and “Organizing,” and splitting “Political Activities and Lobbying” into separate “Political Activities” and “Lobbying” schedules—so that union members can more easily evaluate their union’s spending priorities.
For smaller labor organizations, the rule raises the Form LM-3 threshold from $10,000 to $25,000, and allows organizations with receipts below $25,000 to file the abbreviated Form LM-4. The DOL estimates that this will significantly reduce the reporting burden on smaller unions.
Transparency and Anti-Corruption Goals
The DOL has justified these changes in the name of transparency. The rule will further empower union members to monitor their organization’s financial affairs and to make informed choices about leadership and direction. It should also serve as a deterrent to fraud and embezzlement and aid in their detection. OLMS Director Elisabeth Messenger stated that the rule “fine tunes reporting requirements for larger labor organizations – many of which report tens of millions of dollars in assets each year – and adjusts thresholds for smaller labor organizations to increase transparency for America’s hardworking union members and ensure reporting requirements keep pace as labor organizations evolve.”
Implementation Timeline
Although the rule’s effective date is July 1, 2026, no labor organization will be required to file the new or revised forms until 90 days after the conclusion of its first fiscal year that begins on or after July 1, 2026. As a result, the earliest any labor organization will be required to file a new or revised LM report is after June 30, 2027. OLMS has stated that the new and revised LM forms will be made available on its Electronic Forms System on or before June 30, 2027. Thus, it will be at least a year before the public can review information provided pursuant to these updated disclosure requirements.
Finally, it is possible that large labor unions opposing this new rule will assert challenges in court to try to stay its implementation. We will continue to follow any related developments.