New Labor Union Reporting Form
Summary of the key rule changes to the LM-2 reporting forms from the Department of Labor’s final rule (RIN 1245–AA10), published as a combined rulemaking finalizing elements of the 2020 and 2025 NPRMs.
1. New Form Created: Form LM-2 Long Form
- A new, more detailed form (Form LM-2 Long Form) is created for the largest labor organizations.
- Filing threshold: Required for labor organizations with $40 million or more in annual receipts (top ~2% of filers).
- It includes 12 additional schedules compared to the prior Form LM-2 for significantly greater granularity in receipts, disbursements, and transactions.
- Applies prospectively to fiscal years beginning on or after July 1, 2026.
2. Revised Form LM-2
- The existing Form LM-2 is revised and now applies to labor organizations with annual receipts of $350,000 to $39,999,999.
- It incorporates many (but not all) of the transparency enhancements from the Long Form while remaining shorter and less burdensome than the Long Form.
- The prior $250,000 threshold for Form LM-2 is raised to $350,000.
3. Updated Filing Thresholds (Inflation Adjustments)
- Form LM-2: Raised to $350,000 (from $250,000).
- Form LM-3 and LM-4 thresholds are also updated for inflation (specific final numbers align with the goal of reducing burden on smaller organizations).
- Itemization threshold for certain aging schedules (Accounts Receivable and Accounts Payable) raised from $5,000 to $7,500.
4. Major Structural and Reporting Enhancements
- Split Schedules for Investments & Fixed Assets (applies to both forms):
- Previous combined Schedule 3 split into new Schedule 3 (Sale of Investments) and Schedule 4 (Sale of Fixed Assets).
- Previous Schedule 4 split into new Schedule 5 (Purchase of Investments) and Schedule 6 (Purchase of Fixed Assets).
- New columns added: Purchaser/Seller name & address and Date of transaction.
- Automobiles must now be identified individually by make, model, and year.
- New Receipt Itemization Schedules (primarily on Long Form):
- New detailed schedules (e.g., Schedules 16–22) for itemizing various receipt categories that were previously reported only in aggregate (e.g., dues, fees, receipts from members for disbursements on their behalf).
- New Schedule 32 — Foreign Transactions (Long Form only):
- Requires reporting of individual transactions or aggregate transactions of $5,000+ with foreign entities or individuals.
- Enhanced Officer & Employee Reporting (Schedules 13 & 14 on both forms):
- New column added for benefits received by officers and employees.
- Greater disclosure required for indirect travel-related disbursements (removal/modification of prior exception for credit card and travel expenses).
- New/ Revised Items:
- New Item 3(d): Checkbox to indicate a trusteeship report.
- New Item 10(b): Disclosure if an officer/employee paid $10,000+ by the reporting organization also received $10,000+ from another labor organization.
- New Item 18(b): Requires reporting the dates of the labor organization’s current constitution and bylaws.
- Revised Item 13: Clarifies that reporting is required if the organization experienced and/or discovered any loss or shortage of funds/assets.
- Parallel Revision to Form LM-3:
- Eliminates the prior distinction between certain direct and indirect disbursements to officers and employees (for consistency with accounting practices).
5. Proposals Considered but Not Adopted (or Modified)
- Elimination of the proposed specific disclosure of strike fund amounts (proposed Item 11(c) was dropped).
- No requirement to report Vehicle Identification Numbers (VINs) for automobiles.
- No requirement to report EINs for every vendor on disbursement schedules (deemed overly burdensome).
- No addition of a whistleblower policy question on the form.
6. Other Key Details
- Effective Date: 30 days after publication in the Federal Register.
- Applicability: Prospective — applies to labor organizations whose fiscal years begin on or after July 1, 2026.
- The changes are intended to improve transparency for union members and the public, particularly regarding the largest labor organizations, while moderating burden on smaller organizations through higher thresholds.
- Electronic filing via the OLMS EFS system remains required (with import functionality supported for the new Long Form).
These changes represent the most significant update to LM-2 reporting since the major revisions in 2003. The Long Form significantly expands disclosure for the biggest unions, while the revised Form LM-2 and threshold adjustments aim to balance transparency with reduced burden for mid-sized and smaller organizations.