Recent Change in Labor Management Reporting Rules
On May 29, 2026, the U.S. Department of Labor’s Office of Labor-Management Standards (OLMS) announced a new final rule that updates the financial reporting requirements for labor unions. The rule changes the income thresholds that determine which reporting form a union must file.
Unions with less than $25,000 in annual receipts file the simplest form (LM-4), those between $25,000 and $350,000 file Form LM-3, those with $350,000 or more file the revised Form LM-2, and unions with $40 million or more in annual receipts must now file a new, much more detailed "Long Form" LM-2. These changes take effect for fiscal years beginning on or after July 1, 2026.
The revised Form LM-2, for unions with more than $350,000 in annual receipts, brings several notable changes. Two major reporting simplifications are eliminated: unions can no longer exclude travel expenses that were paid directly by the union or on a union credit card, and officers and employees no longer need to report what percentage of their time was spent on various union activities. On the other hand, some reporting categories have been broken into more detailed parts. For example, "Representational Activities" is now split into separate schedules for Contract Negotiation and Organizing. The previous schedule "Political Activities and Lobbying" is now split into two separate schedules as well. The threshold for itemizing accounts payable and receivable is also raised from $5,000 to $7,500, and unions must now include retired members in their membership count.
The biggest change is the creation of the new Long Form LM-2, which applies to the roughly 104 unions that report $40 million or more in annual receipts. This form expands reporting from the current 20 schedules to 32 schedules, establishing more itemized reporting. Notably, these large unions must now individually itemize benefits paid on behalf of each officer and employee in new Schedules 13 and 14. They must also itemize receipts by specific category including: dues, per capita tax, rents, and fees. The new form also creates a new Schedule 32, requiring disclosure of any financial transactions of $5,000 or more with foreign individuals or foreign entities. Unions subject to the new rules are encouraged to contact their CPA as soon as possible to assess what changes to their recordkeeping and reporting systems will be needed.
On June 11, 2026, the AFL-CIO filed suit against the administration over the new rule, claiming it violates federal law and seeking a preliminary injunction. The court heard the motion for a preliminary injunction on June 29, 2026, but an order is still forthcoming. For now, the new rule remains in effect.
We will continue to keep you updated. For more information, please contact your labor law counsel.
By Isadora Stern, WRR Law Clerk