The office enforcing lobbying disclosure brought zero cases in 2025
Summary
GAO has audited lobbyist compliance with the Lobbying Disclosure Act every year since 2008. The paperwork has gotten much better: GAO's 2009 review found only 35% of reports fully documented and 16% of political-contribution reports had errors, omissions, or a missing disclosure; by 2025, per-element documentation ran 80-94%, and just 7% of contribution reports were missing a required disclosure -- a narrower version of the same check. But the U.S. Attorney's Office, which alone can bring a civil or criminal case for noncompliance, took zero such actions in 2025 -- and has never once prosecuted anyone under the 2018 law requiring lobbyists to disclose their own criminal convictions.
The paperwork really has gotten better
In 's 2008 sample, lobbyists could produce documentation for every one of the seven elements checked -- income, expenses, entities lobbied, covered positions, and others -- on only about 35% of reports. Nearly two-thirds of reports (65%) were missing support for at least one element. Even income and expenses, the two figures lobbyists had the easiest time documenting, showed a discrepancy against the reported amount in 14% of cases with documentation, leading to estimate that about 6% of all 2008 disclosure reports misreported income or expenses outright.
View data as table
| Fully documented on all 7 elements | 35 |
|---|---|
| Missing documentation for 1+ elements | 65 |
By 2025, 's per-element documentation rates had climbed well above that old composite figure: 94% of reports had support for income or expenses, 87% for issue area codes, 84% for Senate lobbying activity, 82% for House activity, 81% for federal agencies lobbied, and 80% for the individual lobbyists listed. These aren't the same measurement -- 2008's 35% required every element documented at once, while 2025's figures are checked element by element -- but they point the same direction: a compliance culture that has visibly matured since the disclosure law's early years.
View data as table
| Income or expenses | 94 |
|---|---|
| Issue area codes | 87 |
| Lobbied Senate | 84 |
| Lobbied House | 82 |
| Federal agencies lobbied | 81 |
| Individual lobbyists | 80 |
Political-contribution reporting shows a similar direction, on a related but not identically defined check. checks these semiannual LD-203 reports against Federal Election Commission data, and in 2008 found 16% had errors, omissions, or a failure to disclose a required contribution -- a broader category. In 2025, 's narrower check for reports that failed to disclose a required contribution found that in 7% of cases -- and all 14 reports caught with a missing contribution this cycle were amended once flagged them.
View data as table
| 2008 | 16 |
|---|---|
| 2025 | 7 |
But the enforcement apparatus never got tested
In 2008, the story behind the compliance numbers was that USAO's enforcement side barely existed yet. The office was still running lobbying referrals through a general civil-and-criminal litigation system never designed for the job, patched together with manual recordkeeping, staffed by six people working the caseload part time -- a deputy chief, an investigator, a paralegal, a support manager, and two clerks -- plus three attorneys available if needed. A dedicated tracking system, built in response to an earlier recommendation, was still weeks from going live.
Seventeen years later, that tracking system exists and has real volume behind it: as of December 2025, USAO had logged 12,391 referrals for unfiled lobbying reports covering filing years 2016 through 2025, with about 46% closed out once lobbyists came into compliance -- roughly 5,700 cases. USAO's 2025 staffing was a full-time program compliance coordinator plus three part-time paralegal specialists, with attorneys assigned as needed; a dedicated civil investigator position sat vacant after its occupant retired in 2025, with a refill planned for 2026.
What that larger, more organized apparatus produced in 2025 was nothing. USAO officials told they took no civil or criminal enforcement action against any lobbyist that year. And since Congress passed the Justice Against Corruption on K Street Act in 2018 -- requiring lobbyists to disclose their own convictions for offenses like bribery, fraud, or money laundering -- the Department of Justice has never once prosecuted anyone for failing to make that disclosure. 's report doesn't say whether USAO brought cases in other years since 2016; what it documents is that in the one year checked in detail, a mechanism built to escalate beyond notification letters escalated to nothing.
The takeaway
- The paperwork is genuinely better than it was. 's 2009 review found only 35% of 2008 reports fully documented and 16% of contribution reports had errors, omissions, or a missing disclosure; by 2025, per-element documentation ran 80-94%, and just 7% of contribution reports were missing a required disclosure -- a narrower version of the same check.
- None of that improvement was tested by enforcement. USAO took zero civil or criminal actions against lobbyists in 2025, despite a mature tracking system logging 12,391 referrals since 2016.
- The 2018 anti-corruption law has never been used. No one has ever been prosecuted under the JACK Act's requirement that lobbyists disclose their own criminal convictions -- the claim of compliance rests entirely on lobbyists policing themselves.
The 2008-era findings are from -09-487, '2008 Lobbying Disclosure: Observations on Lobbyists' Compliance with Disclosure Requirements' (April 2009), 's second annual audit under the Honest Leadership and Open Government Act, read directly and in full via an archived copy. The current-era findings are from -26-108486, '2025 Lobbying Disclosure: Observations on Compliance with Requirements' (June 2026), 's 19th annual audit, also read directly and in full. Both examine the same statutory compliance-audit system 17 years apart; the earlier report captures the disclosure regime shortly after enforcement tracking began, and the later one captures its current, more mature but still untested state. The two reports measure documentation completeness with different methodologies (composite versus per-element), which is noted where the comparison is drawn.
Sources(2) ▾
- U.S. Government Accountability Office, 2008 Lobbying Disclosure: Observations on Lobbyists' Compliance with Disclosure Requirements (2009-04-01) — -09-487, 's second annual audit under the Honest Leadership and Open Government Act of 2007 (HLOGA) -- the baseline-era facet, documenting how incomplete lobbyist recordkeeping and USAO's brand-new, still-untested enforcement-tracking system were shortly after the modern disclosure regime began. Distinct from doc-gao26-108486 (the 19th annual audit, filed 17 years later), which covers the current-era compliance rates and a mature but still toothless enforcement apparatus. Direct gao.gov fetch of the legacy PDF returned HTTP 403; fetched via an existing Wayback capture. gao.gov · original document
- U.S. Government Accountability Office, 2025 Lobbying Disclosure: Observations on Compliance with Requirements (2026-06-30) — -26-108486, 's 19th annual audit under HLOGA's statutory mandate for to review lobbyist compliance with the Lobbying Disclosure Act -- the current-era facet. Distinct from doc-gao09-487 (the second annual audit, from 2009), which captured the disclosure regime's early, patchier baseline. Direct gao.gov fetch returned HTTP 403; fetched via a Wayback capture requested at read time. gao.gov · original document
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The Lobbying Disclosure Act requires federal lobbyists to file quarterly activity reports and semiannual political-contribution reports, and Congress has directed to audit compliance every year since 2008. Two of those audits, read side by side, tell a story of real improvement on paper and no improvement in enforcement. GAO's second annual review⧉, in April 2009, found a system where only 35% of disclosure reports were fully documented and the U.S. Attorney's Office (USAO) hadn't yet finished building a system to even track referrals. GAO's 19th annual review⧉, released in June 2026, found documentation rates now running 80-94% -- but a USAO that took zero civil or criminal enforcement actions in all of 2025.