A company must register under the federal Lobbying Disclosure Act when it employs a lobbyist and its lobbying expenses exceed $16,000 in a quarter. An outside firm must register for a client when its income from that client exceeds $3,500 in a quarter. These thresholds took effect January 1, 2025, according to the Senate's Public Disclosure website.
What is the difference between public affairs and lobbying?
Public affairs is the broader communications work of managing a company's relationship with government, regulators and the public, and lobbying is the narrower activity the Lobbying Disclosure Act (LDA) defines and requires to be disclosed. A company can do a great deal of public affairs work, such as monitoring bills, briefing executives and publishing policy commentary, and still fall below the registration line. Counsel has to decide where that line sits.
State and Federal Communications, a research firm for government relations professionals, summarizes one part of the test. An individual counts as a lobbyist for a client when the person makes more than one lobbying contact and spends at least 20% of the time on services for that client over any three-month period.
What are the federal lobbying registration thresholds?
The federal thresholds are $3,500 a quarter in income from a client for a lobbying firm and $16,000 a quarter in expenses for an organization with in-house lobbyists. The Senate's Public Disclosure website says a firm is not required to register for a client when its income for lobbying activities does not exceed and is not expected to exceed $3,500 in the quarter. An organization with in-house lobbyists is exempt when its lobbying expenses do not exceed and are not expected to exceed $16,000 in the quarter.
| Filer | Threshold per quarter since January 1, 2025 | Previous level |
|---|---|---|
| Lobbying firm | $3,500 in income from a client | $3,000 |
| Organization with in-house lobbyists | $16,000 in lobbying expenses | $14,000 |
Source: Senate Public Disclosure website and State and Federal Communications.
The Senate's site says the amounts are adjusted every four years for changes in the Consumer Price Index, and the next adjustment comes on January 1, 2029. Inside Political Law reported that the firm threshold had not been raised since 2013 before this change.
How large is federal lobbying, and why should communications teams care?
Federal lobbying spending reached a record in 2025, which means more companies are filing and more reporters are reading the filings. The Hill reported on May 4, 2026 that Bloomberg Government put 2025 federal lobbying spending at about $5.3 billion, and that OpenSecrets put it above $5 billion for the first time. The same report from The Hill cited a LegiStorm analysis finding that outside lobbying firms took in $2.76 billion in 2025, more than the $2.46 billion spent by in-house corporate government affairs operations, for the first time on record.
Under the LDA, registrants report their activity quarterly to the Clerk of the House and the Secretary of the Senate, as the House's Lobbying Disclosure Act guidance describes. A company's policy positions therefore become public record, and a press release, a policy op-ed and a quarterly filing now sit side by side.
Everything-PR tracks the largest filers in its lists of the biggest lobbying firms by revenue and the biggest lobbying groups in the US. A mismatch between what a company says publicly and what it files is a story a reporter can write from those records. Everything-PR is published by a company owned by a shared interest group that includes me.
What should a communications team do before the first lobbying contact?
A communications team should count contacts, know the thresholds and align the public message before the first lobbying contact. Five steps put that into practice.
- List every employee and agency that contacts government officials about legislation or regulation, and log the date, official and topic of each contact, so counsel can test the contact and 20% time thresholds.
- Ask counsel whether an outside public affairs or PR firm's work for you could make it a lobbying firm, since a firm registers for a client when its income passes $3,500 in a quarter.
- Compare press releases, op-eds and testimony against the issues the company plans to report, so the public story and the filing match.
- Check state and local rules separately, because the federal thresholds do not govern state registration.
- Ask ChatGPT, Gemini and Google's AI Overviews what the company's policy position is, then compare the answers with the filings. The GEO agency guide explains what to look for.
Executives who testify or meet officials need preparation too, and the executive communications guide covers voice and visibility. Companies building a government relations program can review 5W's public affairs and government relations practice. Ronn Torossian is the founder and chairman of 5W. The crisis communications hub covers what happens when a policy fight becomes a reputation fight, and the guide to choosing a PR firm lists questions for any agency.
The through-line is that public affairs becomes lobbying on a measurable line. Count the contacts, know the thresholds and make sure the public story matches the filing.
Frequently asked questions
When must a company register as a lobbyist?
A company must register under the federal Lobbying Disclosure Act when it employs a lobbyist and its lobbying expenses exceed $16,000 in a quarter. An outside firm must register for a client when its income from that client exceeds $3,500 in a quarter, according to the Senate's Public Disclosure website.
What is the difference between public affairs and lobbying?
Public affairs is the broader work of managing a company's relationship with government and the public, while lobbying is the narrower activity the LDA defines and requires to be disclosed. Counsel has to decide where a given activity falls.
How much was spent on federal lobbying in 2025?
Bloomberg Government put 2025 federal lobbying spending at about $5.3 billion, and OpenSecrets put it above $5 billion for the first time, according to The Hill. Outside firms took in $2.76 billion, more than the $2.46 billion spent in-house, per a LegiStorm analysis.
Do state lobbying rules differ from federal rules?
State registration is governed separately from the federal Lobbying Disclosure Act, so a company should check each state where it communicates with officials. Counsel should confirm the thresholds and filing duties for every jurisdiction.
By Ronn Torossian. Updated on Oct 21, 2026. This guide is general communications information, not legal advice. Counsel should decide whether a company's activity requires registration.