New Department of Labor Rule on Union Annual Financial Reports(Labor-Management Forms)

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If your local or state fiscal year begins on or after
July 1, 2026, you are required to file your Labor-
Management (LM) report using the new electronic
forms. The Department of Labor has issued a new
rule that changes the annual financial reports local
and state affiliates file under the Labor- Management
Reporting and Disclosure Act.

The thresholds that determine which form you fi le
have moved, and they are measured on gross annual
receipts.

Form Who Files It Now What Changed
LM-2 (revised) $350,000 to $39,999,999
(up from $250,000)
Adds four new schedules
LM-3 $25,000 to $349,999
(up from $10,000 –
$249,999)
One reporting change
LM-4 Less than $25,000
(up from $10,000)
No changes to the form

LM-2 filers will have functional reporting changes specifically schedules 17 (Contract Negotiation and Administration), Schedule 18 (Organizing), Schedule 19 (Political Activities) and Schedule 20 (Lobbying). Under Officer and Employee Disbursement Changes, Officer and Employee Schedules lose their functional columns. Under Travel and Lodging, the previous form provided exceptions when reporting to Schedules 11 and 12, as it pertains to individual officer’s or employee’s lodging or public transportation costs and what was reported on each individual line on previous schedules. That exception is gone. Retiree members are now reported separately. Schedule 15 will require retired members as a distinct membership category. A/R and A/P Schedules — higher threshold for past-due accounts. There are also several new informational items that treasurers will need to familiarize themselves with. For example, completing the LM-2 for Item 3(d), Item 10(b), Item 13, and Item 19(b) will require the date of the local or state current constitution and bylaws.

LM-3 filers will have one substantive change to the LM -3 form. Travel and Lodging. Similar to the LM- 2 reporting pertaining to what was permissible when reporting individual officer’s or employee’s lodging or public transportation costs and what was reported on each individual line. The changes to this line item will be reflected in Item 24 of Form LM-3.

LM-4 filers will only have the threshold change from under $10,000 to under $25,000.

It is imperative that local and state treasurers begin
preparations now. Review your record keeping and expense
coding. Several changes depend on information
you may not capture today, and the new spending categories
may require you to reconfigure how expenses
are coded. Plan ahead and be sure to attend one of the
virtual training opportunities that will specifically cover
the LM-2 and LM-3 changes. Dates and times of the LM
report presentation will be made available during the
months of September, October, and November. Be sure
to check apwu.org/events to register. ■

Fiduciary Responsibility and Secretary-Treasurer Training

The Secretary-Treasurer’s Department provides virtual fiduciary training for local officers who
are unable to attend fiduciary training during the pre-convention workshops. We recommended
that local and state presidents and treasurers attend at least one Secretary-Treasurer’s Workshop
per year. To schedule virtual Fiduciary Responsibility training, contact Annette August, Executive
Assistant to the Secretary-Treasurer, at 202-842-8528 or email [email protected].

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