Regulatory Updates
DOL Issues Final Rule on Labor Organization Annual Financial Reports
Published May 29, 2026
The Department of Labor (DOL) Office of Labor-Management Standards (OLMS) published a final rule to revise forms LM-2, LM-3, and LM-4. Under the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA), labor organizations have certain reporting and disclosure requirements including filing an annual financial report showing total annual receipts, disbursements, assets, and liabilities of the union.
The final rule:
- Creates a longer LM form for the largest labor organizations (Form LM-2 Long Form),
- Revises a slightly shorter form for most labor organizations at and above the $350,000 threshold (Form LM-2),
- Makes a parallel revision to Form LM-3, and updates reporting thresholds for Forms LM-3 and LM-4 to promote financial integrity and transparency.
The final rule applies prospectively under section 208 of the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA).
For union members, the rule:
- Increases transparency by making practical reporting adjustments to reflect the growth and expansion of labor organizations’ financial operations since the passage of the LMRDA. The Office of Labor-Management Standards last substantially revised the Form LM-2 in 2003 and has not updated reporting thresholds for Forms LM-3 and LM-4 since 1992.
- Allows them to stay better informed of their union’s financial conditions and operations by making it easier to see how their union dues are spent. I
- Serves as a deterrent to fraud and embezzlement, and aid in their detection.
The final rule is effective on July 1, 2026. This rule will apply prospectively to labor organizations whose fiscal years begin on or after July 1, 2026.