Notice: OLMS Final Rule Modernizing Labor Organization Annual Reports

Final Rule: Labor Organization Annual Financial Reports and Filing Thresholds

On June 1, 2026, the Department of Labor and the Office of Labor-Management Standards (OLMS) published a final rule to modernize and improve the Labor-Management (LM) Labor Organization Annual Financial Reports that labor organizations are required to file under the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA). The LMRDA requires that every labor organization file with OLMS an annual financial report showing its total annual receipts, disbursements, assets, and liabilities, with the appropriate form determined by the labor organization's total annual receipts. This final rule establishes a new form, Form LM-2 Long Form, for the largest labor organizations, revises Forms LM-2 and LM-3 in parallel ways, and raises the annual receipts filing thresholds for Form LM-2, LM-3, and LM-4 filers—which have not been adjusted in at least 23 years—to adjust for inflation.

This final rule is the result of two separate proposed rulemakings. In October 2020, OLMS published a Notice of Proposed Rulemaking (NPRM), identified by RIN 1245-AA10, to revise Form LM-2 and introduce a new Form LM-2 Long Form. Subsequently, in July 2025, OLMS published a Notice of Proposed Rulemaking, identified by RIN 1245-AA15, to increase the filing thresholds for Forms LM-2, LM-3, and LM-4. For efficiency, the Department determined to move forward with a joint final rule. The forms, instructions, and thresholds set out in this final rule reflect the Department's review and consideration of the public comments received during the applicable comment periods. 

Form LM-2 Long Form

The final rule establishes a new form, Form LM-2 Long Form, for labor organizations with $40,000,000 or more in annual receipts. The Department estimates that approximately 100 labor organizations will be required to file the Form LM-2 Long Form. This new form has 32 schedules, including a schedule that requires disclosure of foreign transactions, and new itemization requirements that will provide union members and the public with more detailed information about the financial condition and operations of the nation's largest and most financially complex labor organizations.

Form LM-2

The final rule revises the format of Form LM-2—which has not undergone substantial revision since 2003–—most notably by eliminating the requirement to report disbursements to officers and employees by functional category and by breaking out existing schedules for easier understanding and visibility, resulting in a total of 24 schedules. For example, Schedule 3, Sales of Investments and Fixed Assets, has been divided into two schedules—Sales of Investments and Sales of Fixed Assets—to provide more granular detail on certain transactions. Labor organizations with annual receipts between $350,000 and $39,999,999 must file the Form LM-2, an increase from the prior $250,000 threshold.

Form LM-3 and Form LM-4

The final rule revises the Form LM-3 by eliminating a reporting exception for certain disbursements paid to labor organization officers—a parallel change to one made in Form LM-2. In addition, the rule raises the filing thresholds for both Form LM-3 and Form LM-4 filers—neither of which have been updated since 1992. Labor organizations with annual receipts of at least $25,000 and less than $350,000 may file the Form LM-3 instead of Form LM-2, and labor organizations with less than $25,000 in annual receipts may instead file the Form LM-4 instead of the Form LM-2 or Form LM-3.

Effective Date

The final rule will be effective July 1, 2026, 30 days after publication in the Federal Register. However, no labor organization is required to file the new or revised LM forms until 90 days after the conclusion of its first fiscal year that begins on or after July 1, 2026.

As a result, the earliest any labor organization will be required to file a new or revised LM report is after June 30, 2027.

How to File

Filers must submit their LM Labor Organization Annual Financial Report electronically to OLMS through the OLMS Electronic Forms System (EFS). OLMS will make the new and revised LM forms available on the EFS on or before June 30, 2027.

For Further Information

View the Form LM-2 Long Form rulemaking fact sheet, or contact the Office of Labor-Management Standards, U.S. Department of Labor, 200 Constitution Avenue NW, Room N-5609, Washington, DC 20210, by telephone at (202) 693-0123 (this is not a toll-free number), 711 (TTY/TDD), or by email at OLMS-Public.gov. 

Last Updated: 06-01-26