Proposed Extension of Information Collection; Labor Organization and Auxiliary Reports

On July 1, 2025, the Department of Labor and the Office of Labor-Management Standards (OLMS) proposed a revision to the Form LM-2, Form LM-3, and Form LM-4 Labor Organization Annual Reports. The Labor-Management Reporting and Disclosure Act of 1959 (LMRDA) requires certain reporting and disclosure requirements for labor organizations, their officers and employees, employers, labor relations consultants, and surety companies. Under the LMRDA, every labor organization must file with OLMS an annual financial report showing total annual receipts, disbursements, assets, and liabilities of the union. There are currently three forms for this purpose—Forms LM-2, LM-3, and LM-4—with the form required determined by total annual receipts. Under current regulations, labor organizations (not in trusteeship) with $250,000 or more in annual receipts must file Form LM-2; those with less than $250,000 may choose to file Form LM-3; and those with less than $10,000 may choose to file Form LM-4. These thresholds have remained unchanged for over 20 and 30 years, respectively.

OLMS proposed to increase each filing threshold to higher values: labor organizations with $450,000 or more in annual receipts must file Form LM-2; those with less than $450,000 may choose to file Form LM-3; and those with less than $25,000 may choose to file Form LM-4. These increases are necessary to reflect economic changes and reduce unnecessary reporting burdens on labor organizations whose total receipts, prior to adjusting for inflation, should not necessitate greater filing requirements. By increasing the filing thresholds in a manner proportionate to inflation, this proposed rule ensures that only those unions whose total receipts have kept pace with inflation remain subject to the most detailed reporting requirements.

The public comment period for the proposed revision, identified by RIN 1245-AA15, closed on July 31, 2025. OLMS is currently reviewing comments received. Additionally, in compliance with the Paperwork Reduction Act of 1995 (PRA), OLMS is soliciting public comments regarding the proposal to amend the currently approved information collection request under OMB Control Number 1245-0003, specifically its proposal to revise the filing thresholds for the Form LM-2, Form LM-3, and Form LM-4 Labor Organization Annual Reports required under Section 201 of the LMRDA. You can submit public comments on the proposed extension of information collection until October 24, 2025, at regulations.gov.

For additional information on Form LM-2, Form LM-3, and Form LM-4 filing requirements, please see the Labor Organization Annual Reports page.

For further information, please contact OLMS at olms-public@dol.gov.

 

 

Last Updated:9-04-25