Department of Labor Rule Changes May Impact Labor Organization Reporting

The U.S. Department of Labor (DOL) continues to review and modernize long-standing reporting requirements for labor organizations. A recent bulletin from the Office of Labor-Management Standards (OLMS) proposes updates aimed at reducing regulatory burdens and aligning with today’s economic and legal standards. These proposed changes could affect financial reporting thresholds and conflict-of-interest disclosures for labor organizations and their officers.

Proposed Revisions to the Filing Thresholds for Forms LM-2, LM-3 and LM-4 and the Definition of “Minor Child” for Form LM-30

On July 1, 2025, OLMS published in the Federal Register two Notices of Proposed Rulemaking (NPRM) under the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA). These notices are part of a deregulatory initiative established by President Trump’s Executive Order 14219, which involves reviewing existing regulations across all federal agencies to identify rules that can reduce regulatory burdens and align requirements with current economic conditions and legal standards.

Increasing the filing thresholds of the Form LM-2, Form LM-3 and Form LM-4 labor organization annual reports

The first NPRM proposes updating the financial reporting thresholds for labor organization annual financial reports to account for inflation. Specifically, it would raise the threshold for filing the Form LM-2 from $250,000 to $450,000 in total annual receipts, allowing labor organizations below this threshold to file the simpler Form LM-3. Similarly, the threshold for filing Form LM-3 would increase from $10,000 to $25,000 in total annual receipts, allowing labor organizations below this threshold to file the even simpler Form LM-4. These thresholds have remained unchanged for over 20 and 30 years, respectively, and this update aims to modernize them.

Updating the definition of “Minor Child” for Form LM-30 Labor Organization Officer and Employee Report

The second NPRM proposes to amend the definition of minor child used in the Form LM-30 Labor Organization Officer and Employee Report. The Form LM-30 requires every officer or employee of a labor organization to make public any actual or likely conflicts between their personal financial interests, as well as that of their spouse and minor child, and their obligations to the union and its members. Under the proposal, minor child would be defined as “an individual under the age of 18,” lowering the age from 21. The purpose of this change is to align this reporting requirement with the age of majority now recognized in almost all U.S. jurisdictions, while preserving the integrity of conflict-of-interest disclosures.

Comment period open through July 31, 2025

OLMS seeks comment on both proposed rules. You can submit public comments on the proposed revisions, identified by RIN 1245-AA15 and RIN 1245-AA16 until July 31, 2025. Those who submit comments, including duplicate comments, should understand and expect that the comment, including any personal information provided, will become a matter of public record. OLMS will post comments without change at www.regulations.gov and include any personal information provided.

These filing requirements stem from section 202 of the LMRDA. For additional information on Form LM-2, Form LM-3, Form LM-4 and Form LM-30 filing requirements, please visit Labor Organization Annual Reports and Labor Organization Officer and Employee Reporting.

How Weaver Can Help

If your labor union or employee benefit plan is impacted by these proposed changes, Weaver can help you assess your current filing obligations and prepare for any future updates. Contact us to discuss how we can support your compliance strategy and help you navigate evolving DOL requirements.

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