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VideoCourt Denies AFL-CIO Request to Delay New LM-2 Long Form Requirements: What Labor Unions Should Know
Labor organizations subject to the Department of Labor’s (DOL’s) revised reporting requirements should continue moving forward with implementation efforts.
On June 30, 2026, a U.S. District Court denied the American Federation of Labor and Congress of Industrial Organizations’ (AFL-CIO’s) request for preliminary relief seeking to postpone the DOL’s new labor organization reporting requirements. As a result, the DOL’s revised LM-2 reporting framework, including the new LM-2 Long Form for the largest labor organizations, remains effective as scheduled.
What the Court’s Decision Means for Labor Organizations
The litigation stems from the DOL’s final rule requiring large unions to provide more detailed annual financial disclosures. Among the most notable changes is the creation of a new LM-2 Long Form for labor organizations with annual receipts exceeding $40 million. The rule took effect on July 1, 2026, 30 days after publication.
The AFL-CIO challenged the regulation on several grounds, including procedural and constitutional objections. For its emergency motion, the organization focused specifically on the July 1 effective date, arguing that labor organizations were not given sufficient time to prepare for compliance.
Why the Court Allowed the Rule to Move Forward
The court’s opinion did not address the underlying validity of the new reporting requirements. Instead, it focused on whether the AFL-CIO had demonstrated immediate and irreparable harm necessary to justify delaying implementation of the rule while the broader case proceeds. The court concluded that the AFL-CIO did not meet that burden.
A key aspect of the court’s reasoning was the distinction between costs associated with complying with the rule and costs resulting specifically from its July 1 effective date. The court found that expenses related to purchasing new accounting software, updating systems and training personnel would likely be incurred regardless of whether implementation occurred on July 1, 2026, or later. As a result, those costs did not support the request for emergency relief.
The court noted that one potential impact of the rule’s timing could be the need to manually recode transactions entered before compliant software systems are fully operational. However, while acknowledging that this process may create additional work, the court found insufficient evidence that the resulting costs or operational burdens would be substantial enough to constitute irreparable harm.
The opinion also noted that the claimed harms may not occur before the court reaches a final decision on the underlying challenges. The parties agreed to an expedited briefing schedule, indicating that a ruling on the merits could occur well before the first LM-2 Long Form filings are due.
Practical Steps Labor Organizations Should Consider Now
With the rule remaining in effect, labor organizations subject to the new requirements should continue moving forward with their implementation efforts.
Although the first LM-2 Long Form filing will not be due for more than a year, the DOL’s rule applies to fiscal years beginning on or after July 1, 2026. As a result, organizations with fiscal years that began on July 1 must begin capturing transaction-level information to support future reporting obligations.
For many large labor organizations, this will require:
- Determining whether existing accounting systems can capture the transaction-level detail required for LM-2 Long Form reporting
- Modifying chart-of-accounts structures and data capture processes to align with new reporting requirements
- Training finance and accounting personnel on new reporting classifications and documentation requirements
- Assessing internal controls over the collection, validation and reporting of LM-2 Long Form data
Organizations that delay these efforts may face additional operational challenges when preparing future filings, particularly if historical transactions require reclassification, recoding or supplemental documentation.
What to Watch Going Forward
This decision should not be viewed as a definitive endorsement of the new rule. The court expressly stated that it was not ruling on the merits of the AFL-CIO’s broader challenges, including claims relating to the rulemaking process and other legal objections. Those issues remain pending and could ultimately influence the regulation’s future.
Until a court rules otherwise, the DOL’s revised reporting framework remains in effect. Labor organizations that meet the applicable thresholds should continue preparing for compliance while monitoring future developments in the case.
How Weaver Can Help
Preparing for the new LM-2 Long Form reporting requirements may require changes to accounting systems, data collection processes and internal reporting procedures.
Weaver can help assess reporting impacts, evaluate readiness, identify process gaps and develop practical strategies for capturing and reporting the information required under the DOL’s revised framework. As labor organizations continue their compliance efforts, our team can provide guidance to help address reporting challenges and prepare for future filing obligations. Contact our team today.
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