Articles June 15, 2026 3 min read

DOL Overhauls Financial Reporting: What the New Form LM-2 Rules Mean for Your Labor Organization

Labor Unions

Form LM-2 reporting is a key component of how labor organizations demonstrate financial transparency and meet federal compliance requirements. Recent changes from the U.S. Department of Labor (DOL) represent a meaningful shift in reporting expectations, particularly for larger organizations.

The DOL has finalized significant revisions to labor organization financial reporting under the LMRDA, effective for fiscal years beginning on or after July 1, 2026. These changes represent the most substantial update to Form LM-2 in over two decades and introduce a new “LM‑2 Long Form” for large organizations.

What the New Filing Thresholds Mean for Your Organization

The updated filing thresholds reflect a tiered approach based on gross annual receipts, with larger organizations subject to expanded reporting requirements:

$40,000,000+ in gross annual receipts — LM-2 Long Form required

$350,000 to $39,999,999 — Form LM-2 required

$25,000 to $349,999 — May file Form LM-3

Less than $25,000 — May file Form LM-4

These thresholds determine not only which form must be filed, but also the level of detail required in reporting.

How the New LM-2 Rules Increase Reporting Complexity

Beyond the updated thresholds, the DOL has made significant structural and disclosure changes to the existing Form LM-2, including expanded schedules and more detailed reporting requirements.

These changes significantly increase reporting complexity — particularly for larger organizations — and will require enhanced data collection, reporting processes and planning to ensure compliance.

As a result, organizations should begin assessing their current reporting processes and identifying any gaps ahead of the upcoming effective date.

Additional details are available in the DOL’s press release and accompanying fact sheet.

What Organizations Should Do Next

The changes to Form LM-2 represent a meaningful shift in reporting expectations and will require organizations to take a more proactive approach to compliance. As the July 2026 effective date approaches, now is the time to begin preparing. Here’s how:

Assess current reporting processes to determine whether updates are needed

Evaluate data collection practices to ensure the necessary level of detail can be captured

Coordinate across finance and compliance teams to support timely and accurate reporting

Notably, the AFL-CIO has filed a lawsuit challenging this rule, and organizations should closely monitor developments, as the outcome may affect the timing, implementation or final scope of its provisions.

Is Your Organization Ready for the New LM-2 Requirements?

For questions about how you can ensure your organization’s readiness and compliance with the new reporting requirements, reach out to our Labor Unions Services Team.

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