The Price of Tardiness: New York's Lobbying Late Fees Add Up Fast
By: Joseph T. Burns and Eitan Genger
One thousand three hundred and sixteen. That’s the number of late fees or fines assessed against New York lobbyists and their clients in 2025 for failing to make timely filings of required reports, according to the New York State Commission on Ethics and Lobbying in Government's (“COELIG”) recently released 2025 Annual Report.
These penalties accumulate quickly. Missing a handful of routine filings, such as a Statement of Registration, a Bi-Monthly Report, or a Client Semi-Annual Report, can result in tens of thousands of dollars in late fees in a single year, even where the lobbyist or client simply, and inadvertently, forgot to file.
The math can be unforgiving. The late fee regulation, which went into effect on January 1, 2025, applies separately to each missed filing of a Statement of Registration, Registration Amendment, Bi-Monthly Report, Client Semi-Annual Report, or Disbursement of Public Monies Report. Late fees can reach $2,000 per filing.
Two thousand dollars per filing sounds manageable in isolation, but the regulation does not assess fees in isolation. Lobbyists file Bi-Monthly Reports six times a year. Clients file Client Semi-Annual Reports twice a year. Add a Statement of Registration for the biennial registration period, plus Registration Amendments as engagements change, and a single lobbyist-client relationship can generate nine or more separate filings in a calendar year. Each one is assessed independently. There is no aggregate cap, and no volume discount for falling behind across multiple filings.
Run a single-lobbyist, single-client engagement through the schedule with every filing after some busy months, and the exposure is six Bi-Monthly Reports at $2,000 each ($12,000), two Client Semi-Annual Reports at $2,000 each ($4,000), and one Statement of Registration at $2,000 ($2,000), for a total of $18,000 in late fees for one client in one year. None of this reflects any substantive penalty for the underlying conduct. It is simply the price of tardiness. Moreover, Legislative Law § 1-o does treat a knowing and willful failure to file, or the knowing and willful filing of false information, as criminal offense.
Financial exposure is only part of the cost. Late filings, audit findings, and enforcement actions before the Commission are public. COELIG publishes lobbying data on its website, releases bi-monthly compilations of that data six times a year, and devotes a section of its Annual Report to summarizing late fee assessments and identifying entities with significant reporting discrepancies. The same transparency tools the Commission uses to inform the public also make missed deadlines and reporting failures readily visible to journalists, advocacy organizations, opposing counsel, and the entity’s own clients and prospective clients. For a lobbying firm, in-house government affairs team, or trade association whose value to clients depends on a reputation for competence and discretion, a public record of repeated late filings, audit findings, or enforcement settlements undermines this reputation.
Avoiding late fees from the Commission is not a simple compliance task. Layering in the substantive requirements of what each filing must disclose only adds to the complexity. An attorney with substantive expertise in COELIG compliance can help filers develop systems to manage timely, accurate filings, maintain good relations with the regulator, and avoid any unwanted public scrutiny.
Savvy entities who are required to make filings with COELIG would be wise to consult with competent legal counsel before problems arise.
