We do enjoy reporting on union corruption–see those recent Boilermakers convictions. However, we truly don’t like seeing Big Labor taking members’ hard-earned dues money and spending it on luxury goods and travel. So it was welcome news that the Department of Labor, now led by Acting Secretary (and nominee) Keith Sonderling, decided that union financials should meet higher accountability standards. To meet that goal, the DOL issued a final rule requiring the Long LM-2 form for those labor organizations taking in $40 million or more in annual receipts.
The new LM-2 form will feature 32 schedules, up from 24, and strict itemization including more scrutiny of travel costs and the like. Also crucially, the Representational Activities category will contain separate schedules for organizing campaigns and contract administration, so unions can’t simply state vague total amounts without explanation.
Unsurprisingly, the AFL-CIO expressed its displeasure while accusing the DOL of “blindsiding” unions and violating the Administrative Procedures Act by not providing a notice and comment period. A federal judge disagreed.
In the U.S. District Court for D.C., Chief Judge James E. Boasberg declined to issue an injunction and found that the AFL-CIO failed to show “irreparable injury” from this new form. Further, “[a]s Plaintiff concedes, the only injury that the effective date will inflict is the burden of later recoding payments that it enters using its current software.” Boasberg added that a lengthier opinion would be forthcoming.
The DOL’s new Long LM-2 form will be effective on July 1, 2026 with first filings due on June 30, 2027. This is the first substantial LM-2 form revision since 2003. Given that OLMS used LM data to convict 255 individuals for fraud and embezzlement between 2021 and 2025, the rule suggests Sonderling’s DOL won’t be going easy on union financials.
