The federal government thinks union members should know more about where their union dues are spent. Employers will also benefit from transparent union financials.
The Department of Labor (DOL) just announced the most significant overhaul of union financial reporting in more than two decades. If you work on the employer side of labor relations, the detailed data you’ve always wanted to know about the organization across the table is about to become public record.
On June 1, 2026, the Office of Labor Management Standards (OLMS) published a final rule that modernizes Form LM-2 and creates a new Form LM-2 Long Form for labor organizations with $40 million or more in annual receipts. The rule is effective July 1, 2026. First filings aren’t required until after June 30, 2027.
Why this is happening
OLMS last substantially revised Form LM-2 in 2003. Thresholds for Forms LM-3 and LM-4 hadn’t moved since 1992. By fiscal year 2025, three labor organizations reported holding over $1 billion in assets. The fraud record made the reform case more definitive. The UAW-Fiat Chrysler investigation, involving more than $1.5 million in prohibited payments to UAW officials, was part of the explicit record supporting this rule. From October 2020 through September 2025, OLMS used LM reporting data to obtain convictions for 255 individuals for fraud, embezzlement, or other criminal activity involving union funds.
What changes matter most
Spending categories that were previously bundled are now separate. Organizing activity and contract negotiation and administration, previously reported together under Representational Activities, become two distinct schedules. Political activities and lobbying are divided into two: political activity covers candidates, ballot measures, and PAC spending; lobbying covers legislative, executive branch, and regulatory advocacy.
For transactions of $5,000 or more, unions must now identify the buyer or seller, the date, a description of the asset, its value, and the amount paid or received. Compensation reporting is overhauled: travel costs paid directly by the union count as compensation, and health, retirement, and other benefits are given a separate disclosure column. A new schedule covers foreign transactions of $5,000 or more. The strike fund disclosure was proposed but didn’t survive public comment.
The threshold adjustments reflect a compromise. The LM-2 filing threshold was set at $350,000 in the final rule, down from the proposed $450,000, to better balance burden reduction and transparency against historic baselines and inflation. The Duane Morris Labor Blog notes that the Long Form alone has 32 schedules. The revised LM-2 carries 24.
Why unions won’t love this
Unions have long argued that existing disclosures gave members everything they needed. The Department of Labor just disagreed, in 231 pages.
The old Representational Activities category was a comfortable arrangement for union. Organizing campaigns and contract administration were grouped together, making it difficult for members to see how dues were prioritized. Those two functions now get separate schedules. For the first time, a public filing will show whether a union is spending more on signing up new workplaces than on servicing the members already paying dues. That is information some unions would prefer to stay internal.
Compensation reporting is where things get personal. Travel costs paid directly by the union now count as compensation. Benefits get their own column. What union leadership really earns, when you count everything, will be clearer than it has been under any prior version of this form.
The organizations most affected by the Long Form are those with the most resources, the most sophisticated operations, and, historically, the most complex financial arrangements, such as the UAW and SEIU. Legal challenges are possible. Duane Morris notes that large labor unions opposing the rule may file court challenges to seek a stay of its implementation.
Practitioners who understand the new disclosure framework before 2027 will be better positioned to use it when filings land.
Frequently Asked Questions
Does this rule apply to all unions?
No. The new Form LM-2 Long Form applies only to labor organizations with $40 million or more in annual receipts. DOL estimates approximately 100 unions will file it. Smaller organizations file the revised LM-2, LM-3, or LM-4 depending on their receipt threshold.
When do the new filings actually start?
The rule is effective July 1, 2026, but no union is required to file under the new framework until 90 days after the close of its first fiscal year beginning on or after that date. The earliest any filing lands is after June 30, 2027.
Could unions challenge this in court?
Yes. Management-side legal observers have noted that large labor organizations opposing the rule may pursue legal challenges to stay its implementation. Whether any challenge succeeds is an open question. Practitioners should monitor developments but plan on the 2027 filing timeline holding.
