Lobbyists are required to itemize expenditures made by them or their lobbyist employers for political advertising, public relations, telemarketing, polling or similar activities.

Public relations and polling

The following types of expenditures are among those that are reportable if they are directly or indirectly intended, designed or calculated to influence legislation or rulemaking.

  • expenditures for market research done in-house or through a vendor;
  • expenditures for the development, production, and distribution of advertising to enhance the lobbyist employer's image;
  • an association's expenses to poll the general public or a segment of the general public about a matter that may be the subject of legislation;
  • costs associated with producing press releases, op-ed pieces or other articles designed to sway public opinion about possible tax increases; and
  • costs associated with contacting editorial boards regarding the need for certain statutory changes.

At present, the PDC is relying on the following dictionary definitions:

  • "Public relations" means the method and activities employed in persuading the public to understand and regard favorably a person, business or institution.
  • "Telemarketing" means selling or advertising by telephone
  • "Polling" means asking people for their opinions as part of a general study of what people think about a subject

Report the amount, vendor or person receiving payments and a brief description of the activity:

The cost of materials produced primarily for another purpose but used incidentally as part of the lobbying effort are not reportable. Promotional items such as desk sets, calendars, golf balls and similar gifts, even though promotional in nature, are reportable. The cost of placing an advertisement in a candidate or political committee publication is also reportable.

Expenditures by an association or other organization to communicate with its own members are not reportable.


If your employer sponsors an advertising campaign addressed to the general public (e.g., radio or TV ads, newspaper ads, billboards, inserts in monthly bills) to influence legislation, including an initiative to the legislature, you may disclose these costs on your monthly lobbyist report. No other special reporting by the employer would be necessary so long as the grassroots campaign is funded with existing employer resources.

If, however, the campaign is partially or fully paid for with funds acquired from sources other than the employer, the primary sponsor of the campaign must keep detailed records of all contributions and expenditures and file grassroots lobbying reports. See Grassroots Lobbying .

Lobbyist also must disclose expenditures for political advertising supporting or opposing a state or local office candidate or ballot measure. Political advertising includes any advertising displays, newspaper ads, billboards, signs, brochures, articles, tabloids, flyers, letters, radio or television presentations or other means of mass communication used for the purpose of appealing, directly or indirectly, for votes or for financial or other support in any election campaign.

If a lobbyist or lobbyist employer - alone or in conjunction with others - pays for a direct mail piece supporting a candidate, all of the lobbyist's or employer's costs associated with developing, producing and distributing the political ad must be reported on the lobbyist's monthly report. They should be itemized by amount, identity of the vendor or other person paid, and a brief description.

A monetary contribution from a lobbyist or lobbyist employer to a candidate or political committee that the recipient in turn decides to spend on political advertising is not reportable by the lobbyist as a political advertising expense, but is still reportable as a contribution.

Independent Expenditures

A lobbyist or lobbyist employer who sponsors an electioneering communication or an independent expenditure ad that appears within 21 days of an election must file a C-6 in addition to the lobbyist/lobbyist employer reports. See the Independent Expenditure reporting section for more information.