Compliance Corner: New Jersey 2025 Political-Law Calendar

The Gold Dome.

With the new year comes an opportunity to review and re-set the political-law compliance for campaigns, PACs, lobbyists, non-profits, businesses, and individuals. The following checklist provides a brief overview of upcoming dates on the political-law calendar for 2025.

  1. Candidate ELEC Reporting

New Jersey state and local candidates should continue with their standard ELEC reporting. If 2025 is an election year for a given candidate, including gubernatorial and Assembly candidates, the candidate should report using the pre-election and post-election reporting schedule published by ELEC. Otherwise, candidates are still generally required to report activity on a quarterly basis even if there is no election scheduled for this year for that candidate.

Contributors to candidates must keep in mind that contribution and reporting limits for candidates do not re-set based on the start of a new calendar year. Instead, contribution limits for candidates follow the election calendar. For example, if John Doe already contributed the maximum amount to Candidate Smith for the 2025 primary election in contributions made in 2024 or earlier, Contributor Doe is still maxed out for this candidate until after the June 2025 primary election. Keep in mind that contribution limits have just increased on January 1 based on new inflation adjustments.

  1. PAC and Political Party ELEC Reporting

ELEC-registered PACs and political parties must report their activity from the 4th Quarter of 2024 in the January 2025 quarterly report. This report is due on January 15, 2025.

As opposed to candidates whose contribution limits follow the election periods, PACs and political parties follow a calendar-year reporting period. Therefore, even if an individual had maxed out to a PAC in 2024, that contributor is now starting with a fresh slate for contributions in 2025.

  1. Lobbying Reports

Registered lobbyists in New Jersey actually have two upcoming lobbying reports due to ELEC.

First, the regular quarterly-activity reports for lobbyists for the 4th Quarter of 2024 are due on January 10, 2025.

Second, annual reports that cover in detail all lobbying clients and lobbying receipts for all of 2023 are due on February 17, 2025 (this report, normally due on February 15, is pushed back to the first business day following February 14 for 2025). This annual report must actually be filed by both the lobbyist and the represented client, though in some cases the client can designate its lobbying firm to file on behalf of the client. Many businesses do not recognize that the decision to hire a New Jersey lobbyist gives rise to annual reporting requirements that must be handled by the client directly, so it is important for lobbyists and their clients to communicate about this reporting obligation.

  1. 501(c)(3) and 501(c)(4) IRS and New Jersey Reporting

501(c)(3) charitable organizations and 501(c)(4) social-welfare organizations potentially have multiple annual filings due, with the deadlines dependent on their fiscal years. First, most 501(c)(3)s and 501(c)(4)s must file IRS Form 990 as their annual tax return. This filing is due the 15th day of the 5th month after the close of the tax year, or May 15 for a calendar-year filer. Second, many 501(c)(3)s and 501(c)(4)s are registered with the New Jersey Charities Section, and must file annual renewals through the DCA Charities Portal. The annual renewal is due 6 months after the close of the tax year, or June 30 for a calendar-year filer.

  1. Professional Fundraising Reporting

Under New Jersey law, a professional campaign fundraiser that receives compensation of at least $5,000 per year for fundraising activity must register with ELEC and must file quarterly activity reports. The start of the year is a good opportunity to review compensation records from 2024 and to anticipate 2025 compensation to determine whether registration as a professional campaign fundraiser is required. For fundraisers that are already registered, the activity from the 4th Quarter of 2024 must be reported by January 15, 2025.

  1. Financial Disclosures

Elected officials and other government employees are generally required to file an annual financial disclosure. The specific form and the filing deadline will depend on the level of government. For example, local government officials file their financial disclosures with the Department of Community Affairs and this report is generally due April 30 of each year. In contrast, legislative officials file their report with the Joint Legislative Committee on Ethical Standards and the deadline is generally May 15 of each year.

  1. Form BE Annual Pay-to-Play Disclosure

With the close of 2024, business entities that hold New Jersey government contracts, at the state or local levels, can begin preparations for their annual pay-to-play disclosure. This annual report will include information regarding the business entity’s government contracts and political contributions (made by the business entity and its covered individuals, including owners, officers, and directors) during 2024. This filing is due March 31, 2025, pushed back one day because the usual deadline date (March 30) falls on a Sunday this year.

Compliance Tip: With the start of the new year, there is no better time to ensure that your political-activity compliance is on the right track. Making a clean compliance program and plan a priority in the early part of the year is the key to avoiding headaches during the rest of 2025.

Avi D. Kelin is a founding partner of PEM Law LLP, and chairs the firm’s Political Law and Non-Profit Law practices. He helps businesses, organizations, individuals, and political organizations to influence policy while complying with the law.

This column is for educational and informational purposes only and is not intended and should not be construed as legal advice. It is recommended that readers not rely on this column, but that professional advice be sought for individual matters.

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