SECOND MEASUREMENT SM-020

A registered lobbyist must file each quarter’s report within 20 days. Of 97,884 reports for 2025, 11,986 went up late, 2,069 more than a month late, and the fine for a knowing violation is up to $200,000

Markovian ProtocolMeasured 2026-10-15; live read 2026-10-21Status: published 2026-10-21; questions sent to the Senate and House 2026-10-21DOI: 10.5281/zenodo.23396299

Every lobbying firm and every organisation with in-house lobbyists files a quarterly report (LD-2) with the Senate and the House, due 20 days after the quarter ends. The public database stamps each report with the time it was posted; on every report we checked, that was the time it was signed. We counted every quarterly and termination report for January 2025 to June 2026 and read the stamp on every late one: 17,972 of 149,237 (12.0%) were late. For 2025, 11,986 of 97,884 were late, by a median of 15 days. Who lobbies for whom is public from the day a lobbyist registers; until the quarterly report is up, what that quarter’s lobbying covered is not: the issues, the agencies, the lobbyists and the money. The law sets a fine of up to $200,000 for a knowing violation.

Look up a firm or client: every late report and the 20 October status, by name: lobbying lookup. For foreign governments’ agents, see the FARA country lookup (SM-024).

Disclosure: Markovian Protocol holds no financial position in any organisation named here, was paid by no one for this work, and showed it to no one before publication. How we work.

Six deadlines, 149,237 reports

Every LD-2 for the quarter: regular reports (Qn), reports of no activity (QnY), and termination reports (nT, nTY), which carry the same deadline; amendments are not counted. Late = posted on or after the day after the deadline, Eastern time. Deadlines from 2 U.S.C. 1604(a), matching the Senate and House filing calendars.⁴ Read from lda.gov on 2026-10-15: regular and no-activity reports from 04:59 UTC, termination reports from 07:25 UTC, the firm totals 07:32 to 08:06 UTC.

The Center for Public Integrity counted late filing in 2005, under the old law, when reports were due every six months and the Senate’s database recorded only the day a form was entered: of “some 183,000” forms filed with the Senate since 1998, “36,000 of them (more than 19 percent) were late, 8,800 by more than three months.” The same article says “the Center counted all forms entered within 90 days of the deadline as ‘on time’”, so its rule and ours differ and the two shares do not compare. The nearest figure we have: 796 of our 149,237 reports (0.5%) went up more than 90 days after the deadline.⁵

How late

Only 16 late reports went up in the first five minutes after midnight, so the line between the deadline day and the next does not decide the count.

The days on which the most late reports were posted.

The firms

A lobbying firm files one report per client per quarter, so a firm that is late for a quarter is late many times. “Of” counts every report the registrant filed for the six quarters, all four types; the per-type counts are in the summary exhibit.

How this ends

The firms close it by filing on time; the table above names the ones with the most to file. The Secretary of the Senate and the Clerk of the House write to registrants who do not file and refer those who do not answer within 60 days to the U.S. Attorney for the District of Columbia, which enforces the Act.² GAO counts 3,566 such referrals for failure to file quarterly reports in 2015–2024: about 36% closed as in compliance, meaning the report was eventually filed, about 63% still pending; and one civil settlement in 2024, a $65,000 penalty and an agreement to “permanently retire from lobbying at the federal level”.³ A report filed late is not a report never filed, and nothing public says whether lateness alone is ever referred. We re-read every deadline the day after.

Our questions to the Secretary of the Senate and the Clerk of the House

1. In every quarter we read, the busiest day for late reports after the first week came 14 to 17 days after the deadline, with 137 to 338 registrants filing on that one day. Do your offices send a notice around then, and what does it say?
2. Is a report filed late, but within 60 days of your notice, ever referred to the U.S. Attorney, or only a report never filed?
3. Would you publish the number of reports filed after each deadline?

Their reply, scored

What we told whom, and when.

What we can’t be sure of

• We take the posted time as the filing time; 40 of 40 sampled reports carried the same signed time. Filing must be electronic; the guidance names one exception, an accommodation under the Americans with Disabilities Act, and such a report could be posted later than it was filed.
• Amendments are not counted, and a report replaced by an amendment keeps its original time.
• Each late report is counted once, as filed. 158 registrant–client–quarter groups have more than one late report, such as two copies posted seconds apart, or a regular report and a termination report for the same client and quarter: 163 reports in all, 0.9% of the late count.
• The registration check covers registrations posted since 1 December 2024.
• Third-quarter 2025 reports fell due on 20 October 2025, during the federal shutdown. The guidance says the Secretary and the Clerk “do not have the authority under the LDA to grant extensions to registrants”, and we found no notice moving the date.²

Run it yourself

python3 lda_census.py results_2026-10-15.json 2025Q1 2025Q2 2025Q3 2025Q4 2026Q1 2026Q2
python3 lda_registrations.py 2024-12-01 registrations_2026-10-15.json
python3 analyze.py results_2026-10-15.json registrations_2026-10-15.json summary_2026-10-15.json --firm-totals
python3 sig_check.py results_2026-10-15.json 40 20261015 signature_vs_posted_sample.json
# back-test of the live read on the previous quarter
python3 lda_pairs.py 2026Q1 Q,QY pairs_2026Q1.json --posted-before 2026-07-21; python3 lda_pairs.py 2026Q1 T,TY pairs_2026Q1_term.json --posted-before 2026-07-21
python3 lda_pairs.py 2026Q2 Q,QY pairs_2026Q2.json --posted-before 2026-10-21; python3 lda_pairs.py 2026Q2 T,TY pairs_2026Q2_term.json --posted-before 2026-10-21; python3 lda_pairs.py 2026Q2 A,AY pairs_2026Q2_amend.json --posted-before 2026-10-21
python3 backtest.py pairs_2026Q1.json 2026-07-21 backtest_2026Q2.json pairs_2026Q2.json pairs_2026Q2_term.json pairs_2026Q2_amend.json --terminated pairs_2026Q1_term.json
# the live read, after the July-September deadline (or recompute it from the exhibits with the second line alone)
python3 lda_pairs.py 2026Q3 Q,QY,T,TY,A,AY pairs_2026Q3.json --posted-before 2026-10-21
python3 live.py pairs_2026Q2.json pairs_2026Q3.json live_2026Q3.json --terminated pairs_2026Q2_term.json

The exhibits are gzipped; gunzip -k them first. Standard library only; the API allows anonymous reads but rate-limits them, so a full run takes about an hour. Scripts and exhibits: sm-020/.

References

1. 2 U.S.C. 1603, 1604 and 1606, saved copies usc-2-1603.html, usc-2-1604.html, usc-2-1606.html.
2. Secretary of the Senate and Clerk of the House, Lobbying Disclosure Act Guidance, last revised 28 February 2025, saved copy ldaguidance.pdf.
3. GAO, 2024 Lobbying Disclosure, GAO-25-107523, saved copy gao-25-107523.html.
4. Secretary of the Senate, filing deadlines, saved copy senate_filing_deadlines.html; Clerk of the House, lobbying disclosure notices, saved copy house_lda_notices.html.
5. M. Asif Ismail, Breaking the law, Center for Public Integrity, 4 April 2005 (archive kept by POGO). publicintegrity.org, saved copy cpi_breaking_the_law_2005.html.

Cite as

@misc{markovian-sm020,
  author = {{Markovian Protocol}},
  title  = {Time from the 2 U.S.C. 1604(a) deadline to posting, every quarterly and termination
            lobbying report (LD-2) for January 2025 to June 2026},
  number = {SM-020},
  year   = {2026},
  month  = oct,
  url    = {https://markovianprotocol.com/measurements/sm-020.html},
  doi    = {10.5281/zenodo.23396299}
}