Federal Election Commission and Lobbying Disclosure Act Report Deadlines Remain Despite the Government Shutdown
Federal Election Commission (FEC) and Lobbying Disclosure Act (LDA) reporting deadlines remain unaffected by the partial government shutdown.
Because Congress was unable to pass an appropriations bill or a continuing resolution at the end of the fiscal year (September 30, 2025), federal agencies were required to discontinue all nonessential discretionary functions until new funding legislation is passed and signed into law. Although a government shutdown has broad and far-reaching consequences, its impact on the reporting obligations of political committees, lobbyists, lobbying firms, and other companies remains modest.
Federal Election Commission Reports
As of October 17, 2025, the FEC is closed due to the government shutdown. According to Commission guidance, the electronic filing system remains operational, but staff support and technical assistance are unavailable to filers and the public. All filing data, including newly submitted electronic reports, should remain accessible,[1] though certain advanced data tools may be limited while the Commission is closed.
Filing deadlines remain in effect during the shutdown. Although the FEC has indicated that it will not pursue routine administrative fines for reports filed within 24 hours after the Commission resumes operations, this should offer little reassurance to late filers. Failure to timely file exposes committees to the risk of third-party FEC complaints, along with the resulting legal expenses, heightened public scrutiny, and potential civil penalties.
Prudent filers should continue to make timely filings throughout October and until the government shutdown is over. Shutdown-related technical obstacles should be documented and filing confirmations should be saved. For committees filing on a monthly schedule, the October monthly reports are due October 20, 2025. Reports for Texas’ 18th congressional district special election and Arizona’s 7th congressional district special election are due October 23, 2025. Additional filing deadlines may be found here.
During the shutdown, filers may continue to submit reports electronically. Paper filings, however, will not be accepted.
Lobbying Disclosure Act Reports
The LDA requires all active registrants to file quarterly activity reports with the clerk of the U.S. House of Representatives and secretary of the U.S. Senate. As of October 17, 2025, these offices have not issued guidance regarding late filings and continue to operate with reduced staffing levels. As such, third quarter reports covering July 1, 2025, through September 30, 2025, are due October 20, 2025.
Our Political Law Group will continue monitoring developments, including from the clerk of the House and secretary of the Senate.
Endnote
[1] For example, the FEC reporting database currently includes hundreds of 2025 October Quarterly Reports filed on or slightly before the recent October 15, 2025, deadline.
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