Who is Actually Influencing Policy in DC?

Why It Matters

Most registered lobbyists are following the rules, but significant gaps remain in how they disclose their prior government service and lobbying activities. The Government Accountability Office's (GAO) latest annual review of lobbying disclosure compliance reveals a system that largely works, yet fails to capture complete information about who influences federal policy and how they do it.

The stakes are straightforward: lobbying transparency underpins the public's ability to understand who has access to lawmakers and what they're being paid to do. When disclosure rules break down, accountability does as well.

The Big Picture

The GAO has been conducting this review for nearly two decades. This year's examination, the 19th in the series, covered the third and fourth quarters of 2024 and the first and second quarters of 2025, analyzing how well registered lobbyists complied with the Lobbying Disclosure Act of 1995.

The agency sampled 101 quarterly lobbying disclosure reports filed by lobbyists reporting five thousand dollars or more in lobbying activity, pulling from a universe of roughly 71,497 such reports. It also reviewed 160 contribution reports from a population of 35,735. GAO researchers interviewed 95 lobbyists to understand how they approached compliance.

Most registered lobbyists appear to be getting the basics right. 94% of those filing quarterly lobbying disclosure reports had documentation confirming their income and expenses related to lobbying. When it comes to semiannual political contribution reporting, 89% of reports included all reportable contributions.

But the picture becomes murkier when examining specific lobbying activities. Only 84% of lobbyists who reported lobbying the Senate had documentation confirming the related lobbying activities they claimed to have undertaken. This gap suggests that while lobbyists are filing reports, some are not maintaining records that fully support what they've disclosed.

Most registered lobbyists reported finding it relatively straightforward to comply with quarterly reporting requirements and to understand key terms like "lobbying activities." The compliance findings this year are generally consistent with what GAO has documented since 2016, indicating a stable system rather than one in crisis.

The Prior Employment Problem

One significant weak spot stands out: prior federal employment disclosure. The Lobbying Disclosure Act requires registered lobbyists to disclose relevant government jobs they held before becoming lobbyists. This requirement exists to illuminate potential conflicts of interest and revolving-door dynamics between government and the private sector.

22% of the quarterly reports GAO reviewed listed lobbyists who did not fully disclose their relevant prior federal jobs as required by law. That means roughly one in five reports examined contained incomplete information about a lobbyist's government background.

This gap is particularly consequential because prior federal service can signal influence and access. A former Senate staffer lobbying the Senate, for instance, may have relationships and institutional knowledge that give them advantages. The public deserves to know this context.

Enforcement and Referrals

The enforcement side of lobbying disclosure reveals a different pattern. From 2016 through 2025, the U.S. Attorney's Office for the District of Columbia received 12,391 referrals for lobbyists who failed to file required disclosure and contribution reports. That's roughly 1,200 referrals per year on average.

As of December 2025, approximately 46% of those referrals had been closed as "in compliance" after lobbyists filed their required reports. The remaining cases either remain open or were resolved through other means. The number of enforcement actions taken and the percentage of referrals brought into compliance have generally increased in recent years after earlier declines, suggesting the enforcement apparatus is gaining traction.

The Bottom Line

The compliance picture that emerges is one of a system that mostly works but has meaningful leaks. Most lobbyists are filing reports and most are including the information required. Yet the 22% gap in prior employment disclosure, combined with the 16% of Senate lobbying reports lacking documentation of actual activities, indicates that transparency is incomplete.

Federal lobbying requirements exist to let the public see who is trying to influence their government. When disclosure breaks down, even partially, that visibility dims. The GAO's 19-year track record of auditing this system shows both progress and persistent challenges. The question for policymakers is whether the current system's imperfections are acceptable or whether stronger enforcement and clearer rules are needed.

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