Revisions to Forms LM-10, 20, 21, and Technical Revision to Form LM-1

On December 12, 2024, the Department and the Office of Labor-Management Standards (OLMS) published a notice of information collection in the Federal Register soliciting public comments on a proposed revision to the Form LM-10 Employer Report, the Form LM-20 Agreement and Activities Report, and the Form LM-21 Receipts and Disbursements Report, as well as their corresponding instructions. These forms, among other things, collect information from employers and labor relations consultants who surveil workers or unions or persuade workers concerning their union organizing rights. The proposed revisions will enhance OLMS’ ability to identify individuals or entities that owe a report but have not filed it. By cross-matching the three sets of reports (Forms LM-10, LM-20, and LM-21), OLMS ensures that each report is accompanied by all required companion filings. This process relies on the identification of responsible parties within the reports. However, because names can be ambiguous, misspelled, or inconsistently reported, incorporating Employer Identification Numbers (EINs) enables OLMS to more accurately determine whether a specific entity has failed to submit a required report. 

The proposed revisions will require:

  • Employers and their labor relations consultants to provide the Employer Identification Number (EIN) of the filer and other parties to the agreement.
  • Employers and their labor relations consultants to provide the email address of other parties to the agreement, which will not be made public on the submitted forms.
  • Primary consultants to specify the independent contractors/sub-consultants who performed the reportable activity.
  • Sub-consultants to specify the primary consultants through which they entered into a reportable agreement.

Additionally, the published notice will update the instructions for the Form LM-1 Labor Organization Information Report by making a technical revision to match the corresponding item on the form.

The employer and consultant reporting requirements stem from the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA), which, in part, establish labor-management transparency through reporting and disclosure requirements for labor organizations and officials, employers, labor relations consultants, and surety companies.  For further information, please see the employer and consultant reporting page.

Submit Comments: The Office of Management and Budget will consider all written comments that the agency receives on or before January 13, 2025.  Written comments and recommendations for the proposed information collection should be sent to www.reginfo.gov/public/do/PRAMain.  Find this information collection by selecting ‘‘Currently under 30-day Review—Open for Public Comments’’ or by using the search function. 

Also, on October 3, 2024, OLMS published a notice of information collection in the Federal Register seeking comment on this proposal, and the comment period closed on December 2, 2024. 

For Further Information: Nora Hernandez by telephone at 202-693-8633, or by email at DOL_PRA_PUBLIC@dol.gov. 

 

 

 

Last Updated: 12-23-24