As we’ve shared over the past several years, the legislature passed local government lobbying changes into law in 2023 as part of their sweeping reforms. Housing First Minnesota and other industry groups opposed this and have spent several years pressing leaders and Campaign Finance Board (CFB) to provide clarity and improvements. In the 2025 session legislators provided needed clarity and improvements to the original law.
These changes better clarify who must register as a lobbyist working with local units of government. While we wait for the CFB’s formal guidance and plain-language handbook, Housing First Minnesota Counsel has provided the following overview for your review. As with any internal compliance, Housing First Minnesota members are advised to seek legal counsel to evaluate specifics relating to this and other regulatory requirements. Finally, Housing First Minnesota will continue its advocacy efforts with legislative and CFB engagement, and we will continue to provide resources as we move ahead.
The updated law now clearly includes work involving local units of government—such as cities, counties, and townships—within the scope of lobbying that may require registration with the Minnesota Campaign Finance and Public Disclosure Board (CFB).
While the CFB is still developing formal guidance—including a plain-language handbook, FAQs, and possible advisory opinions—here’s what builders, developers, and those working closely with public entities need to know now.
Key Interim Recommendations for Builders & Developers
1. Track All Potential Lobbying Activity
- Document meetings, communications, and staff time related to influencing official action at the local level—including zoning, land use, permitting, infrastructure, and tax-increment financing (TIF).
2. Delay Registration If Clearly Under Threshold—but Document Decisions
- Lobbyist registration is triggered when an individual is paid more than $3,000 for lobbying activities. If less than $3,000 of your compensation comes from trying to influence local government, you are not required to register.
- Keep in mind that the $3,000 threshold is cumulative for all projects in any calendar year. Once you hit the $3,000 level, you are a lobbyist for all subsequent projects.
- However, maintain clear internal documentation of that determination, in case interpretations evolve after CFB guidance is issued.
3. When in Doubt, It Does Not Hurt to Register
- Voluntary registration is safe, easy, and signals good-faith compliance.
- There are no penalties for registering unnecessarily, but failing to register when required can result in fines, enforcement action, or reputational harm.
- Once registered, the individual lobbyist is required to file periodic reports and comply with rules related to gifts and campaign contributions.
- The organization paying the lobbyist must also file an annual report.
4. Consider a Main Contact Registration
- Many project team members (engineers, architects, etc.) are not lobbying—they’re answering technical questions. But the person leading efforts to secure approvals, whether a project manager, owner, or consultant, may cross the threshold. Registering that main point of contact is often the safest approach.
- Consider registering this key contact person, even if broader staff involvement seems minimal.
5. Be Aware: Enforcement is Complaint-Based
- The Campaign Finance Board typically responds to complaints, rather than proactively investigating every potential case.
- This makes it especially important to maintain clear internal documentation and adopt a risk-aware, good-faith approach to compliance—even if you’re unsure whether a particular activity crosses the threshold.
6. Monitor the Campaign Finance Board’s Updates
- Visit cfb.mn.gov regularly.
The plain-language handbook and further clarifications (e.g., what constitutes “influencing official action”) are expected mid to late 2025.
Quick Action Checklist
| Step | Action | Status |
| 1 | Track time and expenses spent engaging local government | Ongoing |
| 2 | Register if lobbying > $3,000/year — or if in doubt | Recommended |
| 3 | Document decisions not to register (if applicable) | Ongoing |
| 4 | Prepare draft internal policies & staff training | Now – mark as pending guidance |
| 5 | Monitor Campaign Finance Board website for handbook | Summer/Fall 2025 |
| 6 | Seek legal or advisory opinion if needed | Encouraged for those that engage city governments |
Final Word
“When in doubt, consider registration.”
Voluntary registration offers peace of mind, protects against future risk, and shows a proactive, transparent approach to compliance while the state finalizes its guidance.
If you have any questions, you can reach out to Mark Foster, vice president of legislative & political affairs.
