October 14, 2026
In the FY 2027 Final Budget passed this year, Part U made some changes to the current Commission on Ethics and Lobbying in Government (COELIG) training and deadlines. This proposed rulemaking is to implement the statutory amendments included in Part U relating to ethics training for lobbyists and clients and the imposition of late fees for failing to complete such training within the required time.
The New York State Commission on Ethics and Lobbying in Government (COELIG) proposed rulemaking to its regulations governing mandatory ethics training for lobbyists and clients was published in the October 14, 2026, New York State Register. To view the full proposed rulemaking, please refer to Page 9 of the New York State Register.
Written comments may be submitted during the 60-day public comment period for this proposed rulemaking, which ends on December 14, 2026.
Comments may be directed to:
Megan Mutolo
Commission on Ethics and Lobbying in Government
540 Broadway
Albany, NY 1220
Telephone: (518) 486-7593
Of particular importance to note, the most significant changes are a reduction in the required training interval from three years to two years, new certification and recordkeeping responsibilities, and the schedule of late fees for noncompliance.
Clients Should Take the Following Actions to Ensure Compliance
- Confirm your organization’s Responsible Party and establish clear responsibility for training certifications and electronic filings. The Responsible Party for an organization is an employee, partner, owner, or officer employed by the organization who has legal authority to bind the lobbyist or client. The Responsible Party does not include an individual whose sole responsibility or authority is to prepare such Statements or Reports for a Lobbyist or Client.
- Confirm which officers, employees, or other individuals are subject to training and ensure that the organization has a process to document and certify compliance. All Lobbyists (Principal Lobbyists and Individual Lobbyists) and all Clients (Contractual Clients and Beneficial Clients) listed on a Statement of Registration must complete the online ethics training course for Lobbyists and Clients, as provided by the Commission.
- Update your compliance calendars to reflect the two-year training cycle and applicable 2027 deadlines.
- Maintain supporting documentation of training completion for at least the required three-year retention period.
- Be aware of the new late-fee structure which creates a financial penalty for failure to complete training promptly and maintain accurate records. Clients should not assume that completing training after a deadline automatically eliminates potential penalties.
Full Summary of the Proposed Changes
1. Ethics Training Required Every Two Years
Beginning with the 2027–2028 biennial registration period, covered lobbyists and clients must satisfy ethics training requirements at least once during each biennial period and no less frequently than every two years. Currently it is a three-year training cycle.
2. Initial Training and Compliance Deadlines
Individuals newly subject to the training requirements generally must complete training within 60 days of their first applicable active lobbying registration. The proposal also establishes rules for individuals returning to lobbying after a lapse in registration.
Individuals whose training would otherwise become overdue on January 1, 2027, or during January 2027, would have until February 1, 2027, to comply.
3. Responsibilities for Lobbying Organizations and Clients
The proposed regulations require:
- All individual lobbyists must complete the required ethics training.
- The designated Responsible Party must report training compliance information through COELIG’s electronic filing system.
- Organizations must maintain individual lobbyist training certifications for three years.
- Responsible Parties must ensure that required training information is accurately reported.
For clients that maintain in-house lobbying operations, these requirements make internal tracking and documentation particularly important.
4. New Late Fees for Noncompliance
The proposal also establishes a graduated late-fee schedule for lobbyists and clients that fail to satisfy applicable training requirements.
Proposed Late-Fee Schedule
| Period of Noncompliance | Proposed Late Fee |
|---|---|
| 1–7 days | No fee |
| 8–14 days | $200 |
| 15–30 days | $375 |
| 31–90 days | $775 |
| 91–180 days | $2,275 |
| 181 days or more | $4,525 |
Under the proposed regulations, completion of the required training alone does not resolve noncompliance if an assessed late fee remains unpaid.
5. Waivers and Reductions of Late Fees
COELIG may waive or reduce late fees under specified circumstances, including serious illness, death, events beyond the individual’s control, or other mitigating factors. A request must be supported by appropriate documentation, including an affidavit.
COELIG may consider prior compliance history and other relevant circumstances. Outstanding late fees of $500 or more may be referred to the New York State Attorney General for collection.
We will continue to keep you updated as the rulemaking process continues.