A new report from LaborLab reveals a significant and widening gap in compliance with the Labor-Management Reporting and Disclosure Act (LMRDA). The report, titled “One-Sided Transparency: The Growing Gap Between Required Annual Union Versus Employer and Persuader Filings and OLMS Compliance Efforts Continues to Widen,” highlights persistent non-compliance among employers and persuader consultants, contrasting sharply with improved reporting by labor unions.
LaborLab’s analysis, which examines 2024 non-filing data as of June 30, 2025, integrates findings from three key government studies: the 2025 Government Accountability Office (GAO) report on union filings, the 2024 Department of Labor’s Inspector General Report, and a 1984 U.S. House of Representatives Subcommittee Report. This triangulation of data provides compelling evidence of a two-tiered system of enforcement.
Key Findings: A Two-Tiered System of Enforcement and Compliance
The report uncovers several critical disparities:
- Improved Union Compliance: The GAO study indicates a 10% improvement in on-time union report filings over a five-year period, alongside a substantial reduction in chronically delinquent reports. This demonstrates the Office of Labor-Management Standards (OLMS)’s effectiveness when it focuses on compliance efforts.
- Abysmal Employer and Persuader Non-Compliance: In stark contrast, data from the Department of Labor’s own Inspector General reveals a consistently dismal on-time filing rate and high non-filing rate for persuader consultants and their engaging employers during the same period. This is particularly alarming given that the number of persuaders is approximately 100 times smaller than the number of union filers.
- Conspicuous Absence of Enforcement: While OLMS has successfully implemented voluntary compliance programs to improve union on-time filing, comparable initiatives for employer and persuader reporting deficiencies have been notably absent. This omission persists despite the significantly smaller population size of employers and persuaders and the reduced resource requirements for enforcement in this area.
- Persistent Deficiencies: The report also highlights the widespread failure to provide essential information, such as Employer Identification Numbers (EINs). This deficiency was noted as far back as the 1984 House Subcommittee report and continues to be an issue, as reiterated by LaborLab’s recent complaints.
“Our latest report clearly shows a two-tiered system of enforcement within the LMRDA,” said Bob Funk, LaborLab Executive Director. “While OLMS has demonstrated its effectiveness in improving union reporting, it has neglected the persistent and widespread non-compliance by employers and persuaders. This creates an uneven playing field and undermines the transparency the LMRDA was designed to guarantee. By failing to ensure transparency from employers and the labor relations industry, the law is once again applied in a way that lets corporations and union-busters off the hook, denying workers their rights, exposing them to coercion and intimidation, and keeping the public in the dark.”
LaborLab’s Recommendations
To address this critical reporting gap, LaborLab urges OLMS to immediately implement the following recommendations:
- Systematic Identification: Initiate a systematic and consistent effort to identify non-filing persuaders and engaging employers through robust crossmatching of existing data, a methodology recommended since 1984.
- Dedicated Resources: Allocate dedicated personnel within OLMS specifically to ensure the timely filing of LM-10 and LM-21 reports.
- Voluntary Compliance Programs: Establish voluntary compliance programs for persuaders and employers, mirroring the successful initiatives used for unions, and integrate benchmark data into OLMS’s annual reports.
LaborLab has consistently shared its crossmatching spreadsheets, methodologies, and deficiency complaints with OLMS and remains committed to providing its expertise to help correct this glaring discrepancy.
About LaborLab: Rooted in educating workers about their organizing rights, LaborLab helps working families build power by ensuring employers and the labor relations industry operate with greater transparency and accountability. Since 2021, LaborLab has monitored and reported on employers and persuader consultants who have failed to file their required annual reports, advocating for consistent and equitable enforcement of the LMRDA.
