We are an eMembership publication, and we build union management software, so we know our own platform best. This guide is written to be useful whether or not you ever look at ours. Every regulatory statement below is sourced to the Department of Labor, and the software section is confined to one clearly marked part near the end.

What the LM forms are

The Labor-Management Reporting and Disclosure Act of 1959 requires every labor organization covered by the LMRDA, the Civil Service Reform Act, or the Foreign Service Act to file an annual financial report showing its receipts, disbursements, assets, and liabilities. Coverage extends to labor organizations representing employees in private industry, employees of the U.S. Postal Service, and most federal government employees. Labor organizations that include or represent only state, county, or municipal government employees are not covered and are not required to file.

Which form you file depends on one number: total annual receipts. That term means all financial receipts during the fiscal year regardless of source, including special funds such as strike funds, vacation funds, and scholarship funds, even when those sit outside the general treasury.

The reports are public. Filed reports can be viewed and downloaded at unionreports.gov. Your members read them. So do employers across the table from you, journalists, and researchers.

All of the LM annual reports must be filed electronically through the OLMS Electronic Forms System. Paper filing exists only as a temporary hardship exemption, and an electronic copy still has to follow within ten business days of the due date.

What changed in the 2026 OLMS final rule

On June 1, 2026, the Department of Labor and OLMS published a final rule modernizing labor organization annual financial reports, with a correction notice following on June 11, 2026. The rule creates a new Form LM-2 Long Form for the largest labor organizations, revises Forms LM-2 and LM-3, and raises the annual receipts filing thresholds, which had not been adjusted in at least 23 years.

Four changes matter operationally, and one date governs when they bite.

The thresholds moved up. Labor organizations with annual receipts between $350,000 and $39,999,999 file the Form LM-2, up from the prior $250,000 threshold. Labor organizations with at least $25,000 and less than $350,000 in annual receipts may file the Form LM-3 instead. Labor organizations under $25,000 may file the Form LM-4. A local that has been filing the long LM-2 on receipts of, say, $300,000 moves down to the simpler LM-3.

A new top tier exists. The Form LM-2 Long Form applies to labor organizations with $40,000,000 or more in annual receipts. The Department estimates roughly 100 labor organizations will file it. The Long Form carries 32 schedules, including a schedule requiring disclosure of foreign transactions, along with new itemization requirements.

Officer and employee time allocation is gone from the LM-2. The revised Form LM-2 eliminates the requirement to report disbursements to officers and employees by functional category, and breaks out existing schedules for easier understanding, resulting in 24 schedules total. That removes the time-allocation recordkeeping that sat behind the officer and employee schedules on the prior form. Schedules 13 and 14 now capture gross salary, allowances, disbursements for official business, and other disbursements, with no percentage split across functional categories.

Functional categorization of everything else expanded. Every disbursement not reported elsewhere on Statement B has to be allocated across eight functional schedules, with benefits reported separately:

• Contract Negotiation and Administration
• Organizing
• Political Activities
• Lobbying
• Contributions, Gifts, and Grants
• General Overhead
• Union Administration
• Benefits

Organizing and Lobbying now stand as their own schedules instead of sitting inside broader categories. A local that has been coding to the old groupings will have to split them. OLMS will assign the final schedule numbers when it publishes the revised Form LM-2.

When it applies. The rule took effect July 1, 2026, but no labor organization has to file the new or revised forms until 90 days after the conclusion of its first fiscal year beginning on or after July 1, 2026. The earliest required filing on a new or revised form is after June 30, 2027, and OLMS will make the forms available on the Electronic Forms System on or before June 30, 2027.

For a calendar-year local, the first filing on a revised form covers fiscal 2027 and comes due in early 2028. Every transaction being coded today still reports on the current form. Locals that settle their category scheme before fiscal 2027 opens will not have to re-code a year of history to match the new schedules.

Where LM filing actually breaks

Ask a secretary-treasurer what makes the LM report painful and you rarely hear "the form is confusing." You hear that the answers live in too many places.

The LM-2 asks for a member count by category, and the categories are ones your union defines. Schedule 15 requires you to list each membership category you track, define it, report the number in each, report retiree members whether or not you track that category internally, report agency fee payers separately, and indicate for each category whether it is generally eligible to vote in union elections. That is a membership database question. Nothing in your general ledger answers it.

The same form asks for your regular dues rates, working dues in addition to regular dues with the basis for payment, initiation fees, transfer fees, and work permit fees, entered as a minimum and maximum where more than one rate applies. That is a contract and dues configuration question.

It asks for the date of the labor organization's next regular election of general officers, and whether the constitution and bylaws changed during the period, in which case a dated copy has to be filed as an electronic attachment.

Then it asks for receipts and disbursements down to named-payee itemization, which is a general ledger question.

The seam between those two halves is where filing goes wrong. Dues receipts are calculated in the membership system and posted in the accounting system. Agency fee payers are a status in the membership record and a receipt line on the form. Per capita tax owed to your international is a function of member counts and a disbursement line. When the two systems disagree, someone spends the filing window reconciling them by hand, and the disagreement is usually about which category something belongs to.

The Department publishes its own estimate of what this costs. The public reporting burden notice printed on the revised Form LM-2 puts it at an average of 343.1 hours per response, with an additional 88 hours estimated for filers that have subsidiary organizations. Read that carefully. It is a regulatory burden estimate covering the whole cycle of reviewing instructions, searching existing data sources, gathering and maintaining the data, and completing and reviewing the report. It is not a measured average of what any particular local spends. But 343 hours is roughly two months of one person's full-time work, and the Department arrived at that figure by assuming a filer has to go find the data. Every hour of it is a searching-and-gathering hour that better records will remove.

The LM data map: which system owns which answer

Before evaluating any software, it helps to know which half of the form you are actually trying to fix. This table maps the major LM-2 items to the system that ordinarily holds the source data. Item numbers reference the revised 2026 Form LM-2.

Read down the right column. Only two of the thirteen rows are purely a general ledger question, and a third is payroll. Everything else touches membership records, dues configuration, or governance documents. This is the part of LM compliance that gets least attention during a software evaluation, because most unions frame the annual report as a finance problem and hand the whole question to the bookkeeper or the outside accountant.

The LM Filing Readiness Ladder

Union size predicts filing difficulty very poorly. A small local without clean coding can spend longer on the report than a much larger one that codes as it goes. The variable that does predict difficulty is what we call categorization distance: the elapsed time between an event happening and the moment someone decides which LM category that event belongs to.

A disbursement classified as Organizing on the day the check is cut has a categorization distance of zero. The same disbursement classified the following February, from a bank statement line reading "check 4471," has a categorization distance of more than a year, and the person doing the classifying is guessing.

Four rungs describe where a union sits.

Rung 1. Reconstructed

Filing data is assembled after the fiscal year closes, from bank statements, check registers, spreadsheets, and institutional memory. Member counts are estimated or pulled from a roster that was never designed to answer the question. Categorization distance runs to a full year or more. The filing becomes a project with its own start date. The signature risk is real here, because the president and treasurer are personally responsible for the report's filing and accuracy, and they are signing conclusions somebody else reconstructed after the fact.

Diagnostic: If the report were due in ten days instead of ninety, could you file it?

Rung 2. Recorded

Transactions are entered into an accounting system as they happen, and member records are maintained in a database. But neither system carries the LM-specific dimensions. Disbursements are coded to internal expense accounts that do not map cleanly to the eight functional schedules. Membership statuses exist but were never tied to the categories Schedule 15 will ask about. The raw material is better. The categorization still happens during the filing window.

Diagnostic: Can you produce a list of every disbursement of $5,000 or more to a single payee for the year, by function, without opening a spreadsheet?

Rung 3. Coded

The LM-relevant dimensions are captured at the moment of the event. Functional category is assigned when the disbursement is entered. Payee identity is captured well enough to support named-payee itemization. Membership categories carry their retiree and agency fee payer distinctions and their voter eligibility flag as attributes of the record, not as a note someone wrote down. Categorization distance approaches zero. Filing becomes extraction.

Diagnostic: When a member moves from active to retiree, does one action update both the dues assessment and the count that will appear on Schedule 15?

Rung 4. Traceable

Everything at Rung 3, plus a change history on the values themselves. When OLMS, an auditor, a parent body, or a member asks why a number is what it is, the answer comes from pulling the record rather than rebuilding the reasoning. This is where the five-year retention obligation stops being a filing-cabinet problem and becomes a property of the system.

Diagnostic: If a member disputed their good-standing status as of a date three years ago, could you show who changed it, when, and what it was before?

The rung that matters is the move from 2 to 3, and it starts as a policy decision rather than a purchase. Deciding that every disbursement gets its functional category at entry, and that every status change carries its Schedule 15 implication, can be done with the tools most unions already have. Software makes the decision durable, because it puts the category on the screen at the moment of entry and will not let the transaction through without one.

The records behind the filing

The report is one artifact. The obligation underneath it runs longer and reaches further, and it is the part unions tend to underbuild.

Five years, including the software. The officers required to file are responsible for maintaining records that provide in sufficient detail the information necessary to verify the accuracy and completeness of the report. Those records must be kept for at least five years after the date the report is filed, and include vouchers, worksheets, receipts, applicable resolutions, and any electronic documents, including recordkeeping software, used to complete, read, and file the report.

That last clause deserves more attention than it gets. If your filing worksheets live in a spreadsheet on a laptop, or in a database whose vendor has stopped supporting the version you run, the retention obligation attaches to the ability to read those records, not just to their existence. A union that migrates off a legacy system without preserving readable copies of the underlying records still owes those records for five years.

Bonding. Where a labor organization has property and annual financial receipts exceeding $5,000, each officer, employee, and agent who handles union funds or property must be bonded. The bond must be at least 10 percent of the value of the funds handled by that individual during the last reporting period, up to a maximum of $500,000, and must be obtained from a surety company approved by the Secretary of the Treasury. The form asks for the maximum recoverable amount. Knowing who handled how much is a records question.

Election records. Officer elections carry their own preservation rule. Under section 401(e) of the LMRDA, the ballots and all other records pertaining to the election must be preserved for one year following the election. The Department's regulations at 29 CFR 452.106 state the same requirement for every secret ballot election subject to the Act. In OLMS practice this is read broadly. In one published statement of reasons, a local that retained voted ballots, return envelopes, challenged ballots, totals reports, and membership lists still committed a technical violation because the secret ballot envelopes were missing. That is the standard of completeness the retention rule is measured against.

Amended LM-1. Some governance changes trigger a separate filing. If the labor organization changed practices or procedures such as qualifications for membership, levying assessments, authorizing disbursement of funds, auditing financial transactions, ratifying contract terms, authorizing strikes, disciplining or removing officers, or issuing work permits, and those practices are not described in the constitution and bylaws, an amended Form LM-1 must be filed to update the information on record.

What most unions get wrong

Treating the LM report as an accounting deliverable. The bookkeeper or outside accountant owns the filing, and the membership side of the form gets filled in at the end from whatever roster the office can produce. That is how a union ends up reporting a member count that does not match the count it uses for per capita, and then has to explain the difference.

Assuming the outside accountant's chart of accounts maps to the form. It rarely does without work. Expense accounts are built for budgeting and board reporting. The LM-2 schedules are built around what the union does for its members. "Staff travel" is a budget line. It is not an LM category, and the same travel could belong to Contract Negotiation and Administration, Organizing, or Political Activities depending on the trip. Someone has to make that call, and the only person who reliably can is the person who authorized the trip.

Preparing for the audit instead of preparing the records. OLMS conducts compliance audits of unions, and the natural instinct is to prepare when one is announced. The five-year retention rule means the preparation happened, or did not, years earlier.

Waiting for the filing window to discover the data problem. Ninety days is not much time when the fiscal year just ended, the books are still closing, and the answer to a schedule turns out to require reconciling two systems. There is no extension. A local that runs a dry-run extraction in month seven of the fiscal year finds the gaps while there is still time to fix the underlying records rather than paper over them.

Reading the 2026 threshold change as pure relief. Moving from LM-2 to LM-3 removes reporting detail. It does not remove the recordkeeping obligation, and it does not remove the five-year retention rule. A local that drops to the LM-3 and simultaneously relaxes its records discipline has traded a smaller form for a larger risk.

What to ask a software vendor

If you are evaluating union reporting software with DOL compliance in mind, these questions separate platforms that hold the data from platforms that merely display it. None of them can be answered with a brochure.

Press hardest on the fifth question. The five-year retention rule makes the answer to it a compliance question rather than a contract preference.

How eMembership fits

This section describes our own platform. Everything above applies regardless of which system you use.

eMembership has been in continuous development for labor unions since 2008 and is used by 55+ locals and internationals across the United States and Canada. It does not file your LM-2 or LM-3. No software does, because the LM annual reports go through the OLMS Electronic Forms System and your president and treasurer sign them. What a platform can do is hold the records that produce the answers, and hold them where you can pull them on demand.

The membership portion of the form. Member Management carries member status and custom tags, chapter and employer associations, work history, and COPE authorization details with opt-out windows. Statuses such as active, inactive, life member, and potential member are tracked as attributes of the record. That is the raw material behind a member count by category rather than a roster export somebody has to interpret.

The dues and receipts portion. Member Payments and Billing supports rates configured by employer, region, contract, or classification, with effective date ranges so rate changes apply on the right date. On the employer side, a single remittance can carry dues, COPE contributions, agency fees, and clearing account amounts, with each amount posting to its own ledger account and rolling up into member, employer, and union-wide reports. That allocation happening at intake is categorization distance of zero on the receipts side.

Getting the data out. The Reports and Queries module includes a built-in library covering members, finance, employers, organizing, and grievances, plus a Query Builder that staff use through a checkbox and picklist interface with no programming required. Advanced users can write SQL directly. Results export to Excel in one click. Queries are saved by name, can carry runtime parameters such as a date range, and can be shared or kept private. Reporting requirements that the built-in library and the Query Builder cannot satisfy are documented and built during Discovery.

The audit trail. Changes are logged with the user, the timestamp, and the old and new values. There is no one-click rollback. Point-in-time restoration is handled with support through nightly backups. We say that plainly because a vendor claiming instant reversal of any change is describing something different from what most union databases actually do.

Retention and hosting. eMembership is hosted in Winmill's own data center, which is SOC 1 and SOC 2 audited and HIPAA and PCI DSS compliant, inside an ISO 27001 certified facility, with nightly encrypted backups and Winmill managing server hardware, patching, and monitoring. Your data belongs to your union and exports at any time.

What eMembership does not do: it does not generate a completed Form LM-2 or LM-3, and it does not map its reports to LM schedule numbers out of the box. Whether a given LM schedule can be produced as a standing report for your local is a question for Discovery, and the honest answer depends on how your union codes its own categories.

At ILWU Local 13, moving onto eMembership was part of a change that eliminated manual remittance entry, which had previously meant thousands of records keyed by hand every month, and removed the need for temporary staff hired for that data entry. The local also described a finance-model problem that a general-purpose system could not solve.