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Federal and State Filing Requirements for Locals

Updated September 7, 2022

(See Section 11.9 of U.O.P.M.)

ALL Locals must file with the IRS. There are NO exceptions.

Organizations with Gross Receipts of $50,000 or Less
Filing Requirement: e-Postcard (Form 990-N)
For more information, go to:

Organizations with Gross Receipts of more than $50,000
Filing Requirement: Form 990 or 990EZ
For more information, go to:

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Every labor organization subject to the Labor-Management Reporting and Disclosure Act (LMRDA) of 1959, as amended, is required to file an electronic Financial Report, Form LM-2, LM-3, or LM-4 each year with the Office of Labor-Management Standards (OLMS) of the DOL.

EFS is a web-based system for completing, signing, and submitting Labor Organization Annual Financial Reports. EFS allows a labor organization with a web-enabled computer the ability to acquire, complete, sign, and electronically file reports without purchasing a digital signature or downloading special software.

DOL reports are due no later than 90 days after the close of the fiscal year.

The fiscal year for most CWA Locals closes on September 30; therefore, the reporting period for DOL reports is October 1 through September 30. These reports must be filed with the DOL by December 28. The LMRDA does not authorize or grant any extension of time for filing these reports for any reason.

Reporting Requirements

  • If total annual receipts are less than $10,000, Locals may use the onlineForm LM-4;
  • If total annual receipts are less than $250,000, Locals may use the online Form LM-3;
  • If total annual receipts are more than $250,000, Locals must use the online Form LM-2.

Go to the following links for more info:

LM-2, LM-3 & LM-4

Exclusion From Filing LM Reports

Only those Locals comprised entirely of public employees (state, county or municipal employees) are excluded from filing an LM financial report.

CWA Councils ― Labor-Management (LM) Reporting

CWA Councils (city, state, or regional Councils) are also subject to the reporting requirements of the LMRDA. The Councils should use the same monetary guidelines as previously outlined in determining which LM financial report form to use. (See Section 11.16 of the U.O.P.M.)

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Specific attention should be given to the questions on the reporting forms concerning the Labor Organization Bond. The LMRDA requires that individuals handling union funds be bonded. This requirement covers both CWA Locals and CWA Councils.

Go to the following link for more bonding information:

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Several states require Local unions to file financial data with the State Department of Labor. It is the responsibility of the appropriate Local officer to become familiar with such state regulations. If you have any questions in this respect, I suggest you contact your State Department of Labor which is generally located in the capital city.

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It is CWA’s policy that Locals forward to the Secretary-Treasurer’s office the following:

  • A copy of the Local’s LM-2, LM-3 or LM-4 report;
  • A copy of the Local’s IRS Form 990;
  • A copy of the Local’s financial report/audit.

Please either mail a copy of your completed reports to my office or email it to

NOTE: The CWA Secretary-Treasurer's office does not require a copy of any state reports your Local may be obligated to file.