Pennsylvania Government Contractor Pay-to-Play Disclosure Deadline – February 15, 2022

Under Pennsylvania's pay-to-play disclosure law, any business entity that has been awarded any no-bid contract by the Commonwealth of Pennsylvania or any of its political subdivisions must file a disclosure with the Pennsylvania Department of State by February 15, 2022.

This report covers activity from the 2021 calendar year.

If contributions above the reporting threshold were made to Pennsylvania recipients by the business entity’s covered individuals during 2021, Form DSEB-504 must be used to disclose those contributions.

In contrast, if no reportable contributions were made during the relevant calendar year by the business entity’s covered individuals, a form must still be filed to indicate that no contributions were made. This is done using Form DSEB-504B.

Electronic filing is not available in Pennsylvania, so the appropriate form must be submitted either by mail or by bringing a copy to the Department of State’s offices.

COMPLIANCE TIP – ALTHOUGH PENNSYLVANIA LAW PROHIBITS CORPORATE CONTRIBUTIONS, THE DEFINITION OF “COVERED INDIVIDUALS” IS BROAD AND INCLUDES A COMPANY’S OFFICERS, DIRECTORS, ASSOCIATES, PARTNERS, OWNERS AND EMPLOYEES. THE DEFINITION ALSO INCLUDES THE IMMEDIATE FAMILY MEMBERS OF ANY COVERED INDIVIDUAL.

For more information, please contact Partner and specialist in Corporate Political Activity Law, Rebecca Moll Freed, Esq. via email here, Counsel Avi D. Kelin, Esq. via email here, or call 973.533.0777.

An earlier version of this post appeared in InsiderNJ.