As we move into fiscal year reporting season, this is a good time for every local and council to review year-end financial records and make sure all required compliance filings and safeguards are in place. That includes Department of Labor LM reports, IRS Form 990 filings, and required fidelity bonding for anyone who handles union funds. Each of these carries specific thresholds, electronic filing requirements, and firm deadlines — so early preparation makes the process much smoother. We strongly recommend filing your LM report early, as the DOL’s online filing system can slow down or become unavailable in the days leading up to the deadline. Heavy traffic in the final 48 hours often results in slower page loads, longer save and submit times, and session timeouts.
I want to recognize the financial officers, trustees, and local leaders who handle this work year after year. Much of it happens behind the scenes, but it is essential to protecting our union’s integrity and the trust of our members. Strong compliance practices are not just regulatory obligations — they are part of good stewardship.
The UWUA continues to work with the Department of Labor through the Voluntary Compliance Partnership Program to support our affiliates and strengthen reporting and financial controls. That partnership focuses on proper LM filings, required bonding coverage, electronic submission standards, and the use of OLMS resources and training tools.
The overview below highlights the key DOL, IRS, and bonding requirements. As always, the National Office is available to provide guidance, training, and hands-on assistance to help every affiliate stay compliant and protect union funds and assets.
DOL Filing Requirements
What Form do you file?
Depending on size of the organization’s receipts, there are three potential forms your local union would be required to file:
- Form LM-2 –required when your local union’s total annual receipts were $250K or more.
- Form LM-3 –required when your local union’s total annual receipts were $10K or more, but less than $250K.
- Form LM-4 –required when your local union’s total annual receipts were less than $10K.
When is the Form due to the DOL?
The Form LM-2, LM-3 and LM-4 are required to be filed within 90 days after an organization’s fiscal year-end and must be filed electronically. The DOL does not authorize or allow extensions.
Fidelity Bonding Requirements
The Labor-Management Reporting and Disclosure Act (LMRDA) provides that any person who handles union funds must be bonded for an amount of at least 10% of the funds handled (including assets and income) during the previous fiscal year up to a maximum of $500,000. The coverage must be computed at the start of each fiscal year and any increase in coverage must be adjusted promptly. The National Office does obtain the coverage for your local union or council through a national policy. In order to obtain the coverage, each affiliate must provide the National Office with the amount of coverage needed annually. Please contact the National Office for assistance in determining the amount of bonding required.
IRS Filing Requirements
What IRS Form do you file?
Depending on the size of your local union’s assets and receipts, there are three potential forms organizations would be required to file:
- 990-N (Postcard) – if your union normally has gross receipts of $50K or less.
- 990-EZ – if your union has gross receipts of less than $200K and total assets at the end of the tax year of less than $500K.
- Form 990 (full form) – which is filed if either gross receipts are greater than or equal to $200K or total assets are greater than or equal to $500K at the end of the tax year.
When is the Form due to the IRS?
All forms are to be filed electronically and for organizations that have a calendar year end of December 31 the Form 990, 990-EZ, and 990-N are due May 15th (4 ½ months after year end). Organizations can apply for an extension which will extend the time to November 15th (10 ½ months after year end). Steep monetary penalties may apply for late filers.
Ramifications for Non-Compliance
In addition to monetary penalties, if you do not file for three consecutive years, your local union’s tax exemption will be automatically revoked, and it will be considered a taxable entity and possibly be subject to income taxes similar to for-profit entities. Once this occurs, there is a fairly lengthy application process to get reinstated as a tax-exempt organization so please make sure to comply with the annual filing requirements.