SB1850 targets post‑employment movement between Congress and the lobbying industry. The bill rewrites parts of 18 U.S.C. §207 to bar former Members from lobbying Congress, lengthens cooling‑off periods for staff, restricts hiring of recent registered lobbyists and foreign agents by Members and committees, and expands public disclosure and enforcement tools.
The measure matters because it changes the balance between preventing conflicted influence and preserving mobility between public service and private advocacy. It creates new operational duties for congressional offices, lobbying firms, and an interbranch pair of administrators charged with a public lobbyist database and additional reporting requirements.
At a Glance
What It Does
The bill amends criminal conflict‑of‑interest law and the Lobbying Disclosure Act to: impose a lifetime ban on Members lobbying Congress after leaving office, extend staff cooling‑off periods, prohibit hiring of recent registered lobbyists or foreign agents by Members/committees under a 6‑year rule, require a joint searchable disclosure website, and raise civil penalties under the Lobbying Disclosure Act.
Who It Affects
Directly affects former and current Members and senior congressional staff; registered lobbyists and lobbying firms (including incorporated entities that employ multiple lobbyists); entities that use former congressional staff as consultants; and the House Clerk and Senate Secretary who must maintain the new website and databases.
Why It Matters
The bill tightens revolving‑door rules and transparency, increasing compliance obligations for both congressional offices and private advocacy shops, while giving prosecutors and ethics committees clearer reporting and enforcement channels.
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What This Bill Actually Does
SB1850 changes both criminal conflict‑of‑interest law (title 18) and the Lobbying Disclosure Act to make it harder for recent government insiders to return to work that directly seeks congressional action. For Members of Congress, the bill replaces the existing cooling‑off language with a categorical prohibition: after leaving office a former Senator or Representative (and elected officers of each House) may not knowingly make communications to, or appear before, congressional staff or Members to influence official action on behalf of a private client.
The criminal reference points to section 216 for penalties, and the bill also removes certain elected‑officer references elsewhere to tighten the statute’s structure.
For staff, SB1850 increases multiple statutory cooling‑off periods from one year to six years across several enumerated categories of legislative employees. That change applies to the specific staff paragraphs listed in current law, lengthening the window during which former staff are barred from lobbying their former offices.The bill separately addresses the hiring side of the revolving door: it bars Members and committees from hiring registered lobbyists or agents of foreign principals for six years if the individual had substantial lobbying contact with that Member or committee.
The text defines relevant terms by reference to the Lobbying Disclosure Act and FARA, provides a non‑exhaustive set of considerations for what counts as “substantial lobbying contact” (e.g., coordination of meetings, presentations to staff, solicitation of earmarks, fundraising activity beyond a mere contribution), and authorizes the Ethics Committees in each chamber to grant waivers for “compelling national need.”On transparency and enforcement, the bill directs the House Clerk and Senate Secretary to run a joint, searchable website called lobbyists.gov and to include a new dataset of “Substantial Lobbying Entities.” Incorporated entities that employ more than three registered lobbyists must annually file lists of current or contracted individuals who are former Members or covered legislative branch officials meeting pay, tenure, or title‑based thresholds; filings must include brief job descriptions and be shared with the U.S. Attorney for the District of Columbia. Finally, the bill increases the civil penalty available under the Lobbying Disclosure Act from $200,000 to $500,000.
The Five Things You Need to Know
The bill replaces the current Member cooling‑off provision with a lifetime criminal ban on former Senators, Representatives, or elected congressional officers lobbying Congress on behalf of any private party.
It increases statutory cooling‑off periods for multiple categories of congressional staff from one year to six years by amending section 207(e) of title 18.
Members and committees may not hire a registered lobbyist or agent of a foreign principal for six years if that individual had a substantial lobbying contact with that Member or committee; chamber Ethics Committees can waive this for a ‘compelling national need.’, The House Clerk and Senate Secretary must maintain a joint, searchable site (lobbyists.gov) and the bill requires an annual filing by incorporated entities employing more than three registered lobbyists listing covered former officials and their job descriptions; those filings go to the U.S. Attorney for D.C.
The Lobbying Disclosure Act’s civil penalty is raised from $200,000 to $500,000 and the joint website must include a ‘Substantial Lobbying Entities’ dataset with an API or similar download feature.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Short title
Establishes the act’s name: the Close the Revolving Door Act of 2025. This is housekeeping but signals the bill’s intent and scope for interpretation and related rulemaking or implementing guidance.
Lifetime lobbying ban for Members and elected officers
Substitutes new text that criminalizes post‑service lobbying by former Senators, Representatives, and elected officers when they knowingly communicate to or appear before congressional Members, officers, or employees on behalf of another person to influence official action. Practical effect: knocks out the limited cooling‑off model for Members and converts the provision into a broad bar tied to the criminal provision at section 216; it also rearranges surrounding statutory language to remove duplicative elected‑officer entries, clarifying scope but raising questions about prosecutorial thresholds (knowledge and intent elements).
Extends staff cooling‑off periods to six years
Amends several specific subsections of section 207(e) to replace ‘1 year’ with ‘6 years’ for the enumerated staff categories. This is a straight numeric extension but touches many staff roles (as listed in the statute) and therefore lengthens the period during which former staff cannot engage in lobbying activities related to their prior duties, increasing compliance monitoring in House and Senate offices and for firms that recruit ex‑staff.
Creates a joint lobbyist disclosure website and small appropriation
Requires the Clerk and Secretary to maintain a single, easily searchable internet database called lobbyists.gov for information already required under the Lobbying Disclosure Act, with an explicit goal of usability. The bill authorizes $100,000 for FY2026 to implement the site. Implementation will require technical choices about searchability, data formats, and ongoing funding beyond the one‑year authorization provided in the text.
Hiring ban for registered lobbyists and foreign agents; waiver and definition of contact
Adds a prohibition on hiring registered lobbyists or agents of foreign principals by Members or committees within six years of the lobbyist’s service where the lobbyist had a ‘substantial lobbying contact’ with that Member or committee. The section cross‑references LDA and FARA definitions, provides examples and non‑exhaustive criteria to determine ‘substantial’ (meetings coordination, earmark solicitation, presentations to staff, non‑mere social ties), and creates a waiver path through each chamber’s Ethics Committee for compelling national needs. The practical implication: hiring decisions for staff and consultants must include a legal assessment of prior lobbying activity and relationships.
Annual reporting by substantial lobbying entities and law‑enforcement sharing
Adds a new LDA section requiring incorporated entities that employ more than three registered lobbyists to annually file with House and Senate leadership a list of any employee, contractor, or paid consultant who is a former Member or covered legislative official and who meets pay, tenure, or title thresholds (≥$100,000 yearly pay, ≥4 years service, or specified senior titles). Filings must include brief job descriptions and be posted on lobbyists.gov in a searchable, downloadable format with an API; copies must also go to the U.S. Attorney for D.C. This creates a mechanism for proactive disclosure and for prosecutors to detect underreporting or potential criminal violations.
Increases civil penalties under the Lobbying Disclosure Act
Raises the maximum civil penalty from $200,000 to $500,000 for violations of the Lobbying Disclosure Act’s reporting requirements. That increases the financial risk of noncompliance for both registrants and entities but does not itself change criminal standards or procedural enforcement mechanisms.
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Explore Government in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Advocacy groups and watchdogs: gain clearer reporting lines, an accessible unified database, and a new dataset of former‑official hires to monitor influence and detect potential conflicts more easily.
- Ethics committees: receive explicit waiver authority and standardized filings and data that make investigating hiring and disclosure failures more straightforward.
- Members’ constituents: benefit from reduced potential for immediate post‑service influence by former representatives and clearer public transparency about who is lobbying and who formerly served in government.
Who Bears the Cost
- Members of Congress and congressional offices: face reduced hiring flexibility and the need to vet candidates’ prior lobbying contacts and foreign agent ties, with attendant HR/legal costs and potential loss of experienced hires.
- Registered lobbyists and lobbying firms: face longer exclusion windows on moving into congressional employment and additional disclosure obligations if they are part of a substantial lobbying entity; compliance and recruitment strategies will need updating.
- Substantial lobbying entities and incorporated firms that employ multiple lobbyists: must compile annual reports, prepare job descriptions for public filing, implement controls to avoid underreporting, and bear the operational cost of integrating their data into lobbyists.gov; they also face higher civil penalties for misreporting.
- House Clerk and Senate Secretary (and IT teams): must build and operate lobbyists.gov, maintain an API and searchable datasets, and manage ongoing data quality, with only a one‑year, $100,000 appropriation explicitly authorized in the bill.
- U.S. Attorney for the District of Columbia: receives filings for oversight and will bear increased investigative workload and potential resource burdens if the filings generate enforcement matters.
Key Issues
The Core Tension
The central dilemma is a conflict between reducing improper influence and preserving legitimate career mobility and expertise: stricter bans and broader disclosure reduce opportunities for conflicted lobbying but also limit the ability of former officials to bring institutional knowledge into private‑sector policy work and of congressional offices to hire seasoned professionals; simultaneously, the bill increases transparency and enforcement capacity but risks circumvention and uneven implementation absent clearer definitions, resources, and procedural safeguards.
The bill is ambitious but leaves several operational and legal wrinkles unresolved. The lifetime ban on Members adopts criminal language tied to intent and knowledge; proving those elements—particularly for informal advice, off‑site communications, or written background briefings—will be challenging in prosecution and may require supplemental guidance or rulemaking.
The statutory criteria for ‘substantial lobbying contact’ provide examples but remain subjective; that opens room for gaming (e.g., routing advocacy through contractors, redefining roles as ‘strategic advice’ rather than direct lobbying) and for disputes about whether particular past interactions trigger the hiring ban.
The transparency provisions create useful public datasets but the funding is minimal. A one‑time authorization of $100,000 in FY2026 is unlikely to cover a robust, secure, and sustainably operated portal plus API and data curation across House and Senate systems.
The reporting thresholds (incorporated entity employing more than three registered lobbyists; pay, tenure, and title cutoffs for listed individuals) will push some entities to restructure labor arrangements—shifting to independent contractors or subcontracting to avoid the threshold—rather than reduce insider influence. Finally, relying on the U.S. Attorney for the District of Columbia to review all filings could concentrate burdens in a single office and create uneven enforcement unless resources and coordination mechanisms are specified elsewhere.
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