• Prohibited Political and Lobbying Activities for LSC Grantees 
  Election-Year Reminder Memo (July 16, 2026)
  (This memo as a PDF for printing.)

To: All LSC Grantees

From: Will A. Gunn, Vice President for Legal Affairs and General Counsel

Date: July 16, 2026

Subject: 2026 Review of Prohibited Political and Lobbying Activities for LSC Grantees

Because 2026 is an election year, I want to provide you with a review of LSC's restrictions on political and lobbying activities of LSC grantees and some thoughts about operating within them. Please share this with staff, volunteers, board members, and anyone else acting on behalf of your organization or using its resources.

In 1974, Congress created LSC to address the "need to provide high quality legal assistance to those who would be otherwise unable to afford adequate legal counsel." LSC Act § 1001, Pub. L. 93-355 (42 U.S.C. § 2996). Congress found that "for many of our citizens, the availability of legal services has reaffirmed faith in our government of laws" and that "the legal services program must be kept free from the influence of or use by it of political pressures."

Congress also found that "attorneys providing legal assistance must have full freedom to protect the best interests of their clients in keeping with the Code of Professional Responsibility, the Canons of Ethics, and the high standards of the legal profession."

To further those goals, Congress has funded LSC and established restrictions on political and lobbying activities of LSC and LSC grantees. For 2024, Congress appropriated $560 million to LSC, including $526 million for grantees. This longstanding support reflects the success of LSC grantees in providing high-quality legal assistance to low-income people while operating in compliance with LSC rules and restrictions.

Summary of Restrictions on Lobbying and Political Activities

• All LSC grantees must avoid political activities prohibited by 45 C.F.R. Part 1608 .
• All LSC grantees must avoid lobbying activities prohibited by 45 C.F.R. Part 1612 .
  • Grassroots lobbying is always prohibited.
• These rules apply to anyone acting on behalf of the grantee, including:
  • Staff
  • Volunteers
  • Board members
• These rules apply at all times to the use of grantee offices, equipment, and other resources, including computers, phones, and internet services, even when used on personal time.

For more detailed information about the scope of these restrictions, including how they apply to non-LSC funds, see Part 1608—Political Activities, Part 1612—Lobbying, Part 1610—Use of Non-LSC Funds, and www.lsc.gov/lobbying-and-political-activities.

Political Activities

LSC defines "political" as providing or encouraging any "support for or opposition to candidates for public office, ballot measures, or political parties..." as defined in 45 C.F.R. § 1600.1 .

Part 1608 prohibits grantees from engaging in any political activity, including:

• Intentionally identifying the grantee with any partisan or nonpartisan political activity.
• Intentionally identifying the grantee with campaigns for public or party office.
• Providing grantee funds or resources for any political activity, political party, campaign for public or party office, ballot measure, initiative, or referendum.

Part 1608 does not prohibit providing legal assistance to eligible clients. For example, a grantee may represent an eligible client facing eviction because of campaign signs in the tenant's window.

Lobbying

Lobbying means any attempt to influence government decision-making through statements about what actions the government should or should not take regarding the enactment, amendment, or repeal of legislation, rules, executive orders, or other covered government actions.

Lobbying includes grassroots lobbying. Grassroots lobbying occurs when you both state a position about what the government should or should not do and encourage others to contact government officials with that position. Grassroots lobbying is always prohibited.

Lobbying does not include providing information about proposed government actions, such as how a proposed law or rule would work and the effects it would have, so long as you do not express a position about what the government should do.

Lobbying also does not include providing information about the services you provide and the clients you serve. For example, although you may not lobby Congress regarding funding for LSC or your grantee, you may educate members of Congress about your work.

In some limited situations, you may use non-LSC funds to offer views and recommend action on pending or proposed policy, such as responding to an unsolicited written government request, commenting on public rulemaking, or advocating for state or local funding for your own organization. However, those exceptions are narrow and have situation-specific compliance and reporting requirements.

For more information about lobbying restrictions, including exceptions involving the use of non-LSC funds, see 45 C.F.R. Part 1612 , Advisory Opinion 2014-005 , and www.lsc.gov/lobbying-and-political-activities .

Examples of Permissible Personal Activities

In your personal capacity and during your non-work time, you may engage in the following activities. However, you must not use grantee time or resources, and you must not do anything that would intentionally identify a grantee with those activities:

• Actively campaign for candidates for public office in partisan and nonpartisan elections.
• Contribute money to political organizations and attend political fundraising functions.
• Campaign for and hold office in political clubs and organizations.
• Run for public office in nonpartisan elections (but no grantee staff attorney may run for public office in a partisan election).

In pursuing any of these permissible activities, you must follow these requirements:

• Do not engage in any of these activities during your grantee work hours.
• Do not, at any time, use grantee resources for these activities, including grantee-provided phones, computers, copiers, scanners, internet service, office space, or supplies.
• Do not engage in these activities while at a grantee office, regardless of whether you are on or off the clock.

Your non-work time means time when you are not working for a grantee. This may include evenings, weekends, official lunch breaks, or while on any type of leave, whether paid or unpaid.

Please note: These restrictions apply any time you are working for an LSC grantee, even outside of your normal schedule. For example, if you normally do not work weekends but spend a weekend preparing for trial, the restrictions apply during those weekend work hours.

Questions and Guidance

If you have questions, we encourage you to contact LSC so we can provide guidance specific to your situation.