Reminder: Illinois Pay-to-Play Registration Updates Are Due Quarterly

Skadden Publication / Political Law Update

Ki P. Hong Charles M. Ricciardelli Matthew Bobys Melissa L. Miles Tyler Rosen Theodore R. Grodek

The next quarterly update for state contractors that is required under the Illinois pay-to-play law is due August 14, 2019. As described in earlier mailings, the state’s pay-to-play law requires a company with aggregate annual bids, proposals and contracts totaling more than $50,000 to register with the Board of Elections and list its covered donors.

If the company has existing contracts and no pending bids, updates to the registration are due quarterly on the 14th of February, May, August and November each year. If the company has pending bids, updates to the registration are due within five business days or seven calendar days of any change requiring an update, or the day before the contract is awarded, whichever is first.

We suggest confirming all state contractors are properly registered and, at least quarterly, are confirming the accuracy of their registrations. We often find covered donor lists in registrations include problems such as:

  • capturing too many employees, which can be problematic under the pay-to-play ban if an employee is listed who does not need to be;
  • failing to include spouses of covered employees;
  • listing affiliate companies that do not need to be, such as non-U.S. affiliates, and non-operating sister companies and subsidiaries;
  • failing to include the contractor’s PAC; and
  • allowing years to have passed since the last update.

This memorandum is provided by Skadden, Arps, Slate, Meagher & Flom LLP and its affiliates for educational and informational purposes only and is not intended and should not be construed as legal advice. This memorandum is considered advertising under applicable state laws.