Covington Announces Pay-to-Play Survey (2026 Edition)

Covington is pleased to announce that it has revised and updated its comprehensive 50-state survey of pay-to-play laws for 2026.

Companies doing business with the federal government or state and local governments and companies operating in regulated industries are subject to a dizzying array of “pay-to-play” rules. These rules effectively prohibit company executives and employees (and in some cases, their family members) from making certain personal political contributions. Even inadvertent violations can be dangerous—a single political contribution can, for example, jeopardize the company’s largest public contract.

To help in-house lawyers and compliance professionals with making these decisions, Covington annually updates a detailed survey of the pay-to-play laws of the federal government, all 50 states, the District of Columbia, and dozens of cities and counties. This over 460-page survey:

• Details all federal and statewide pay-to-play rules.
• Describes over 100 “specialty” pay-to-play rules that apply to contractors doing business with certain agencies or companies operating in certain regulated industries, including those that apply to investment firms that manage state or local public funds, lottery and gaming companies, public utilities, redevelopment contractors, and insurance companies.
• Includes pay-to-play laws for major cities and counties across the country.

The survey also includes user-friendly charts and legal citations answering questions such as:

• Which donors are affected?
• Which contributions are restricted?
• Is there a de minimis exception? What are the other exceptions?
• Which types of contracts are covered?
• How long after a contribution does the restriction run?
• Does the rule restrict political fundraising and other solicitations?
• Are there reporting and disclosure requirements?
• What are the penalties?

Covington offers the survey for purchase in its entirety. Alternatively, groups of states may be made available at discounted rates. For questions or to purchase the survey, please contact paytoplaysurvey@cov.com.

If you have any questions concerning the material discussed in this client alert, please contact the following members of our Election and Political Law practice.