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Labor Organization Officer and Employee Report - Minor Child Definition

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Published April 22nd, 2026
Detected March 21st, 2026
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Summary

The Labor-Management Standards Office (LMSO) has issued a final rule revising the definition of 'minor child' for Form LM-30, the Labor Organization Officer and Employee Report. This revision clarifies reporting obligations for labor organizations and their officers and employees.

What changed

The Labor-Management Standards Office (LMSO) has finalized a rule amending the definition of 'minor child' as it pertains to Form LM-30, the Labor Organization Officer and Employee Report. This change directly impacts how labor organizations and their officers and employees report certain financial interests and transactions, aiming to provide clearer guidance on what constitutes a reportable relationship involving a minor child.

Compliance officers for labor organizations and related entities must review the updated definition and ensure their reporting practices for Form LM-30 align with the new requirements. The rule becomes effective on April 22, 2026, and applies to fiscal years beginning on or after July 1, 2026, necessitating an update to reporting procedures before the next reporting cycle.

What to do next

  1. Review the revised definition of 'minor child' for Form LM-30.
  2. Update internal policies and procedures for completing Form LM-30.
  3. Ensure compliance with the revised definition for fiscal years beginning on or after July 1, 2026.

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Rule

Minor Child Definition for Form LM-30 Labor Organization Officer and Employee Report

A Rule by the Labor-Management Standards Office on 03/23/2026

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Published Document: 2026-05634 (91 FR 13737) This document has been published in the Federal Register. Use the PDF linked in the document sidebar for the official electronic format.

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Department of Labor
Office of Labor-Management Standards
  1. 29 CFR Part 404
  2. RIN 1245-AA16 ( printed page 13737) # AGENCY:

Office of Labor-Management Standards, Department of Labor.

ACTION:

Final rule.

SUMMARY:

This final rule revises the definition of “minor child” as that term appears in 29 CFR 404.1(h) and on the Form LM-30 Labor Organization Officer and Employee Report. The definition is changed from “under 21 years of age” to “under 18 years of age.” This amendment aims to align the definition with the age of majority recognized in the vast majority of United States jurisdictions, thereby reducing the reporting burden on filers while preserving the integrity and purpose of the Labor-Management Reporting and Disclosure Act (LMRDA)'s disclosure requirements. A technical correction is also made to the Form LM-30 Instructions.

DATES:

This rule is effective April 22, 2026, and applies to fiscal years beginning on or after July 1, 2026.

FOR FURTHER INFORMATION CONTACT:

Andrew C. Hasty, Chief of the Division of Interpretations and Regulations, Office of Labor-Management Standards, U.S. Department of Labor, 200 Constitution Avenue NW, Room N-5609, Washington, DC 20210, by telephone at (202) 693-0123 (this is not a toll-free number), 711 (TTY/TDD), or by email at olms-public@dol.gov.

SUPPLEMENTARY INFORMATION:

I. Background

The Labor-Management Reporting and Disclosure Act of 1959 (LMRDA), 29 U.S.C. 401 et seq., mandates specific reporting and disclosure requirements for labor organizations, their officers and employees, employers, labor relations consultants, and surety companies. Under Section 202 of the LMRDA, 29 U.S.C. 432, every officer or employee of a labor organization, or whose spouse or “minor child,” directly or indirectly holds any interest, or derives income or benefit from certain employers or businesses dealing with the labor organization, is required to file a disclosure report with the Secretary of Labor. The Secretary of Labor has the authority to prescribe the form for these financial disclosure reports. 29 U.S.C. 438.

The U.S. Department of Labor (Department), Office of Labor-Management Standards (OLMS), uses the Form LM-30 Labor Organization Officer and Employee Report to address actual or potential conflicts of interest involving union officials' personal financial interests, as well as those of their spouse or “minor child,” and their labor organization. In 2007, OLMS defined “minor child” as a “son, daughter, stepson, or stepdaughter under 21 years of age”. This definition aimed to provide a uniform, nationwide standard, noting that 21 was the age of majority in most states at the time of the LMRDA's passage. See generally 72 FR 36106. In light of the statutory silence on the age at which a child reaches majority, OLMS reasoned that age 21 was sensible because there needed to be a uniform, nationwide definition that Form LM-30 filers, union members, and the public could easily ascertain, and that 21 was already the age of majority in most states at the time of LMRDA passage. See Labor Organization Office and Employee Report, Form LM-30, 72 FR 36145 (July 2, 2007).

On July 1, 2025, the Department published a Notice of Proposed Rulemaking (“NPRM”) seeking public comment on amending its regulations to redefine “minor child” as a son, daughter, stepson, or stepdaughter under the age of 18. See Minor Child Definition for Form LM-30 Labor Organization Officer and Employee Report, 90 FR 28255 (July 1, 2025).

II. Discussion of the Final Rule

After reviewing the one and only comment received in response to the July 1, 2025 NPRM, the Department is now issuing a final rule that implements the proposed rule. This revision aligns the Form LM-30 reporting requirements with current legal norms, where individuals aged 18 and older are generally considered capable of managing their own financial affairs and are legally responsible for their actions. In various areas of the law, such as voting, entering into contracts, and military service, adulthood typically begins at age 18. Currently, 47 states and Washington, DC, recognize 18 as the age of majority, with only Alabama and Nebraska at age 19, and Mississippi at age 21. [1 ]

As the one public comment received on the proposed rule explicitly stated, “[t]his proposal to redefine a minor child as an individual `under 18 years of age' is based on sound reasoning. It correctly aligns the LMRDA's reporting requirements with the legal age of majority now established in 47 states and Washington, DC. This change creates a more consistent, modern, and common-sense standard for filers nationwide.”

Additionally, this change has potential to reduce administrative burdens on filers. Requiring disclosure of financial interests or transactions for children or stepchildren aged 18 to 20 imposed unnecessary administrative burdens without significantly enhancing transparency or the detection of conflicts of interest, especially since union officials lack legal control over the financial affairs of their adult children. This amended definition maintains the essential conflict-of-interest disclosure requirements while alleviating an undue burden. In practice, this means filers are no longer required to obtain, review, or disclose information about the financial ( printed page 13738) interests, gifts, employment relationships, or business transactions of children or stepchildren aged 18 through 20 who are legally adults, nor to collect supporting documentation for those disclosures.

Finally, the Department has made a technical correction on page 6 of the Form LM-30 Instructions, in Item 7, removing outdated references to the “How to Provide Additional Information” section, as this instruction is no longer necessary for completing the form.

III. Procedural Issues and Regulatory Review

The Department has reviewed this final rule under various executive orders and acts, concluding the following:

A. Review Under Executive Orders 12866 (Regulatory Planning and Review)

Executive Order (E.O.) 12866, “Regulatory Planning and Review,” 58 FR 51735 (Oct. 4, 1993), requires agencies, to the extent permitted by law, to (1) propose or adopt a regulation only upon a reasoned determination that its benefits justify its costs (recognizing that some benefits and costs are difficult to quantify); (2) tailor regulations to impose the least burden on society, consistent with obtaining regulatory objectives, taking into account, among other things, and to the extent practicable, the costs of cumulative regulations; (3) select, in choosing among alternative regulatory approaches, those approaches that maximize net benefits; (4) to the extent feasible, specify performance objectives, rather than specifying the behavior or manner of compliance that regulated entities must adopt; and (5) identify and assess available alternatives to direct regulation, including providing economic incentives to encourage the desired behavior, such as user fees or marketable permits, or providing information upon which choices can be made by the public. Section 6(a) of E.O. 12866 also requires agencies to submit “significant regulatory actions” to OIRA for review.

OIRA has determined that this final rule does not constitute a “significant regulatory action” under section 3(f) of E.O. 12866, as it reduces reporting and recordkeeping burden for filers and potential filers. Accordingly, this rule was not submitted to OIRA for review under E.O. 12866.

By revising the definition of “minor child” to align with the widely accepted age of majority, the rule is designed to reduce unnecessary administrative burdens on filers while maintaining the integrity and purpose of the Labor-Management Reporting and Disclosure Act's (LMRDA) disclosure requirements. The Department views the benefits of reducing unnecessary burden on filers as justifying the non-existent costs associated with this change.

B. Review Under the Regulatory Flexibility Act (RFA)

The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires preparation of an initial regulatory flexibility analysis (IRFA) and a final regulatory flexibility analysis (FRFA) for any rule that by law must be proposed for public comment, unless the agency certifies that the rule, if promulgated, will not have a significant economic impact on a substantial number of small entities.

The Department conducted a review under the provisions of the Regulatory Flexibility Act (RFA). This rule will eliminate burdensome regulations; therefore, the Department concluded that the impacts of this final rule will not have a “significant economic impact on a substantial number of small entities.” E.O. 13272, “Proper Consideration of Small Entities in Agency Rulemaking,” 67 FR 53461 (Aug. 16, 2002). A “significant economic impact” is generally defined as affecting costs or revenues by more than three percent annually, and a “substantial number” of small entities is typically considered 20 percent.

Because this rule reduces burden rather than imposing new requirements, the preparation of an initial regulatory flexibility analysis (IRFA) or a final regulatory flexibility analysis (FRFA) was not warranted. The Department will transmit this certification, along with a supporting statement of factual basis, to the Chief Counsel for Advocacy of the Small Business Administration for review under 5 U.S.C. 605(b).

C. Review Under the Paperwork Reduction Act (PRA)

This final rule imposes no new information or recordkeeping requirements. The Department does not anticipate any changes to the number of respondents or reporting or recordkeeping hours. An Information Collection Request (ICR) revision package will be submitted to the Office of Management and Budget (OMB) for approval to update the Form LM-30 Instructions. The OMB Control Number for Labor Organization and Auxiliary Reports is 1245-0003.

D. Review Under Executive Order 13132 (Federalism)

E.O. 13132, “Federalism,” 64 FR 43255 (August 10, 1999), imposes certain requirements on Federal agencies formulating and implementing policies or regulations that preempt State law or that have federalism implications. The Executive order requires agencies to examine the constitutional and statutory authority supporting any action that would limit the policymaking discretion of the States and to carefully assess the necessity for such actions. The Executive order also requires agencies to have an accountable process to ensure meaningful and timely input by State and local officials in the development of regulatory policies that have federalism implications.

The Department has determined that this rule will not have a substantial direct effect on the States, on the relationship between the national government and the States, or on the distribution of power and responsibilities among the various levels of government.

E. Review Under Executive Order 12988 (Civil Justice Reform)

With respect to the review of existing regulations and the promulgation of new regulations, section 3(a) of E.O. 12988, “Civil Justice Reform,” imposes on Federal agencies the general duty to adhere to the following requirements: (1) eliminate drafting errors and ambiguity, (2) write regulations to minimize litigation, (3) provide a clear legal standard for affected conduct rather than a general standard, and (4) promote simplification and burden reduction. 61 FR 4729 (Feb. 7, 1996). Regarding the review required by section 3(a), section 3(b) of E.O. 12988 specifically requires that Executive agencies make every reasonable effort to ensure that the regulation: (1) clearly specifies the preemptive effect, if any, (2) clearly specifies any effect on existing Federal law or regulation, (3) provides a clear legal standard for affected conduct while promoting simplification and burden reduction, (4) specifies the retroactive effect, if any, (5) adequately defines key terms, and (6) addresses other important issues affecting clarity and general draftsmanship under any guidelines issued by the Attorney General. Section 3(c) of E.O. 12988 requires Executive agencies to review regulations in light of applicable standards in section 3(a) and section 3(b) to determine whether they are met or it is unreasonable to meet one or more of them.

The Department has completed the required review under E.O. 12988 and has determined that, to the extent permitted by law, this final rule meets the relevant standards of E.O. 12988, ( printed page 13739) which include eliminating drafting errors and ambiguity, minimizing litigation, providing a clear legal standard, promoting simplification and burden reduction, and adequately defining key terms.

F. Review Under the Unfunded Mandates Reform Act (UMRA):

Title II of the Unfunded Mandates Reform Act of 1995 (UMRA) requires each Federal agency to assess the effects of Federal regulatory actions on State, local, and Tribal governments and the private sector. Public Law 104-4, sec. 201 (codified at 2 U.S.C. 1531). For a regulatory action likely to result in a rule that may cause the expenditure by State, local, and Tribal governments, in the aggregate, or by the private sector of $100 million or more in any one year (adjusted annually for inflation), section 202 of UMRA requires a Federal agency to publish a written statement that estimates the resulting costs, benefits, and other effects on the national economy. 2 U.S.C. 1532(a), (b)). The UMRA also requires a Federal agency to develop an effective process to permit timely input by elected officers of State, local, and Tribal governments on a “significant Federal intergovernmental mandate,” and requires an agency plan for giving notice and opportunity for timely input to potentially affected small governments before establishing any requirements that might significantly or uniquely affect them. 2 U.S.C. 1534(a).

The Department examined this final rule according to UMRA and its statement of policy. It determined that the final rule does not contain a Federal intergovernmental mandate. Furthermore, it is not expected to require expenditures of $100 million or more in any one year by State, local, and Tribal governments, in the aggregate, or by the private sector. As a result, the analytical requirements of UMRA do not apply.

G. Review Under the Treasury and General Government Appropriations Act, 1999 (Family Policymaking Assessment)

Section 654 of the Treasury and General Government Appropriations Act, 1999, requires Federal agencies to issue a Family Policymaking Assessment for any rule that may affect family well-being. This final rule will not have any impact on the autonomy or integrity of the family as an institution. Accordingly, the Department concluded that it is not necessary to prepare a Family Policymaking Assessment.

H. Review Under Executive Order 12630 (Governmental Actions and Interference With Constitutionally Protected Property Rights)

Pursuant to E.O. 12630, the Department has determined that this final rule will not result in any takings that might require compensation under the Fifth Amendment to the U.S. Constitution.

I. Review Under the Treasury and General Government Appropriations Act, 2001 (Information Quality)

Section 515 of the Treasury and General Government Appropriations Act, 2001, provides for Federal agencies to review most disseminations of information to the public under information quality guidelines established by each agency pursuant to general guidelines issued by OMB. OMB's guidelines were published at 67 FR 8452 (Feb. 22, 2002). The Department has reviewed this final rule under the OMB guidance and has concluded that it is consistent with applicable policies in those guidelines.

J. Review Under Additional Executive Orders and Presidential Memoranda

The Department has examined this final rule and determined that it is consistent with the policies and directives outlined in E.O. 14154, “Unleashing American Energy,” E.O. 14192, “Unleashing Prosperity Through Deregulation,” and the Presidential Memorandum, “Delivering Emergency Price Relief for American Families and Defeating the Cost-of-Living Crisis.” This rule is specifically expected to be an E.O. 14192 deregulatory action.

List of Subjects in 29 CFR Part 404

PART 404—LABOR ORGANIZATION OFFICER AND EMPLOYEE REPORTS

  1. The authority citation for part 404 continues to read as follows:

Authority: Secs. 202, 207, 208, 73 Stat. 525, 529 (29 U.S.C. 432, 437, 438); Secretary's Order No. 03-2012, 77 FR 69376, November 16, 2012.

  1. Amend § 404.1 by revising paragraph (h) to read as follows:

§ 404.1 Definitions. * * * * * (h) Minor child means a son, daughter, stepson, or stepdaughter under 18 years of age.

  • * * * * Signed in Washington, DC.

Elisabeth Messenger,

Director, OLMS.

Footnotes

1.

                     Ala. Stat. Ann. § 26-1-1 (2024) (While the age of majority is 19 in Alabama, individuals over the age of 18 may enter into legal contracts): Alaska Stat. Ann. § 25.20.010 (2024): Ariz. Rev. Stat. Ann. § 1-215 (2025): Ark. Code Ann. § 9-25-101 (2024): Cal. Fam Code §§ 6500, 6501 (2024): Colo. Rev. Stat. § 13-22-101 (2021): Conn. Gen. Stat. Ann. § 1-1d (2024): Del. Code Ann. tit. 1, § 701 (2024): DC Code Ann. § 46-101 (2024): Fla. Stat. Ann. § 1.01(13) (2025): Ga. Code Ann. § 39-1-1 (2022): Haw. Rev. Stat. Ann. § 577-1 (2024): Idaho Code § 32-101 (2024): 755 Ill. Comp. Stat. Ann. 5/11-1 (2024): Ind. Code Ann. § 1-1-4-5 (2024): Iowa Code Ann. § 599.1 (2025), see also § 565B.1, Kan. Stat. Ann. § 38-101 (2024): Ky. Rev. Stat. Ann. § 2.015 (2024): La. Civ. Code Ann. art. 29 (2024); Me. Rev. Stat. Ann. tit. 1 § 72(11) (2021): Md. Gen. Provis. § 1-401 (2025), Mass. Gen. Laws Ann. ch. 4, § 7, cl. 48 (2025): Mich. Comp. Laws Ann. § 722.52 (2024): Minn. Stat. Ann. § 645.45 (2024): Miss. Code. Ann. § 1-3-27 (2024): Miss. Code. Ann. § 93-19-13 (2024) (while the age of majority in Mississippi is 21, individuals over the age of 18 may enter into legal contracts); Mo. Ann. Stat. § 431.055 (2024): Mont. Const. art. II, § 14 (amended by Const. Amend. No. 4 (1978) and Const. Amend. No. 16 (1986)); Neb. Rev. Stat. § 43-2101 (2021); Nev. Rev. Stat. § 129.010 (2024); N.H. Rev. Stat. Ann. § 21:44 (2023); N.J. Stat. Ann. § 9:17B-3 (2024); N.M. Stat. Ann. § 28-6-1 (2025); N.Y. Gen. Oblig. Law § 1-202 (2024); N.C. Gen. Stat. § 48A-2 (2025); N.D.C.C. § 14-10-02 (2024); Ohio Rev. Code Ann. § 3109.01 (2024); Okla. Stat. Ann. tit. 15, § 13 (2024); Or. Rev. Stat. Ann. § 109.510 (2023); 23 Pa. Stat. and Cons. Stat. Ann. § 5101 (2024); 15 R.I. Gen. Laws Ann. § 15-12-1 (2024); S.C. Code Ann. § 15-1-320 (2025); S.D. Codified Laws § 26-1-1 (2025); Utah Code Ann. § 15-2-1 (2024); Tenn. Code Ann. § 1-3-105(1) (2025); Tex. Civ Prac. & Rem. Code § 129.001 (1985); Va. Code Ann. § 1-204 (2025); Vt. Stat. Ann. Tit. 1, § 173 (2024); Wash. Rev. Code Ann. § 26.28.010 (2024); W. Va. Code Ann. § 2-2-10 (2025); Wis. Stat. Ann. § 990.01 (2025); Wyo. Stat. Ann. § 14-1-101(3) (2025); *See “Age Boundaries in Juvenile Justice Systems,”* Nat'l Governors Ass'n, (Aug. 12, 2021), *<a href="https://www.nga.org/publications/age-boundaries-in-juvenile-justice-systems/">https://www.nga.org/​publications/​age-boundaries-in-juvenile-justice-systems/</a>; see, e.g. Roper* v. *Simmons,* 543 U.S. 551, 574, 125 S. Ct. 1183, 1198, 161 L. Ed. 2d 1 (2005) (“The age of 18 is the point where society draws the line for many purposes between childhood and adulthood”), Vivian E. Hamilton, *Adulthood in Law and Culture,* 91 Tul. L. Rev. 55, 64, fn. 47 (2016).

Back to Citation [FR Doc. 2026-05634 Filed 3-20-26; 8:45 am]

BILLING CODE 4510-86-P

Published Document: 2026-05634 (91 FR 13737)

CFR references

29 CFR 404

Named provisions

Minor Child Definition for Form LM-30 Labor Organization Officer and Employee Report

Classification

Agency
Labor Department
Published
April 22nd, 2026
Compliance deadline
July 1st, 2026 (99 days)
Instrument
Rule
Legal weight
Binding
Stage
Final
Change scope
Substantive
Document ID
91 FR 13737
Docket
1245-AA16

Who this affects

Applies to
Employers
Industry sector
9211 Government & Public Administration
Activity scope
Reporting Requirements
Geographic scope
United States US

Taxonomy

Primary area
Employment & Labor
Operational domain
Compliance
Topics
Reporting Requirements Labor Unions Reporting and recordkeeping requirements

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