LWVUS joined 112 advocacy groups in opposing the proposed OMB Uniform Guidance rule changes that would significantly impact nonprofits' ability to engage in voter registration and advocacy activities.
Alliance for Justice and 112 Organizations: Comment on Proposed OMB Uniform Guidance Revisions (OMB-2026-0034)
We, the undersigned nonprofit organizations, respectfully submit this comment in opposition to OMB 2026-0034 (Proposed Regulation to Federal Financial Assistance), specifically Section 200.450-Lobbying, which would place greater restrictions on the use of federal funds for issue advocacy, voter registration, and other policy activities. The proposed restrictions ignore the critical role that nonprofits play in informing policymakers and educating the public. The proposed regulation also risks silencing the organizations with the greatest expertise and connection to the communities that federal grant programs aim to serve.
In effect, the proposed regulation is a direct attack on nonprofits’ ability to advocate for the ways public policy impacts communities’ rights and lives. Civic engagement is foundational to democracy, and an integral component of nonprofit advocacy. It ensures that our communities have a voice in the government that serves them and that their needs are acknowledged and addressed by policymakers at the local, state, and federal levels. While the proposed regulations are limited to the use of federal funds, they represent yet another attempt to chill the effectiveness of nonprofits in promoting and defending our democracy.
In addition, the recommended provisions are likely to create unnecessary confusion given the already existing limitations on lobbying included in federal grant awards. By broadening the definition of lobbying in Section 200.450 to prohibit voter registration activities and “issue advocacy or public messaging that promotes or opposes a particular social, political, or public policy position unrelated to the statutory objectives or performance requirements,” and certain state-level executive branch advocacy, the proposed regulations would effectively prohibit a wide range of communications that are critical to discussions related to community needs and the provision of nonprofit services.
Because of the confusion these changes would create, and the high risk of silencing issue advocacy that is integral to effective program implementation, we oppose the proposed changes. Restricting federal support for advocacy activities would reduce the flow of valuable information to government officials and undermine evidence-based policymaking. It would also unnecessarily restrict activities that are otherwise permissible for nonprofit organizations.