SF-LLL: Disclosure of Lobbying Activities

Last verified: September 5, 2026. SF-LLL, “Disclosure of Lobbying Activities,” is the federal form a recipient of a covered contract, grant, loan, or cooperative agreement over $100,000 files — but only when it has actually paid a registered lobbyist with non-federal funds to influence that award. It implements the Byrd Anti-Lobbying Amendment, 31 U.S.C. § 1352. The distinction most sponsored-programs offices get backwards: nearly every applicant above the threshold has to make a certification; very few of them ever have to file the disclosure form itself, because most institutions do not pay a lobbyist with non-federal money in connection with a specific award.

When SF-LLL Is Required

31 U.S.C. 1352 sets two different dollar thresholds, and it is easy to apply the wrong one:

Covered action	Threshold	Statutory basis
Federal contract, grant, cooperative agreement, subcontract, or subgrant	Exceeds $100,000	31 U.S.C. 1352(d)(2)(B)
Federal loan or loan commitment	Exceeds $150,000 (or the single-family maximum mortgage limit for the affected program, whichever is greater)	31 U.S.C. 1352(d)(2)(C)

What Counts as a “Covered Federal Action”

The statute’s prohibition and its filing requirement both turn on whether a “covered Federal action” is involved. Under 31 U.S.C. 1352(a)(2), that means:

The awarding of any federal contract
The making of any federal grant
The making of any federal loan
The entering into of any cooperative agreement
The extension, continuation, renewal, amendment, or modification of any federal contract, grant, loan, or cooperative agreement

A competing renewal or a modification is covered just as much as the original award — the threshold and filing obligation can be triggered again at renewal even if nothing was owed at the original award.

Certification vs. Disclosure: the Distinction Most People Get Wrong

31 U.S.C. 1352(b)(1)–(2) actually describes a single “written declaration,” but the OMB flow-down language that implements it — 2 CFR 200, Appendix II, item (j) — splits it into two operationally distinct obligations, and conflating them is the single most common SF-LLL mistake:

	Certification	Disclosure (the SF-LLL form itself)
Who must do it	Every applicant/recipient above the threshold, at every tier, every time	Only a tier that actually paid a registered lobbyist with non-federal funds in connection with the award
What it states	“We have not used and will not use federally appropriated funds to pay anyone to influence this award.”	The name of the registered lobbyist, who they contacted, and what they were paid to do it
Triggered by	Simply requesting or receiving a covered action over the threshold	An actual lobbying payment made with non-appropriated funds
If nothing to disclose	Still required	Not filed at all — the certification alone satisfies the requirement

Per Appendix II(j): “Each tier certifies to the tier above that it will not and has not used Federal appropriated funds to pay any person or organization for influencing or attempting to influence” a covered action, and separately, “each tier must also disclose any lobbying with non-Federal funds that takes place in connection with obtaining any Federal award.” Most research institutions can truthfully make the certification and never need to touch the SF-LLL form itself — it exists for the minority of awards where a registered lobbyist actually was paid, from non-federal money, to work the specific award.

Appropriated vs. Non-Appropriated Funds — Why the Line Matters

The underlying prohibition in 31 U.S.C. 1352(a)(1) is narrower than most people assume: it bars using federally appropriated funds to pay anyone to influence a covered federal official in connection with a covered action. It does not prohibit an institution from lobbying with its own non-federal money — state appropriations, tuition, endowment income, private gifts. What non-appropriated-funds lobbying triggers instead is the disclosure obligation described above, not a violation. The statute also carves out two narrow, specific exceptions in 31 U.S.C. 1352(d)(1): reasonable compensation paid to a person’s own regularly employed officer or employee for agency and legislative liaison work not directly tied to a specific covered action, and reasonable payment for professional or technical services rendered in actually preparing a bid, proposal, or application. Both exceptions turn on facts specific to how a given position is funded and what it actually does — not on a blanket rule that in-house staff are always exempt.

Costs of lobbying itself are also separately unallowable as a direct or indirect charge to a federal award under 2 CFR 200 Subpart E — a related but distinct rule from the Byrd Amendment’s certification/disclosure regime. See our guide on 2 CFR 200 Subpart E cost principles and the unallowable cost dictionary entry for how the two interact.

Who Signs

The statute directs the “person” requesting or receiving the covered action to file the declaration (31 U.S.C. 1352(b)(1)); it does not name a specific job title. In practice, the awarding agency’s own instructions govern, and the person who signs is ordinarily the same individual who holds signature authority for the application or award on the organization’s behalf — not the principal investigator personally, unless that individual happens to also hold that institutional signing authority. Confirm the required signatory against the specific funding opportunity’s instructions or your institution’s own delegation-of-signature policy rather than assuming it defaults to the PI.

Subrecipients: How SF-LLL Flows Up to the Prime

2 CFR 200 Appendix II(j) makes the certification and disclosure requirements flow down through a pass-through entity’s entire chain of subawards and subcontracts, not just apply at the prime level:

Tier	Certifies to	Discloses (if triggered) to
Sub-subrecipient / lower-tier subcontractor	The tier immediately above it	The tier immediately above it
Subrecipient / subcontractor	The prime recipient (or its own pass-through entity, if there are more than two tiers)	Forwards its own disclosure, plus any it received from lower tiers, up the chain
Prime recipient	The federal awarding agency	Forwards its own disclosure and every disclosure collected from subrecipients to the federal awarding agency

The rule text puts it plainly: “Such disclosures are forwarded from tier to tier up to the non-Federal award.” A prime that never itself pays a lobbyist can still end up responsible for forwarding a subrecipient’s disclosure — subrecipient monitoring for Byrd Amendment compliance means confirming each subrecipient over the threshold has actually made its own certification, not just assuming silence means nothing to disclose.

When an Update Is Required — the Calendar-Quarter Trigger

31 U.S.C. 1352(b)(4)(C) requires a filer to submit an updated declaration “at the end of each calendar quarter in which there occurs any event that materially affects the accuracy of the information contained in any declaration previously filed.” Two things follow from that wording. First, this obligation only exists once an initial disclosure has actually been filed — an institution that only ever made the certification, with nothing to disclose, has no previously filed declaration whose accuracy could be affected, so there is no quarterly-update obligation running in the background. Second, the trigger is a material change to what was already disclosed (a new lobbyist engaged, a change in who was contacted, a materially different payment amount) — not every quarter automatically, and not a change that has nothing to do with the specific covered action.

Where the Form Goes

31 U.S.C. 1352(b)(1) directs the filer to submit the declaration “with that agency” — the federal agency making the award. Combined with the tier-to-tier flow-down described above, that means: a direct recipient files with its federal awarding agency, and a subrecipient or subcontractor files up its own chain until the disclosure reaches the prime recipient, who is responsible for getting the complete set to the agency. The statute does not specify a single universal office or portal, and agencies vary in exactly how they want it submitted (as an attachment to the application package, or through the agency’s own grants system) — check the specific funding opportunity’s instructions or your subaward agreement for the current channel rather than assuming a single answer holds government-wide. The current form itself is maintained by the General Services Administration as form SFLLL (most recently revised 07/1997).

Falsely Signing Either Document Is Its Own Exposure

Because the certification is itself a statement made to the federal government in connection with obtaining an award, signing it falsely can create exposure separate from 31 U.S.C. 1352’s own civil penalty — including under the False Claims Act, where a false certification tied to obtaining or retaining federal funds has been treated as its own basis for liability. See our guide on the False Claims Act in research grant compliance for how false-certification theories work more generally.

Where Each of These Requirements Is Written Down

Requirement	Authority	Where to read it
$100,000 threshold — contracts, grants, cooperative agreements, subawards	31 U.S.C. 1352(d)(2)(B)	Cornell LII, 31 U.S.C. 1352
$150,000 threshold — loans and loan commitments	31 U.S.C. 1352(d)(2)(C)	Cornell LII, 31 U.S.C. 1352
Prohibition on using appropriated funds to lobby a covered action	31 U.S.C. 1352(a)(1)–(2)	Cornell LII, 31 U.S.C. 1352
Certification-and-disclosure declaration requirement	31 U.S.C. 1352(b)(1)–(2)	Cornell LII, 31 U.S.C. 1352
Quarterly update trigger on material change	31 U.S.C. 1352(b)(4)(C)	Cornell LII, 31 U.S.C. 1352
Regularly-employed-officer and bid-preparation exceptions	31 U.S.C. 1352(d)(1)	Cornell LII, 31 U.S.C. 1352
Civil penalty, $10,000–$100,000 per violation	31 U.S.C. 1352(c)	Cornell LII, 31 U.S.C. 1352
Tier-to-tier certification and disclosure flow-down on grants/cooperative agreements	2 CFR 200, Appendix II, item (j)	Cornell LII, 2 CFR 200 Appendix II
The form itself (SFLLL, rev. 07/1997)	General Services Administration	GSA Forms Library

What This Page Cannot Tell You

Three things decide whether your institution actually has anything to disclose, and none of them are answerable from this article, because they depend on facts specific to your office and your award:

Whether your government-relations or federal-relations staff fall inside the “regularly employed officer” liaison exception in 31 U.S.C. 1352(d)(1)(A) — that depends on how the position is actually funded and whether its contacts are “directly related” to a specific covered action, not on the job title alone.
Whether a subrecipient on your award has already filed a disclosure sitting in a subaward file waiting to be forwarded — that depends on that subrecipient’s own lobbying activity, which this page has no visibility into.
Which office and format your specific funding agency wants the filing submitted through — the statute only says “file with that agency,” and agencies differ in the mechanics.

Checking this against the current guidance

Whether a specific payment to your institution’s government-relations office counts as reportable lobbying under 31 U.S.C. 1352 depends on how that person is paid and what the “regularly employed officer” exception actually covers — the page above states the general rule, not your funding structure.

Ask CASRAI: If a university’s in-house government-relations staff contact Congress about a specific NIH grant using non-federal (state or endowment) funds, does that trigger the SF-LLL disclosure requirement, or does the regularly-employed-officer exception in 31 U.S.C. 1352(d)(1) cover it — and does the answer change if part of that staff member’s salary is charged to F&A/indirect cost recovery?

It searches CASRAI’s indexed corpus of research-administration guidance and cites
the passage behind each claim, so you can open the source and check it rather than
take its word — and it says so when the corpus does not cover something instead of
guessing. Two questions a day are free while you are signed out, no
account and no card. Everything CASRAI publishes stays free to read.

Frequently Asked Questions

If a university’s in-house government-relations staff contact Congress about a specific NIH grant using non-federal (state or endowment) funds, does that trigger the SF-LLL disclosure requirement, or does the regularly-employed-officer exception in 31 U.S.C. 1352(d)(1) cover it — and does the answer change if part of that staff member’s salary is charged to F&A/indirect cost recovery?

This depends on facts this page can’t resolve for you: whether the specific activity qualifies as “agency and legislative liaison activities not directly related to” the award under 31 U.S.C. 1352(d)(1)(A), and how that staff member’s compensation is actually funded and allocated across the institution’s awards. Ask CASRAI to work through your specific facts against the statute and its implementing guidance.

What is the difference between the SF-LLL certification and the SF-LLL disclosure form?

The certification is a blanket statement, required of every applicant/recipient above the threshold, that no federally appropriated funds were or will be used to lobby a covered federal action. The disclosure — the SF-LLL form itself — is only filed when a registered lobbyist was actually paid with non-federal funds to work that specific award. Most institutions only ever do the former.

What is the dollar threshold for filing SF-LLL?

$100,000 for a federal contract, grant, cooperative agreement, subcontract, or subgrant; $150,000 for a federal loan or loan commitment (31 U.S.C. 1352(d)(2)(B)–(C)).

Who has to sign the SF-LLL form?

The statute names the “person” requesting or receiving the award, without specifying a title. In practice this is the individual who holds signature authority for the application or award on the organization’s behalf, per the awarding agency’s own instructions — confirm against the specific funding opportunity rather than assuming it is always the principal investigator.

Does a subrecipient have to file its own SF-LLL?

If the subaward exceeds $100,000 and the subrecipient paid a registered lobbyist with non-federal funds in connection with it, yes — and that disclosure is forwarded up the subaward chain to the prime recipient, who is responsible for getting it (along with the prime’s own, if any) to the federal awarding agency (2 CFR 200, Appendix II(j)).

When do I have to update or amend a previously filed SF-LLL?

At the end of any calendar quarter in which an event materially affects the accuracy of a declaration you already filed (31 U.S.C. 1352(b)(4)(C)). If you never filed an initial disclosure because you had nothing to disclose, there is nothing to update.

Can federal grant money ever be used to pay a lobbyist?

No — 31 U.S.C. 1352(a)(1) prohibits using federally appropriated funds to pay any person to influence a covered federal action, subject only to the narrow exceptions in (d)(1) for a regularly employed officer’s liaison work not directly tied to a specific action, and for professional/technical services in actually preparing a bid or application.

What happens if a required SF-LLL disclosure isn’t filed?

31 U.S.C. 1352(c) sets a civil penalty of not less than $10,000 and not more than $100,000 for each prohibited expenditure or each failure to file or amend a required declaration, and the statute allows the government to pursue additional remedies.

SF-LLL: Disclosure of Lobbying Activities Under the Byrd Amendment