COVID-19 Update: New Jersey ELEC Issues Grace Period for Form BE Annual Pay-to-Play Disclosure Filing Deadline

The statutory filing deadline for the Form BE annual pay-to-play disclosure in New Jersey, which requires each business entity that received payments of $50,000 or more (in the aggregate) as a result of New Jersey government contracts during the 2019 calendar year to disclose its government contracts and political contributions, is set for Monday, March 30, 2020.

Recognizing that the COVID-19 pandemic has resulted in business closures and stay-at-home orders, the New Jersey Election Law Enforcement Commission (ELEC) has for the first time instituted a grace period for government contractors that are not able to file by the March 30 deadline.

While ELEC still encourages all filings to be submitted by the March 30 deadline where possible, ELEC is now providing a grace period for business entities that, due to closures during this public-health emergency, may not have access to their records or are facing other challenges that make a timely filing impossible.

To make use of this grace period, government contractors are required to contact ELEC via email. Supplemental communications may be submitted to ELEC as additional information regarding closure duration becomes known.

For ELEC assistance or counsel, contact Avi Kelin, Esq., Corporate Political Activity Specialist.