New Jersey’s Pay-to-Play Annual Disclosure filing deadline is imminent. By March 31, 2014, all for-profit businesses that have received aggregate payments of $50,000 or more during the 2013 calendar year as a result of New Jersey government contracts (at the state, county or local level) must file Form BE electronically with the New Jersey Election Law Enforcement Commission. Even if you have no contributions to report, if your company meets the $50,000 threshold, you are required to file an ELEC Annual Disclosure.
This filing requirement has been in effect since 2006. All businesses that meet the $50,000 threshold should be following a compliance plan that accurately tracks covered contracts and contributions and facilitates reporting. Now is the time to move from tracking into full filing preparation mode. It is also a good time for conducting an annual audit to ensure that all contributions are in full compliance with applicable law and that no contributions jeopardize eligibility for any government contract.