Connecticut’s Department of Labor (CTDOL) has discovered a novel approach to state law: complying with it.
On May 13, Labor Commissioner Danté Bartolomeo emailed the co-chairs and ranking members of the legislature’s Labor and Public Employees Committee to notify them that CTDOL had sent labor organizations new instructions on their reporting obligations under Connecticut statute 31-77. The agency also created an online form for unions to submit annual financial reports.
This may sound like routine bureaucracy. It is not. It is the long overdue enforcement of a transparency law the Labor Department tried — twice — to erase.
Section 31-77 requires certain labor organizations operating in Connecticut with 25 or more members to file annual written reports with the labor commissioner and make those reports available to their membership.
CTDOL’s new instructions say reports must be filed within three months after the end of the calendar or fiscal year, submitted by the treasurer or chief financial officer, verified by oath, and made available to members during regular business hours. The reports are not open to the general public, but members may inspect the report of their own labor organization.
In other words, the department is now doing what the law already told it to do.
That matters because, for years, the statute was on the books but apparently not in practice. A 2021 Yankee Institute article reported that DOL had no record of receiving annual union reports, no record of levying fines, and no record of destroying reports under the statute.
The department’s legal director initially said, “To my knowledge, we have received no reports.”
That long gap is especially hard to justify because 31-77 is not some forgotten paperwork requirement. It is a worker-protection law written to answer a basic question: can union members see how their dues are being spent?
Connecticut adopted the original union financial-disclosure law in 1957, when congressional investigations into organized-labor corruption had put union finances under a national spotlight. The state acted two years before Congress passed the federal Labor-Management Reporting and Disclosure Act of 1959. The point was not paperwork for paperwork’s sake; it was accountability.
When Congress later created federal disclosure requirements for private-sector unions, Connecticut narrowed its law to avoid duplication. That left 31-77 to protect workers outside the federal system, especially public-sector union members bargaining under state law.
CTDOL later tried to solve its enforcement problem by making the law disappear.
In 2022, the department backed a “technical” bill that would have repealed 31-77 by listing it among statute numbers proposed for deletion, without explaining in plain English that the change would eliminate the union disclosure law. The effort failed.
The idea returned in 2026. This time, Bartolomeo argued that the reports were unnecessary because information was already available through IRS Form 990 and that enforcement would consume staff time over a statute carrying only a $25 fine.
That argument misses the point. Section 31-77 is not primarily about public disclosure. It requires covered unions to furnish sworn financial reports to their own members and gives members a path to request a state audit. Form 990 is a tax-exempt organization return, not a union-member transparency tool. Federal union-disclosure forms such as the LM-2 are built for labor organizations and generally provide more granular, union-specific financial information.
Yankee Institute’s 2026 testimony put it plainly: “The issue before the committee is not that Section 31-77 is flawed. The issue is that it has not been enforced.” The testimony warned that weakening the statute because compliance had lagged would only reward noncompliance.
The issue has now reached the courts.
In February, two Connecticut public employees — criminal justice professor Earl Ormond and corrections officer Ryan Bilodeau — sued their unions, alleging that union officials ignored the state transparency law while regulators failed to act. Ormond said, “It’s simple: I want to know where my money is going.” Bilodeau said that when members cannot get straight answers, trust in the union breaks down.
After years of pushback, testimony, and litigation, CTDOL has now taken the necessary steps: new instructions to labor organizations, an online submission portal, and clear notice that annual financial reports are not optional. These are the basic requirements the law has always demanded — nothing more.
But the celebration should be restrained. The state did not invent a new transparency reform. It stopped pretending an old one did not exist.
Frank Ricci, Yankee Institute’s labor fellow, argued that CTDOL’s reversal came only after outside pressure and legislative scrutiny. “Laws are worthless if the powerful can simply ignore them,” he said. “This statute exists to deter the misuse of funds and stamp out corruption — yet it was treated as optional by those sworn to uphold it.”
That is the real story here. Connecticut’s public-sector unions enjoy enormous privileges under state law. Government employers collect dues on their behalf. Union contracts shape public budgets. Union leaders exercise political influence at the Capitol. At minimum, members should be able to see how their own money is being used.
Transparency is not anti-union. It is pro-worker. Honest union leaders should have no fear of showing members the books. Members who pay dues should not have to hire lawyers, contact legislators, or embarrass a state agency into action simply to obtain records the law already guarantees.
Connecticut’s Labor Department deserves credit for finally enforcing the law — but not for needing years of scrutiny, testimony, litigation, and legislative resistance to remember that compliance was never optional.
