General
Political Activity and Lobby Guidelines for Catholic Organizations (2020)
Political Activity Lobbying Guidelines updated 07-21-2020
The USCCB Office of General Counsel is providing these guidelines to (arch)dioceses, parishes, and other Catholic organizations to assist them in distinguishing activities that are permitted during election campaigns from activities that are prohibited. The guidelines also address the distinction between educational activity and lobbying under federal tax law. The latter is restricted but not prohibited.
The intended audience is Catholic organizations included in the USCCB group ruling that are exempt from federal income tax under section 501(a) of the Internal Revenue Code (“Code”) and described in section 501(c)(3). State Catholic conferences that are separately incorporated as section 501(c)(3) organizations, structured as activities (rather than as separate legal entities) of one or more dioceses, or which are separately incorporated as section 501(c)(4) organizations but whose revenue is derived solely from assessments paid by constituent dioceses, are subject to the section 501(c)(3) rules. Therefore, the primary focus is on section 501(c)(3), which prohibits participation or intervention in a political campaign on behalf of or in opposition to any candidate.
General guidance cannot anticipate every conceivable fact pattern, nor can it substitute for the advice Catholic organizations should seek from their own attorneys. Because interpretation of the political campaign intervention prohibition is inherently fact-specific, it frequently presents close questions that should be resolved with the advice of diocesan legal counsel prior to engaging in potentially problematic activities.