HOUSE OF REPRESENTATIVES STAFF ANALYSIS
BILL #: CS/HB 7067 PCB PIE 22-04 Ethics Reform
SPONSOR(S): State Affairs Committee, Public Integrity & Elections Committee, Byrd
TIED BILLS: IDEN./SIM. BILLS:
REFERENCE ACTION ANALYST STAFF DIRECTOR or
BUDGET/POLICY
CHIEF
Orig. Comm.: Public Integrity & Elections 17 Y, 0 N Rubottom Rubottom
Committee
1) State Affairs Committee 21 Y, 0 N, As CS Skinner Williamson
SUMMARY ANALYSIS
The Code of Ethics for Public Officers and Employees establishes ethical standards for public officials and is
intended to ensure that public officials conduct themselves independently and impartially. The Commission on
Ethics (Commission) is an independent commission that maintains financial disclosure filings of constitutional
officers and state officers and employees, administers fines for late filed required annual financial disclosures,
administers the Executive Branch Lobbying Registration and Reporting Law, among other duties.
The bill makes several changes to current ethics and lobbying laws, including:
 Requiring certain candidates for elective office to file required annual financial disclosure forms at the
time of qualifying for office.
 Requiring specified ethics training for members of the governing board of a special district or water
management district, providing requirements for such training, and specifying course content.
 Requiring ethics training to be certified on annual financial disclosure forms as completed and requiring
such forms to list the name of the training provider.
 Providing that contractual relationships held by a business entity are deemed to be held by a public
officer or employee under certain circumstances.
 Revising local government voting conflict provisions.
 Clarifying certain provisions relating to electronic filing of disclosures of financial interests beginning in
2023.
 Provides a five-year statute of limitations for collecting late penalties for late filed annual financial
disclosure forms.
 Repeals certain restrictions on state, state university, and community college employees lobbying the
Legislature.
 Requires executive branch lobbying registration to be electronically registered with the Commission and
makes additional changes to the executive branch lobbyist registration process.
The bill has an indeterminate fiscal impact on the state and local governments. See Fiscal Analysis &
Economic Impact Statement.
The bill has an effective date of July 1, 2022, except where otherwise expressly provided in the bill.
This docum ent does not reflect the intent or official position of the bill sponsor or House of Representatives .
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 FULL ANALYSIS
I. SUBSTANTIVE ANALYSIS
A. EFFECT OF PROPOSED CHANGES:
Commission on Ethics
The Commission on Ethics (Commission) was created by the Legislature in 1974 “to serve as guardian
of the standards of conduct” for state and local public officials and employees. 1 The state constitution
and state law designate the Commission as the independent commission provided for in s. 8(f), Art. II
of the state constitution.2 Constitutional duties of the Commission consist of conducting investigations
and making public reports on all breach of trust complaints towards public officers or employees not
governed by the judicial qualifications commission. 3 In addition to its constitutional duties, the
Commission, in part:
 Renders advisory opinions to public officials;4
 Makes recommendations to disciplinary officials when appropriate for violations of ethics and
disclosure laws;5
 Administers the Executive Branch Lobbying Registration and Reporting Law;6
 Maintains financial disclosure filings of constitutional officers and state officers and employees; 7
and
 Administers automatic fines for public officers and employees who fail to timely file required
annual financial disclosure.8
The Code of Ethics for Public Officers and Employees
The Code of Ethics for Public Officers and Employees (Code of Ethics) 9 establishes ethical standards
for public officials and is intended to ensure that public officials conduct themselves independently and
impartially, not using their offices for private gain other than compensation provided by law. 10 The Code
of Ethics pertains to various ethical issues, such as ethics trainings, voting conflicts, full and public
disclosure of financial interests, standards of conduct, the Commission on Ethics, among others. 11
Disclosure of Financial Interests
Present Situation
The Florida Constitution requires all elected constitutional officers, candidates for such offices, and
statewide elected officers, to file a full and public disclosure of their financial interests. Other public
1 Florida Commission on Ethics, Guide to the Sunshine Amendment and Code of Ethics for Public Officers and
Employees, available at http://www.ethics.state.fl.us/Documents/Publications/GuideBookletInternet.pdf (last visited
February 13, 2022); See also S. 112.320, F.S.
2 Art. II, s. 8(i)(3), Fla. Const.; S. 112.320, F.S.
3 Art. II, s. 8(f), Fla. Const.
4 S. 112.322(3)(a), F.S.
5 S. 112.322(2)(b), F.S.
6 Ss. 112.3215, 112.32155, F.S.
7 S. 112.3144, F.S.
8 S. 112.31455, F.S.; see also Florida Commission on Ethics, Guide to the Sunshine Amendment and Code of Ethics for
Public Officers and Employees, available at http://www.ethics.state.fl.us/Documents/Publications/GuideBookletInternet.pdf
(last visited February 13, 2022).
9 See Pt. III, Ch. 112, F.S.
10 Florida Commission on Ethics, Guide to the Sunshine Amendment and Code of Ethics for Public Officers and
Employees, available at http://www.ethics.state.fl.us/Documents/Publications/GuideBookletInternet.pdf (last visited
February 13, 2022).
11 See Pt. III, Ch. 112, F.S.
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 officers, candidates, and public employees may be required to file a full and public disclosure of their
financial interests as determined by law.12
The term “full and public disclosure of financial interests” means the reporting individual must disclose
his or her net worth and the value of each asset and liability in excess of $1,000. The disclosure must
be accompanied by either a sworn statement which identifies each separate source and amount of
income which exceeds $1,000 or a copy of the reporting individual’s most recent federal income tax
return.13 Pursuant to general law, the Commission has created by rule CE Form 6 (Form 6), which is
used to make the required full and public financial disclosure.14
Individuals holding the following positions must presently file Form 6: governor; lieutenant governor;
cabinet members; legislators; state attorneys; public defenders; clerks of circuit courts; sheriffs; tax
collectors; property appraisers; supervisors of elections; county commissioners; elected
superintendents of schools; district school board members; Jacksonville City Council members
(including the mayor); compensation claims judges; Duval County superintendent of schools; Florida
Housing Finance Corporation Board members; Florida Prepaid College Board members; and each
expressway authority, transportation authority (except the Jacksonville Transportation Authority), bridge
authority, or toll authority created pursuant to Chapter 348 or 343, F.S., or any other general law.15
Reporting individuals are required to file Form 6 annually with the Commission by July 1. Additionally,
candidates for a constitutional office are required to make a full and public disclosure of their financial
interests at the time of qualifying.16
Beginning January 1, 2022, annual Form 6 disclosures filed with the Commission must be filed
electronically through an electronic filing system that is created and maintained by the Commission.17
Candidates will continue to file a copy of their Form 6 with the election office in which they file qualifying
papers.18
In addition to those filing a Form 6, current law requires a less detailed disclosure of financial interests
using the Commission’s CE Form 1 (Form 1). Form 1 must be filed by a large group of local officers,
including all officers holding elected positions in any political subdivision of the state, other than
counties, and specified appointed officers. Other persons filing Form 1 include specified state officers
and employees and persons seeking to qualify as candidates for state or local office.19
Form 1 requires the individual disclose their primary sources of income from which they receive over
$2,500 of gross income as well as secondary sources of income if the filer owned more than 5% of the
total assets or capital stock of a business entity and the filer received more than $5,000 of gross
income during that disclosure period from the business entity. Form 1 filers must also disclose Florida
real property interests in excess of 5% of the property’s value, and intangible personal property that
was worth more than $10,000 identifying the business entity to which the property related. These filers
must also disclose each liability in excess of $10,000 including the name and address of the creditor
when owed at any time during the disclosure period. 20 Until the end of 2022, filers may make their
disclosure using alternate thresholds based on a percentage of gross income, total assets, or net
12 Id. See ss. 112.3144(1)(b) and 112.3145, F.S.
13 S. 8(i)(1), Art. II, Fl. Const. (schedule in effect until changed by law); s. 112.3144, F.S. (clarifying and limiting
disclosure).
14 S. 112.3144(8), F.S.; See R. 34-8.002, F.A.C.
15 Florida Commission on Ethics, Guide to the Sunshine Amendment and Code of Ethics for Public Officers and
Employees, available at http://www.ethics.state.fl.us/Documents/Publications/GuideBookletInternet.pdf (last visited
February 12, 2022).
16 S. 112.3142(2)(a), F.S.
17 S. 112.31446, F.S.
18 Ss. 99.061(5) and 99.061(7)(a)5., F.S.
19 Id.; See S. 112.3145, F.S.
20 S. 112.3145(3)(b), F.S.
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 worth.21 Form 1 must be filed annually with the Commission by July 1. Beginning January 1, 2023 Form
1 must be filed electronically.
All Form 6 filers and Form 1 filers must file quarterly reports naming clients represented for a fee or
commission, except for appearances in ministerial matters, before agencies at the filer’s level of
government.22 Many Form 6 and Form 1 filers must also certify their completion of any required ethics
training on their respective financial disclosure form. 23
Candidate Qualifications Respecting Financial Disclosures
Under the Election Code, at the time of qualifying for office, each candidate for a constitutional office
must file a full and public disclosure of financial interests pursuant to s. 8, Art. II of the State
Constitution, which must be verified under oath or affirmation, and a candidate for any other office,
including local elective office, must file a statement of financial interests. 24 When a candidate has
qualified for office prior to the deadline to file an annual financial disclosure, the disclosure filed with the
candidate’s qualifying papers is deemed to satisfy the annual disclosure requirement. 25
Beginning January 1, 2023, under the Code of Ethics, an incumbent in an elective office or a candidate
holding another position subject to an annual filing requirement may submit a copy of the financial
disclosure form filed with the Commission, or a verification or receipt of the filing, with the officer before
whom he or she qualifies.26 A candidate not subject to an annual filing requirement does not file with
the Commission, but may complete and print the appropriate financial disclosure form to file with the
officer before whom he or she qualifies.27
Under the Elections Code, in order for a candidate to be qualified for nomination or election to office,
the filing officer must receive the full and public disclosure or statement of financial interests by the end
of the qualifying period.28 This provision appears inconsistent with the verification or receipt provisions
in the Code of Ethics. If the filing officer receives qualifying papers during the qualifying period prior to
the last day of qualifying, which do not include all statutorily required items, the filing officer must make
a reasonable effort to notify the candidate of any missing or incomplete items and must inform the
candidate that all required items must be received by the close of qualifying. 29
Effect of Proposed Changes
The bill adds candidates qualifying for constitutional or other elective office subject to an annual Form 6
filing requirement to the list of those that must file Form 6 prior to running for the office. It permits these
candidates to submit a verification or receipt of electronic filing if they have filed an annual financial
disclosure electronically with the Commission.
The bill clarifies that Form 1 and any other form required by s. 112.3145, F.S., except a statement of a
candidate not subject to an annual filing requirement, must be filed electronically through an electronic
filing system created and maintained by the Commission. The bill clarifies other provisions with respect
to certain notices and the role of supervisors of elections pending the 2023 transition to electronic filing
of annual Form 1 disclosures.
The bill exempts a member of a judicial nominating commission (JNC) who holds no other state office
from filing a quarterly report with the Commission that names clients represented for a fee or
21 S. 112.3145(3)(a), F.S.
22 S. 112.3145(6), F.S.
23 S. 112.3144(1)(a), F.S.
24 S. 99.061(5), F.S.
25 Ss. 112.3144(3), 112.3145(2)(a), F.S.
26 Ss. 112.3144(4), 112.3145(2)(c), F.S.
27 S. 112.3144(4), F.S.
28 S. 99.061(7)(a)5., F.S.
29 S. 99.061(7)(b), F.S.
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 commission, except for appearances in ministerial matters, before agencies at the member’s level of
government.
The bill co-locates all provisions related to ethics training and beginning January 1, 2023, requires all
members of the governing board of a special district or water management district to complete 4 hours
of ethics training. The bill requires these individuals to certify on their full and public disclosure of
financial interests that such ethics training has been completed. Beginning January 1, 2023, the bill
requires the name of the training provider to also be provided and specifies that failure to do so does
not constitute an immaterial, inconsequential, or de minimis error or omission.
The bill specifies the course content that must be offered as part of ethics training and encourages
training providers to seek accreditation from an applicable licensing body for courses offered.
The bill provides that through December 31, 2022, local officers must file their statement of financial
interests with the supervisor of elections of the county where they permanently reside and for local
officers that are not permanent residents in any county in the state, statements of financial interests
must be filed with the supervisor of elections in the county where their agency is headquartered.
Effective January 1, 2023, the bill specifies that a statement of financial interests and a final statement
of financial interests, and any amendments, or any other required form, except any statement of a
candidate not subject to an annual filing requirement, must be filed electronically through the
Commission’s electronic filing system.
Beginning January 1, 2023, delinquency notices may not be sent by certified mail. The bill also reduces
the statute of limitations for collection of fines for late filing financial disclosures to five years for persons
who are not public officers or employees measured from the later of the final order or vacation of public
office or employment.
State Employee Lobbyists
Present Situation
State law regulates aspects of legislative lobbying by state employees. 30 Employees of non-public
entities are only required to register as lobbyists if they are employed and receive payment for the
purpose of lobbying or are principally employed for governmental affairs by another person or
governmental entity to lobby on behalf of that other person or governmental entity.31 However, any
state, state university, or community college employee who seeks to encourage the passage, defeat, or
modification of any legislation by personal appearance or attendance before the