How to Report Behested Payments: Form 803, Deadlines, and Penalties

If you are a California elected official or a Public Utilities Commission member, you report behested payments by filing FPPC Form 803 with your own agency within 30 days after payments from a single source total $5,000 or more in the same calendar year. Once that threshold is crossed, every additional payment from that source for the rest of the year needs its own Form 803, filed within 30 days of the payment date.¹

When the Reporting Duty Starts

Disclosure is not triggered by a single donation amount. It is triggered when payments from one source add up to $5,000 or more in a calendar year at the official’s request.¹

The math is cumulative. Four $1,500 gifts from the same company across the year total $6,000 and cross the line, even though no single payment reached $5,000. It also does not matter whether the money went to one recipient or was split among several organizations at your request. What counts is the total from one payor in one year.

After a payor crosses that mark, every later payment from the same payor must be reported for the rest of the calendar year, no matter how small. A $500 follow-up gift in November needs its own report if the donor already crossed $5,000 in March.¹

The obligation is personal to the official who made the request. If more than one official jointly solicited a payment, each is independently responsible for filing.¹

The 30-Day Deadline

You have 30 days after the payment that meets or exceeds the $5,000 aggregate to file. For each subsequent payment from that same source, the 30-day clock restarts on the date of that new payment.¹ Officials with active fundraising for the same charities from the same donors can end up filing several Form 803s across the year.

What Form 803 Requires

The Fair Political Practices Commission publishes Form 803, the Behested Payment Report, for these filings.² Section 84224 sets out the information the form collects:

Your full name, address, and contact information as the behesting official.
The full name and address of the payor.
The full name and address of the payee that received the funds.
The dollar amount and date of each payment.
A description of the goods or services provided and the specific purpose or event the payment supports.

Take the purpose description seriously. “Community support” invites follow-up questions. Naming the actual program, event, or beneficiary — a summer reading initiative at a named library, a free health screening in a specific neighborhood — does the work the form is asking for.

Extra Disclosures for Relationships and Pending Matters

Some situations demand more than the basic fields. If you, an immediate family member, or a member of your campaign or officeholder staff holds a decision-making role, salaried position, founding membership, or advisory board seat at the recipient organization, disclose that relationship on the form with a brief explanation.³ This is where the largest FPPC penalties have landed.

You also have to flag payments where the donor is the named party or subject of a proceeding before your agency at the time of the payment or within the prior 12 months.³ A developer with a permit application pending before your council, who then donates to a charity at your request, fits that description. The payment itself is not banned; the overlap simply has to be visible.

One boundary worth knowing: the “public appeal” exception, which lets officials solicit through speeches, press releases, or social media without triggering a report, does not apply when you or a close associate holds a role at the recipient organization.³ Framing a request as a general appeal does not sidestep the duty when you are on the charity’s board.

Where to File and What Happens Next

File Form 803 with your own agency, not directly with the FPPC. State agencies and the Public Utilities Commission have 30 days to forward a copy to the FPPC. Local agencies forward copies to the filing officer who receives your campaign statements.¹ Filed reports are public records. The FPPC publishes state-level reports in a searchable online database that covers members of the legislature and statewide elected officers.

Penalties for Late or Missing Reports

The FPPC can impose administrative penalties of up to $5,000 per violation of the Political Reform Act.⁴ For behested payment reporting, the FPPC’s streamlined enforcement process sets penalties at $200 to $600 per report for less serious violations and $800 to $1,200 per report for more serious ones.⁵

Per-report figures compound quickly when reports go unfiled across years. The FPPC’s enforcement record includes:

Kevin Johnson, then Sacramento mayor, penalized $37,500 for failing to report over $3.5 million in behested payments across four years.
Tony Rackauckas, a district attorney, penalized $21,000 for missing timely reports on 14 payments of $5,000 or more to a nonprofit he led.
Evan Low, an assemblymember, penalized $106,000 for failing to report 16 payments totaling $227,500 connected to nonprofits where he or his chief of staff held leadership roles.²

The pattern in the larger cases is consistent: officials who both solicit funds and hold a role at the receiving organization draw the steepest consequences.

1
California Legislative Information. California Code Government Code 84224
2
California Fair Political Practices Commission. Reporting Behested Payments – Form 803
3
California Fair Political Practices Commission. Behested Payment Reporting Fact Sheet
4
California Fair Political Practices Commission. 2026 Political Reform Act – Section 83116
5
New York Codes, Rules and Regulations. 2 CCR 18360.3 – Penalties in Streamline Cases