A PR Firm in San Francisco That Checks the Ethics Meter First

Updated November 2026 · Written and maintained by the Progression Agency strategy team

A PR lead emails a supervisor’s aide about a client’s permit appeal, one polite paragraph, and under San Francisco’s rules one paid contact for a client in a month is enough to make that person a contact lobbyist. A media push that urges neighbors to write to the Board can count too, once spending passes $2,500 in a month. A PR firm in San Francisco has to run that meter before it plans the first event. This page walks through one campaign line by line, then what it costs. Progression is based in New York, works with Bay Area companies remotely, and offers on-site sessions on request.

One email to a supervisor’s aide

The email is short and polite. It asks an aide for ten minutes on a client’s permit appeal. Nobody is lobbying in the way people picture it; there is no meeting in a hallway and no speech. The Ethics Commission’s guidance still counts a communication, oral or written, made to influence a local legislative or administrative action.

The card is a hypothetical example. What it shows is the arithmetic: one paid contact for a client in a calendar month. For a person paid by an employer the guidance uses five contacts. The Commission’s guidance defines officers to include elected officials, appointed officials and job titled named staff, so whether an aide counts is a question for the Commission, not for a hunch.

• A short email can be a contact.
• The count is by month and by the person paid.
• The first contact does not wait for a title or a registration form.
• The question about an aide goes to the Commission’s staff.

What a PR firm in San Francisco must know about contact lobbyists

The Ethics Commission’s guidance on contact lobbyists says a person qualifies as a contact lobbyist if paid to contact a City officer to influence local legislative or administrative action five times in a calendar month on behalf of an employer, or one time in a calendar month on behalf of a client. Contact lobbyists must register within five business days of qualifying and may not make additional contacts until they register.

The guidance defines a contact as any communication, oral or written, including through an agent, with an officer of the City made to influence local legislative or administrative action. It defines lobbyist services as services rendered to influence such action, including contacting, preparing for contacts, analysis, research, advice and strategy.

Local legislative or administrative action, in the guidance, includes the drafting, consideration, enactment, defeat, approval, veto, granting or denial of a resolution, motion, appeal, application, petition, ordinance, amendment, approval, referral, permit, license, entitlement or contract.

How are contacts counted?

A meeting with an officer on one action is one contact, and a meeting on two actions is two. A meeting with an officer and a member of that officer’s staff on one action is one contact with that officer, a meeting with two officers on one action is two contacts, and several conversations in one day on the same action count as one.

What if the PR firm only prepares the client?

Preparing for contacts is itself listed as lobbyist services. Whether that makes anyone a registered lobbyist depends on who makes the contacts and how many, so ask counsel and the Commission before the work starts.

The campaign meter, line by line

A hypothetical campaign for a client’s permit appeal has nine lines. For each, the table says whether spending on it counts toward the $2,500 line, whether it makes a contact and who should check before it happens.

Spending that pushes others to call the City

The Commission’s examples of spending that counts are public relations, media relations, advertising, public outreach, research, investigation, reports, analysis and studies, to the extent they are used to solicit, request or urge other persons to communicate directly with a City officer. The test is what the spending is used for.

Spending that stays outside the meter

The guidance lists payments made to a registered contact lobbyist who directly contacts City officers, membership dues, payments by an organization to distribute communications to its members, payments by a news media organization to develop and distribute its publications, payments to a representative to appear in a legal proceeding before a City agency, and salary paid by an employer to an employee for those activities.

The month the meter resets

Both rules count by calendar month. Spending and contacts start again on the first of the next month, but registration, once required, does not go away with the calendar. Ask the Commission when a registration can end.

Who City officers are for this rule

The two guidance pages use different wording, and both matter. The expenditure guidance says City officers include elected City officials, members of City boards and commissions, and City department heads. The contact guidance says officers of the City and County are elected officials, appointed officials and job titled named staff.

Reporters are not officers in either list. A briefing to a reporter is not a contact with an officer, but the story may still matter to the expenditure line if the campaign around it urges readers to contact one.

Registering before the next email

Contact lobbyists register with the Commission within five business days of qualifying and make no further contacts until they have. Expenditure lobbyists register online no later than five business days after qualifying and before making additional payments. The registration guidance says an expenditure lobbyist may have a representative or firm register and file reports on its behalf.

• The fee is $500 at registration and $500 each year by February 1.
• The Commission waives the fee for 501(c)(3) nonprofits that file a Form 990-EZ or 990-N or show an annual budget of $500,000 or less.
• Failure to pay the annual fee by February 1 ends the registration.
• Monthly reports are due on the fifteenth, and a weekend or City holiday moves the date to the next business day.

The reporting guidance says the monthly report must be filed even if there is no activity, and that it covers payments to influence, total payments, matters lobbied and political contributions of $100 or more made or raised. The expenditure guidance lists the spending that counts.

What if the meter is already over?

The guidance says to register before making additional payments, so call the Commission and counsel at once. They can tell you where you stand and what to file.

Media relations that never asks anyone to write

A story placed for awareness, with no call to contact officers, does not ask anyone to do anything. The counting rule turns on urging others to contact officers, so the call to action in the copy decides more than the channel. PR agencies in San Francisco can use the same test on every release, and counsel should read the final copy before anyone relies on it.

• Write the story for the reader, not for the officer.
• Keep any ask to contact officers out of the release and the briefing.
• Put the call to action, if any, on a separate line item and track it.
• Ask counsel to read the final copy.

Can a website page carry both?

A page that explains the matter and a page that urges visitors to email officers are different line items. Keep them apart so the cost of the second one can be totaled.

When the client should hire a registered lobbyist

Payments to a registered contact lobbyist who directly contacts City officers do not count toward the $2,500 line. When a matter needs direct contact with officers, splitting the work so a registered lobbyist makes the contacts and the PR team handles the story keeps the two meters apart.

• Decide who makes any contact with an officer before the work starts.
• Pay the lobbyist under a separate agreement.
• Keep the PR scope to stories and outreach that do not ask readers to contact officers.
• Ask counsel whether the split fits your facts.

This page reaches no conclusion about any client’s duties. The Ethics Commission answers registration questions, and counsel answers questions about your facts.

The note in every San Francisco statement of work

Four lines at the top of the scope keep the meter in view for the whole project. Copy them into your own scope of work and fill them in.

• State whether a City decision is involved.
• Name the people who may contact officers.
• Total the month’s outreach spending each week.
• Name the person who files, and the date.

Our public relations agency page describes the press work itself, and advertising in San Francisco covers paid media.

What does a San Francisco PR scope cost?

The cost depends on the number of stories, the outreach channels and how much tracking the meter needs. Published market bands show the range you will see in quotes.

Progression’s PR retainers

Our public relations agency page publishes its own retainers under the heading How we price it. They sit apart from the market figures above.

The price has no San Francisco premium and no charge per contact. The City’s registration fee is a fee to the City and not part of any Progression price. Pricing depends on scope and is confirmed in a written proposal; published prices are subject to change.

What should a client tell the PR team before the work starts?

The meter only works if the people running it know the facts. A short briefing at the start saves a hard conversation in the middle of the month.

• Which City decision is pending, and who decides it.
• Whether anyone has already contacted an officer this month, and for whom.
• Which ads, mailers and events are planned, and what each asks of readers.
• Who at the client pays for the work, and whether that person is an employer or a client in the Commission’s sense.
• Whether the client already has a registered lobbyist.
• Who will approve every piece of copy before it goes out.

Who decides whether a line asks readers to act?

The person who approves the copy, with counsel in the loop. Put that name in the scope so the decision is never left to whoever sends the file.

Should the client see the meter?

Yes. Share the sheet weekly. A client who sees the total move toward $2,500 can decide what to cut before the month ends.

Related services and guides

Pages that sit beside this meter:

• Public relations agency
• Tech PR agency
• Marketing agency in San Francisco
• Advertising agency in San Francisco

Frequently asked questions