Cooling off period
Definition
A mandatory waiting period before a former government official can lobby their old colleagues. For Congress it runs one year for former House members and two years for former senators. Executive branch rules vary by seniority and agency.
Why it matters
The rule is meant to blunt the most direct form of the revolving door, a lawmaker becoming a lobbyist the week after leaving office. In practice, former officials can join a lobbying firm immediately as long as they avoid personally contacting covered officials or using their own name, a "shadow lobbyist" role the law does not clearly reach.
Seen in the wild
The bipartisan BLAST Act, reintroduced in 2025 by Senators Elizabeth Warren and Rick Scott, would replace the temporary cooling-off period with a permanent ban on former members of Congress ever registering as lobbyists, arguing the current one- and two-year windows are too easily worked around through informal advising roles.1