NYC Doing Business Data Form: What It Is and Who Files

The Doing Business Data Form is the City's campaign-finance disclosure for anyone bidding on or holding NYC business, and most transactions over $5,000 trigger it. Filing it doesn't automatically put you on the public database, but once your City business crosses the dollar thresholds, your owners and top managers face much lower campaign-contribution limits.

Check first: not sure your business is positioned to bid on City work yet? Run our free eligibility checker before you worry about the paperwork — it takes about two minutes and tells you where you stand.

The first time a City agency hands you a Doing Business Data Form, it looks like paperwork that has nothing to do with winning the contract. It isn't. The form is how New York City decides whether your company — and the people who own and run it — land in its public Doing Business Database. And being in that database quietly changes the rules for your principals, right down to how much they're allowed to give to a mayoral campaign. This guide explains exactly what the form is, when you have to file one, who you have to list, and why the City cares so much about it.

What the Doing Business Data Form actually is

The Doing Business Data Form, or DBDF, comes out of Local Law 34 of 2007, a campaign-finance reform law the City passed to track who does business with it. The idea behind the law is simple: when a company and its leadership profit from City contracts, the public should be able to see who those people are, and there should be guardrails on how much those same people can pour into the campaigns of the officials who hand out that work.

The form is the data-collection step. It gathers the names of the people who own and run your company and feeds them into the Doing Business Database, which is maintained by the Mayor's Office of Contract Services (MOCS). That database is not private. According to MOCS, it exists to give "the public, campaigns, and the City's Campaign Finance Board" information on the entities and individuals that do business with New York City.

There are two ways your information reaches the database. If your contract is sourced through PASSPort, the City's online procurement portal, the Local Law 34 certifications are built into PASSPort and you handle them there. For transactions that don't run through PASSPort — small-purchase awards, for example — and for the non-procurement dealings the law covers, the agency sends you a paper Doing Business Data Form that you complete and return to the office that issued it. If you're not yet set up in the City's portal, our PASSPort vendor enrollment walkthrough covers that step.

When you actually have to file one

You generally complete a Data Form (or the equivalent PASSPort certification) at the time of proposal and again at award — not months later, and not only after you win. MOCS treats most transactions valued at more than $5,000 as "business dealings" that require the form. Because the City adds up all the business you do or propose to do with it, that $5,000 line is measured across your dealings, not contract by contract in isolation.

A couple of transaction types are carved out. Awards made on an emergency basis and those made by "conventional" competitive sealed bid are generally excepted from the form requirement. For everything else — most contracts, concessions, franchises, grants, and the non-procurement dealings below — expect to file.

One wrinkle worth flagging if you bid as a team: a joint venture that does not yet exist has to submit a Data Form for each of its component firms. So if you're assembling a JV to go after a City solicitation, build the paperwork for every partner into your timeline rather than scrambling at submission.

Who actually ends up in the Doing Business Database

Here's the distinction that trips people up: filing a form is not the same as being listed on the public database. Plenty of vendors complete a Data Form and never appear publicly, because the City applies dollar thresholds before it lists you.

Per the MOCS Doing Business Q&A, an organization is considered to be doing business with the City — and therefore gets onto the public database — when it aggregates $100,000 or more in grants, contracts for goods or services, franchises, or concessions. For construction contracts, the threshold is higher, at $500,000. Separately, if you hold any economic development agreement, pension fund investment contract, real property transaction, or land use action — regardless of dollar value — you're considered to be doing business with the City and can be listed. Lobbyists are covered by the law as well.

In other words, the $5,000 figure governs when you have to file, and the $100,000 / $500,000 figures (plus the any-value non-procurement categories) govern when you actually get listed and the contribution limits below kick in.

Who counts as a "principal"

The form doesn't just ask about the company. It asks you to name the people behind it, in three categories.

Principal Officers are your Chief Executive Officer, Chief Financial Officer, and Chief Operating Officer — or, as MOCS puts it, "their functional equivalents." If your company doesn't use those exact titles, the equivalents still count: a President, Executive Director, or Board Chair for CEO; a Treasurer, Comptroller, or VP for Finance for CFO; a Director of Operations for COO.

Principal Owners are individuals who own or control 10% or more of the organization — stockholders, partners, and anyone else with an ownership or controlling interest. Since 2018, the form also captures organizations (not just individuals) that own 10% or more of your entity, so a parent company or an investing firm can show up here too.

Senior Managers are a catch-all for influence rather than title: anyone who, by job title or actual duties, "has substantial discretion and high-level oversight" over soliciting, letting, or administering a City contract, concession, franchise, grant, or economic development agreement. This one has teeth — at least one Senior Manager must be listed, or MOCS treats the form as incomplete. Don't leave it blank assuming it doesn't apply.

The real reason the City cares: campaign contributions

This is the part most vendors don't see coming. Local Law 34 limits the municipal campaign contributions that principal officers, owners, and senior managers of a doing-business entity are allowed to make. Once you and your principals are in the database, your personal giving to City candidates gets capped at the law's special "doing business" limits — and those limits are a fraction of what an ordinary New Yorker can give.

For contributions made while you have business dealings with the City, the doing-business limits run to $400 per election cycle for citywide offices (Mayor, Public Advocate, and Comptroller), $320 for Borough President, and $250 for City Council. For comparison, the Campaign Finance Board's standard 2025-cycle limits for those same offices were far higher — in the low thousands of dollars — so landing in the database can cut your principals' permissible giving by more than 80%.

There's a second sting. The Campaign Finance Board confirms that doing-business contributions are not eligible for matching funds and don't count toward a candidate's threshold to receive public money. So a contribution from someone in the database is both smaller and worth less to the candidate. If your leadership is politically active, this is a conversation worth having internally before — not after — your name hits the list.

How long you stay on the database, and keeping your form current

Being listed isn't permanent, but it outlasts the contract. For contract, concession, and economic development agreement holders, you generally stay on the database for the term of the transaction, plus one year. Franchise and grant holders are listed from the commencement or renewal of the transaction, plus one year. If you merely proposed and didn't win, you're typically listed for one year from the proposal date or the public advertisement of the solicitation, whichever is later. When your organization stops doing business with the City, the people associated with it are removed from the database automatically.

Between those milestones, your information can change — an officer leaves, an owner buys in, a senior manager moves on. The Data Form is built for this: it offers a Change option (you report only what's changed) and a No Change option. Separately, a dedicated Update Form lets an individual request removal, or lets your company update its information at a time other than proposal or award. MOCS doesn't publish a hard "within X days" clock for routine updates, so the safe practice is to update promptly whenever your principals change rather than waiting for your next bid. Treating the database like your City recertification filings — something you keep current on a schedule — will save you a fire drill later.

What to do before your next NYC bid

A little preparation turns this from a surprise into a checkbox. Before you respond to a solicitation, know in advance exactly who your principal officers, 10%-or-more owners, and senior managers are, and have their information ready so the form doesn't hold up your submission. Keep your PASSPort profile current so the Local Law 34 certifications flow automatically. Brief your leadership on the contribution limits so no one unknowingly trips the rules during an election year. And when you're reading the solicitation itself, watch for where the agency tells you to submit the Data Form — our guide to reading a NYC city RFP section by section shows you where these requirements usually hide. If you're chasing smaller awards, the $1.5M discretionary small-purchase lane still carries the same $5,000 form trigger.

The Doing Business Data Form rarely decides whether you win. But handled late or incompletely, it can delay an award or create a compliance headache you didn't need. Handled early, it's a non-event.

Want a second set of eyes on where you stand with the City? Start with our free eligibility checker, then book a certification and bid-readiness audit to map exactly what you need to file and when. If you're ready to move, our pricing lays out how we can run the paperwork — PASSPort, certifications, and forms like this one — so you can focus on the work.

Not legal advice — see our disclosures for full disclaimers.