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Red Il Grembiale Milano apron tied with a black satin ribbon on a marble board, with a yellow envelope and pen for a handwritten note to a client
By Mona Bavar, Founder, DLISH · Updated October 24, 2026
The short answer
If a client cannot accept a gift, the limit almost always comes from one of three places: their employer's gift policy, a rule for their industry, or a government ethics rule. Find out which one applies before you choose anything. Then either stay under the limit, send something the whole team shares, send a handwritten note with no gift, or replace the gift with an experience or a later date. In 2026 the main numbers are $300 a year for gifts from broker-dealers to clients' employees under FINRA, and, for US federal employees, $20 per source per occasion with no more than $50 a year from the same source.
It usually surfaces a day before the order deadline: legal says half the client list cannot accept gifts. It is rarely the whole list. It is the bank, the hospital, the city agency and the one client in the middle of a bid. The gift budget is approved, the boxes are chosen, and now nobody is sure what is allowed.
This guide explains what to check and what to send instead. It covers the limits that apply to the recipient, not the tax rules for the sender. For those, read the IRS $25 rule for corporate gifts, and for gifts that cross a border, FCPA rules for international corporate gifts.
This is practical guidance from a gifting company, not legal advice. Rules change and every policy is different, so confirm with the recipient's company or your own counsel before you send anything that matters.
| Who receives the gift | Rule | Limit |
|---|---|---|
| US federal employee | Federal ethics rules, 5 CFR 2635.204 | $20 per occasion and $50 a year from the same source. No cash or gift cards. |
| Employee of a firm whose broker-dealer sends the gift | FINRA Rule 3220 | $300 per person per year since March 30, 2026, valued at cost without tax or delivery. |
| Pension plan fiduciary (ERISA) | US Department of Labor policy | Gifts from one source worth less than $250 in total are treated as insubstantial. |
| Union official | US Department of Labor reporting | Must be reported to the Department of Labor unless worth less than $250 and unrelated to their union role. |
| California state or local official | California FPPC rules | $630 a year for 2025 and 2026; $10 a month from registered lobbyists. |
| Health care professional, from a pharmaceutical company | PhRMA Code on Interactions with Health Care Professionals (effective January 1, 2022) | No non-educational or personal-benefit items, and no cash or gift certificates. Occasional educational items only, of $100 or less. |
| Bank or credit union employee | Bank Bribery Act, 18 U.S.C. 215 | No dollar limit in the law. It prohibits corruptly giving anything of value to influence or reward an employee in connection with the institution's business. Each institution sets its own gift policy. |
| Foreign official | FCPA | See our FCPA guide. |
| Anyone at a company with a gift policy | Their employer's policy | Whatever the policy says. Some cap the value, some require approval, some ban gifts. |
Sources are listed at the end of this article. Checked October 2026.
Before you change the gift, ask three questions. They take one email and save the whole program.
The simplest way to find out is to ask the client's assistant or office manager: "Does your company have a gift policy we should follow?" Nobody is offended by the question. Most people are relieved you asked.
Most limits are not laws. They are the recipient's own employer policy. Some cap the value of any gift an employee may accept, some require the gift to be reported or approved, and some only allow gifts that are shared with the team. Ask for the number, then work inside it. A policy limit is not a reason to send nothing; it is a budget.
Two details trip people up. Many policies count the retail value of the gift, not what you paid. And many count every gift from your company over the year, not each gift separately, so the summer gift and the holiday gift add up.
FINRA Rule 3220 limits gifts from broker-dealers and their people to employees of other firms, such as an institutional client. On March 30, 2026 the limit went from $100 to $300 per person per year, the first increase since 1992. Gifts are valued at cost, without tax or delivery, and every gift from the firm and its people to the same recipient over the year counts toward the $300. The rule does not apply to gifts to individual retail clients, although many firms set their own limits for those.
Some gifts sit outside the $300 limit: customary gifts for a wedding or the birth of a child that are personal and not paid for by the firm, bereavement gifts, small promotional items with the firm's logo, and decorative items that commemorate a closed deal. Other rules can be stricter. Gifts to a pension plan fiduciary are treated as insubstantial only under $250 in total from one source, and gifts to union officials of $250 or more must be reported to the Department of Labor.
In practice: for a client at an institutional firm, a gift up to $300 a year now works, which covers most of our luxury gift boxes. Keep the receipt and the per-recipient value, because the sending firm has to record it.
US federal employees may accept unsolicited gifts worth $20 or less per occasion, up to $50 a year from the same source, and never cash or gift cards. If a gift is worth more than $20, they cannot pay the difference to keep it. In practice that means a card, or a single small item well under $20.
State and local rules vary widely. In California, for example, state and local officials may accept up to $630 a year from a single source in 2025 and 2026, but only $10 a month from a registered lobbyist, and they may have to report what they accept. Check the rule for the specific state, city or agency before you send.
For pharmaceutical company interactions with health care professionals, the PhRMA Code says non-educational items should not be offered to health care professionals or their staff, even practice-related items of minimal value such as pens or mugs. Items for their personal benefit, such as flowers, artwork or event tickets, should not be offered either, and neither should cash or gift certificates. Items designed primarily for education may be offered occasionally if they are of $100 or less and have no value outside the professional's work. Medical device companies have their own industry code. If you are not a drug or device company, the hospital or practice's own policy is what counts, and many hospitals limit what staff may accept. A shared gift for the whole department is usually the safer choice.
Do not send a gift to anyone involved in a decision you are waiting on. Many companies forbid it during a bid, and even where nothing forbids it, it looks like what it is. Send the gift after the decision, whichever way it goes. A thoughtful gift to a client who chose someone else is remembered for a long time.
Some employers ban gifts completely. Do not try to get around the ban with a gift card or a gift sent to their home. Use one of the alternatives below instead. The point of the gift was to show the relationship matters, and respecting their rules does that too.
Tell us about any recipient gift policies when you send your list. We can organize the program around the limits you provide and flag recipients who may need a different approach, such as a card instead of a box, or a gift for the whole team. No prices ever appear inside the box. With over a decade of curation expertise, this is the part of corporate gifting that most often decides whether a program goes well, and it is rarely the part anyone plans for.
Not sure who on your list can accept a gift?
Send us the list with each recipient's company and the budget per head. We sort it by gift rule and send back what each group can receive within two days.
Send the briefWhat do I do if my client cannot accept gifts?Ask whether the limit comes from their employer, their industry or a government rule. Then stay under the limit, send a shared gift for the team, send a handwritten note, or host them at an event or wait until the deal closes. Do not send a gift card or a gift to their home to get around a ban.
What is the FINRA gift limit in 2026?$300 per person per year, effective March 30, 2026, up from $100. It applies to gifts from broker-dealers and their associated persons to employees of other firms. Gifts are valued at cost, without tax or delivery, and all gifts to the same person over the year are added together.
How much can a federal employee accept as a gift?Under 5 CFR 2635.204, $20 or less per occasion and no more than $50 a year from the same source. Cash and gift cards are not allowed, and the employee cannot pay the difference on a gift worth more than $20.
Can I send a client a gift during an RFP?It is best not to. Many companies forbid gifts to anyone involved in an open bid, and it can look like an attempt to influence the decision. Send it after the decision instead.
Can pharmaceutical companies give gifts to doctors?Under the PhRMA Code, pharmaceutical companies should not offer non-educational items, personal-benefit items, or cash and gift certificates to health care professionals or their staff. Items designed primarily for education may be offered occasionally if they are of $100 or less and have no value outside the professional's work. For other senders, the hospital or practice's own policy decides.
Do gift limits include shipping and tax?Under FINRA Rule 3220, gifts are valued at cost without tax or delivery. Company policies and other rules vary, and many use the retail value of the gift, so ask.
What are good gifts for clients with a low gift limit?One very good item instead of a box: a single-variety olive oil, a designer glass or a handmade bowl. Or a shared gift for the whole team, which many policies allow.
Is a gift to a client tax deductible?Only up to $25 per recipient per year under the IRS rules for business gifts. That is a tax rule for you, not a limit on what you may spend. See our guide to the $25 rule.
