The Gap NOligarchy Profile
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Gap scores 40.39 out of 100 on the NOligarchy Score, covering from Q3 2024 through Q2 2026 (8 quarters — the two-year tracking period). That score breaks into three pillar grades:
Current Pillar Scores
Political Access
33.1
Wealth Extraction
19.0
Playing by the Rules
95.0
Score history — 23 quarters
Tier bands show where each quarter's score falls — no numeric y-axis needed. The dashed ring marks the year-over-year comparison point. Tap any quarter but the first to see its pillar breakdown.
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Political Access Grade: 33.07/100 — reflecting a steady stream of lobbying spending and Political Action Committee (PAC) contributions channeled into Washington across two outside firms and 16 registered lobbyists.
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Wealth Extraction Grade: 18.59/100 — reflecting buybacks, dividends, and a chief executive officer (CEO) pay gap measured in the thousands-to-one.
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Playing by the Rules Grade: 95.0/100 — reflecting a near-spotless public violation record: a single workplace-safety penalty across the entire tracking period.
Gap ranks 22 out of 23 in the Clothing and clothing accessories retailers sector — second-to-last, and well below the sector average score of 69.7. Almost every other clothing retailer tracked posts a stronger accountability record. If you want higher-scoring places to shop, see the Better Alternatives section below.
The Bottom Line: A Legal Record to Envy, a Pay Gap That Isn’t
Gap brought in $15.37 billion in annual revenue in its most recent fiscal year. Its compliance ledger is nearly empty — one OSHA fine, $8,440, across the entire two-year tracking period. But that near-spotless legal record sits alongside a CEO pay ratio of 2,749:1 and $230 million spent buying back its own stock while the median Gap worker earned $10,170 for the year. The company chose to reward shareholders and executives at a scale that dwarfs its footprint in any courthouse or regulatory docket.
Spending to Buy a Seat at the Table
Gap spent $2.35 million on federal lobbying from Q3 2024 through Q2 2026, spread across two outside firms and 16 registered lobbyists. The pace accelerated over time: $740,000 in 2024, $1.11 million in 2025 — with $450,000 of that concentrated in the fourth quarter alone, a surge that often lines up with budget and appropriations deadlines on Capitol Hill — and $500,000 in 2026 through the first two quarters.
Gap’s lobbying priorities track directly to how it makes money. Trade and Taxation each led with 17 filings — unsurprising for a retailer that sources apparel internationally and depends on tariff schedules and trade preference programs. Filings specifically cited trade preferences for Haiti and the Central America Free Trade Agreement (CAFTA), reflecting Gap’s reliance on lower-cost production in those regions. Labor Issues/Antitrust/Workplace (8 filings) reflects Gap’s position as an employer of more than 77,000 people. Environment/Superfund filings tied to “Textile Circularity” point to growing regulatory pressure on apparel waste and recycling. Telecommunications filings reference “CORCA,” and Consumer Issues filings address privacy and data protection — both areas where federal legislation could reshape how Gap collects and uses customer data.
Lobbyists filed filings citing the Buying American Cotton Act of 2025 — a bill still in progress before the Senate Finance Committee that would affect cotton sourcing rules with direct relevance to Gap’s supply chain. It was referenced twice across trade, tax, labor, environment, telecommunications, and consumer-issues filings, making it the most heavily cited piece of legislation in Gap’s lobbying record. The filings do not state whether Gap’s lobbyists supported or opposed it. Filings also cited the Haiti Economic Lift Program Extension Act of 2023, the American Worker and Trade Competitiveness Act, the Expedited Review of Products for GSP Act, the Generalized System of Preferences Reform Act, and the HOPE for Haitian Prosperity Act of 2023 — all centered on trade preferences and import duty structures that directly affect where Gap manufactures its clothing and at what cost.
On top of lobbying, Gap’s PAC distributed $212,000 over the same period, split 53.3% to Democratic recipients and 46.7% to Republican ones — a deliberate both-sides strategy that keeps doors open regardless of which party controls Congress. Company executives personally donated $1,725 to federal candidates and committees.
Gap's PAC gave $60,500 to Democrats and $53,000 to Republicans — a 53.3% / 46.7% split that buys access to whichever party wins.
53.3%
46.7%
Democrats · $60,500
Republicans · $53,000
ACCESS-BUYER PENALTY APPLIED
Gap’s lobbying team includes six former government insiders with deep Capitol Hill experience. One previously served as Chief of Staff in a congressional district office. Another served as Policy Advisor to the Senate Republican Conference and Legislative Director to multiple members of Congress. A third was a professional staff member on the House Committee on Rules. A fourth served as Tax Counsel and Staff Director on the House Ways and Means Select Revenue Measures Subcommittee — a position with direct relevance to Gap’s active lobbying on corporate tax issues. A fifth served as Chief of Staff and immigration counsel across a congressional office and the Department of Education. The sixth worked as a staff assistant to a U.S. Senator. Former government employees who know the rules, the players, and the back channels are the most reliable asset a corporation can deploy in Washington.
Prioritizing Wall Street Over the Workforce
The CEO pay ratio is 2749:1, the 3-year average of Compensation Actually Paid, compared to the median Gap employee, according to the company’s SEC DEF 14A. The CEO’s three-year average package was about $28.0 million — while the median Gap worker took home $10,170 for the year. That is not a typo: the typical Gap employee earns just over $10,000 annually, a figure that implies a large share of Gap’s workforce consists of part-time retail workers whose hours are capped well below full-time.
Over fiscal years 2024 and 2025, Gap spent $230 million executing a deliberate reduction in shares outstanding that inflates per-share metrics and triggers executive performance bonuses — $75 million in fiscal 2024 and $155 million in fiscal 2025 — according to its SEC 10-K. That mechanism disproportionately benefits the wealthiest 10% of Americans, who own 93% of the stock market.
Buybacks vs. Workers
What the buyback spend could have meant for 77K employees
Spent on buybacks
$230.0M
directed to shareholders
÷ 77K
workers
Per-worker raise
$2,979
per employee, 2-year total
Spread over those 2 years, that's a 15% annual raise on the median worker's $10,170 salary — money the company chose to send to shareholders instead.
The company made a deliberate choice. The money spent on buying back its own stock could have instead handed every single one of its 77,215 workers a $2,978.70 raise, spread across the last 2 fiscal years. Spread evenly across those two years, that works out to a $1,489.35 annual raise the company chose not to give.
EARNINGS STATEMENT — ANNUAL
EMPLOYEE: 1 of 77,215
Your share of the buyback
+$2,979
Per biweekly paycheck
+$57.28
SPENT INFLATING THE SHARE PRICE
Stock buybacks over the two most recent fiscal years: $230 million.
Spread across Gap's 77,215 employees, its stock buybacks over the last two fiscal years come to $2,979 per worker — about $57 on each of the 52 biweekly paychecks in that span.
Gap didn’t have to choose between investors and its workforce: the company also paid $247 million in dividends in fiscal 2025 and $225 million in fiscal 2024, for a two-year dividend total of $472 million — on top of the buybacks. Even after funneling nearly half a billion dollars to shareholders through traditional dividends, Gap still chose to layer on another $230 million in share repurchases. Unlike dividends, which distribute cash broadly to all shareholders, buybacks are a more targeted tool that disproportionately rewards insiders and large institutional holders who can time their exits around the repurchase program.
Because buybacks reduce share count and lift earnings per share, they can directly trigger performance-based bonuses for the same executives who approved the repurchase program — including a CEO already pocketing thousands of times the median worker’s salary.
Gap paid an effective tax rate of 27.9% — 6.9 percentage points above the 21% federal statutory rate that Congress set. The company’s 10-K discloses that the largest driver pushing its rate above the statutory floor was state and local income taxes, which added a net 4.4 percentage points, with smaller increases from changes in valuation allowances (+1.4 pp), nondeductible compensation (+1.3 pp), and changes in unrecognized tax benefits (+1.4 pp). Two cross-border items reduced the rate slightly: a U.S. tax benefit on branch income (-1.1 pp) and other cross-border tax laws (-0.4 pp), while research and development credits shaved off another 1.1 percentage points. Gap is not using offshore structures to pay less than peers — it is paying more. What demands scrutiny is a different lever entirely: Gap holds Unrecognized Tax Benefits equal to 33.0% of its pre-tax income — contested deductions it has claimed on its taxes that the Internal Revenue Service (IRS) has not yet agreed are valid. The company’s 10-K discloses that the IRS sought to disallow approximately $41 million of research credits for tax years 2009 through 2013, a dispute Gap has taken to the U.S. Tax Court. That is a substantial overhang of aggressive tax positions still unresolved, representing real financial exposure the balance sheet has not yet absorbed.
A Near-Spotless Record on the Public Docket
Gap’s public violation record over the two-year tracking period from Q3 2024 through Q2 2026 covers a single case: a 2025 OSHA workplace-safety penalty of $8,440. One case, one agency, one fine — a record that places Gap 7th out of 23 companies in the sector by total penalty amount, but reflects minimal regulatory friction for a company with more than 77,000 employees. The full historical docket available at the source is considerably broader than this two-year snapshot alone. The contrast with the $230 million Gap spent on buybacks over the same stretch makes the fine’s scale plain: the entire public penalty record amounts to less than four-thousandths of one percent of the cash channeled to shareholders through share repurchases.
While regulators were issuing that fine, governments were simultaneously handing Gap public money. In 2024, Gap received a $675,000 public subsidy in a single grant from New York. The company collected public support and paid a workplace-safety penalty in the same year — a juxtaposition that illustrates the distance between what governments give and what they get back in compliance.