How Super PACs and Independent Expenditures Work, and How They Spend Money

A super PAC is a federal political committee that can raise unlimited money from individuals, corporations, unions and other PACs, as long as it spends that money independently and never gives it to candidates. Its main tool is the independent expenditure: an ad, mailer, text or canvass that expressly supports or opposes a candidate and is not coordinated with that candidate or a party. You start one by filing FEC Form 1 within 10 days of raising or spending more than $1,000, and once you are spending, you report independent expenditures fast: within 48 hours for $10,000 or more, and within 24 hours for $1,000 or more in the last 20 days before an election. Outside groups, mostly super PACs, were on pace to spend more than $5 billion in the 2024 federal cycle, according to OpenSecrets.

What is a super PAC and how does it work?

The FEC's formal name for a super PAC is an independent expenditure-only political committee. The FEC says these committees "may accept unlimited contributions," including from corporations and labor organizations, but cannot use those funds to make contributions, in-kind contributions or coordinated communications to federal candidates (FEC).

A super PAC can say "Vote for Jane Smith" as loudly as it can afford. It cannot ask Jane Smith's campaign what to say, when, or to whom. Two other terms you will see:

• Independent expenditure. Spending on a communication that expressly advocates the election or defeat of a clearly identified candidate and is not made in cooperation with the candidate, the campaign or a party (FEC).
• Hybrid PAC (Carey committee). A committee that keeps two bank accounts: a limited account that can give to candidates and an unlimited account used only for independent expenditures.

State and local races have their own versions (often called independent expenditure committees), governed by state law. This guide focuses on federal rules.

Super PAC vs PAC: what is the difference?

Limits above are from the FEC contribution limits table for 2025 to 2026. For comparison, an individual can give $3,500 per election directly to a federal candidate.

Foreign nationals cannot contribute to any committee, super PACs included (FEC). Super PACs do have to disclose their donors: contributors who give more than $200 in a calendar year are itemized on FEC reports. The catch is that a donor can be a nonprofit or LLC that does not disclose its own funders, which is where the "dark money" debate comes from.

How to start a super PAC

1. Pick a name and a treasurer. The treasurer is legally responsible for records and reports. Use an experienced one.
2. Open a bank account in the committee's name.
3. File FEC Form 1 (Statement of Organization). A committee must register within 10 days of exceeding $1,000 in contributions or expenditures in a calendar year, and can register earlier (FEC). Identify it as an independent expenditure-only committee.
4. Choose a reporting schedule. PACs file Form 3X monthly or quarterly. Committees above $50,000 in annual activity must file electronically.
5. Set up compliance before spending a dollar: disclaimers, a vendor firewall policy, and a calendar for 24- and 48-hour reports.
6. Hire counsel. Super PAC law runs on advisory opinions and enforcement cases (Covington, 2025).

How much does it cost to start a super PAC? There is no FEC filing fee. The real startup costs are legal counsel, a treasurer and compliance software. In our experience those run from a few thousand dollars for a small committee to well into five figures a month for a large one.

Independent expenditure reporting: 24-hour and 48-hour reports

This is where new super PACs get fined. Super PACs report independent expenditures on Schedule E of Form 3X, plus two kinds of fast reports (FEC):

Each additional $10,000 (or $1,000 in the final window) triggers another report. The clock runs from when the ad or mail is publicly disseminated, not when the vendor is paid. Late reports carry real penalties; one FEC settlement over late independent expenditure reports reached $99,000 (Wiley).

Have every vendor confirm in writing when each piece goes public (first airing, mail drop, first impression, first text). Your treasurer cannot report what they do not know.

Coordination rules, common vendors and firewalls

A communication paid for by a super PAC becomes an illegal in-kind contribution if it is "coordinated" with a candidate or party. The FEC uses a three-part test (FEC coordinated communications):

1. Payment. Someone other than the candidate or party pays for it.
2. Content. It meets a content standard, such as express advocacy, republishing campaign material, or referring to a House or Senate candidate in their jurisdiction within 90 days of the election (120 days before a primary through the general for presidential candidates).
3. Conduct. There is interaction: a request or suggestion from the campaign, the candidate's material involvement, substantial discussion, use of a common vendor, or a former campaign employee passing along information.

The common vendor problem

A vendor who provided certain services to a campaign (strategy, polling, media production, media buying, voter targeting, mail, fundraising and similar) within the previous 120 days and then uses or shares material information about that campaign's plans with a super PAC can make the super PAC's spending coordinated (11 CFR 109.21).

The vendor world is small, so this comes up constantly. Shared vendors are not illegal in themselves; the risk is the use or sharing of material campaign information.

The firewall safe harbor

The FEC rules give a safe harbor when a vendor or former employee has a written firewall that keeps information about the candidate's plans, projects, activities or needs away from the people working on the super PAC account. A real firewall means separate staff, separate files and systems, written policies everyone signs, and training. The safe harbor does not protect you if the campaign makes a "request or suggestion" to the super PAC. If a vendor tells you "we have a firewall" and cannot show you the written policy, assume they do not.

Canvassing is analyzed differently from paid advertising

In Advisory Opinion 2024-01 (Texas Majority PAC), the FEC concluded that the requester's canvassing literature and scripts were not "public communications," so they could not meet the content prong of the coordinated-communication rules, and that payments made solely to produce and distribute those communications were not coordinated expenditures. Two limits come with it. First, if canvass data is given to a federal candidate or party committee for less than the usual and normal charge, that is an in-kind contribution. Second, the opinion rests on the specific facts presented, and the Campaign Legal Center sued the FEC in May 2026 to overturn it (CLC complaint).

It does not make all field activity unrestricted, it does not cover the paid ads, mail or digital that accompany a canvass, and state law can differ. Have counsel review the exact plan before any conversation with a campaign about a canvass.

Public information, campaign footage and the republication rule

Coordination first. Under 11 CFR 109.21, most of the conduct standards (material involvement, substantial discussion, common vendors, former employees) are not met when the information used was obtained from a publicly available source. Public polling, press releases and FEC reports are ordinary research; asking the campaign privately for its plans is not.

Republication is a separate rule. Under 11 CFR 109.23, paying to disseminate or republish, in whole or in part, campaign materials prepared by the candidate or the campaign is treated as a contribution to that candidate. The listed exceptions are narrow: material used in a communication advocating the candidate's defeat, news stories and commentary, a brief quote that shows the candidate's position as part of the group's own message, and certain party spending. Footage being public is not on that list.

In MURs 7666, 7675, 7681 and 7715, outside groups ran supportive TV ads built partly from B-roll and photos candidates had posted publicly. The FEC's Office of General Counsel recommended finding reason to believe the groups made in-kind contributions through republication. The Commission split 3 to 3 and closed the files: Commissioners Dickerson and Trainor called the regulation contrary to the statute absent actual coordination, while Commissioner Weintraub said it plainly applies (Dickerson and Trainor statement; Weintraub statement; MUR 7715 case file). A deadlock is not a ruling that the practice is lawful.

The working standard: public sourcing does not automatically resolve coordination or republication questions. Before a super PAC reuses campaign-produced footage or acts on public campaign guidance, counsel should review that specific use under the applicable FEC rules and opinions, and under state law in state races.

Disclaimer requirements

Federal disclaimer rules attach to specific categories of communication, not to everything a super PAC pays for. For a political committee, those are its public communications (broadcast, cable, print, outdoor, mass mailings of more than 500 similar pieces, phone banks and internet ads placed for a fee), email to more than 500 people, and its public website (FEC advertising and disclaimers). For those, the disclaimer on an unauthorized communication must include:

• The full name of the committee that paid for it.
• Its permanent street address, phone number or website.
• A statement that it is not authorized by any candidate or candidate's committee.

Format rules by medium:

Exceptions matter. Small items such as buttons and bumper stickers are exempt, and in Advisory Opinion 2002-09 the FEC applied the small-items exception to SMS text ads because of their length limits. Hand-delivered walk literature is not a public communication under the FEC's reasoning in AO 2024-01 (above). States have their own disclaimer laws for texts, literature and digital ads, often stricter than the federal ones, so treat state rules as a separate checklist. Our standard is to put a clear paid-for-by line on every piece a client distributes and have counsel confirm the exact wording for each medium and state.

How do super PACs spend money?

Mostly on paid media, then mail and digital, with a growing share to field. AdImpact projected in June 2026 that political advertising for the 2025 to 2026 cycle would reach a record $11.6 billion, with about $5.6 billion on broadcast TV, $2.7 billion on connected TV, $1.4 billion on cable and $1.6 billion on digital (AdImpact via GV Wire, 2026). Outside groups are a large share of that.

One cost reality shapes every super PAC plan: candidates get the lowest unit rate on broadcast stations in the 45 days before a primary and 60 days before a general, and super PACs do not. Outside groups pay market rates, which can be double or triple what candidates pay in hot markets (Wisconsin Watch, 2023). A dollar of super PAC TV buys less than a dollar of candidate TV. See our political TV ad cost guide.

What $1 million, $10 million and $100 million typically buy

These are experience-based allocations for a single-candidate super PAC in a competitive race, not published averages. Adjust them for the cost of your markets and the size of your target universes.

Leave room for research, testing and production at every level. A super PAC that spends its whole budget on airtime with untested creative is gambling.

Field is the line item that has grown most, because door-to-door contact has the strongest experimental evidence for moving turnout. A federal super PAC paying for canvassing that expressly advocates still reports that spending, so the treasurer needs dissemination dates just as for an ad. See canvassing cost and effectiveness.

Super PAC spending: what OpenSecrets data shows

OpenSecrets tracks outside spending by cycle on its outside spending pages. For 2024 it reported outside spending of $2.6 billion by early October and projected more than $5 billion for the cycle (CNN reporting on OpenSecrets data, 2024). By mid-August 2024, Make America Great Again Inc. had spent more than $239 million and Future Forward more than $212 million on the presidential race (OpenSecrets via ScheerPost, 2024). The headline money sits in a handful of giant committees. Most super PACs are single-race efforts, where precise targeting and good field work matter most.

Frequently asked questions

How do super PACs work?

A super PAC raises unlimited contributions and spends them on independent expenditures (ads, mail, digital, field) supporting or opposing candidates. It cannot give money to candidates or coordinate with them. It registers with the FEC and discloses its donors and spending.

How do you start a super PAC?

Name a treasurer, open a bank account, and file FEC Form 1 within 10 days of raising or spending more than $1,000, identifying the committee as independent expenditure-only. Then set up reporting, disclaimers and a vendor firewall policy before you spend. Get experienced campaign finance counsel.

How much does it cost to start a super PAC?

The FEC charges no fee to register. The real costs are a treasurer, compliance software and legal counsel. Small committees can launch for a few thousand dollars in professional fees; large ones spend far more on compliance alone.

What is the difference between a super PAC and a PAC?

A traditional PAC can give money directly to candidates (up to $5,000 per election) but can only accept up to $5,000 per year from an individual. A super PAC cannot give to candidates at all, but can accept unlimited money, including from corporations and unions.

Do super PACs have to disclose donors?

Yes. Super PACs report contributors who give more than $200 in a year to the FEC. Donations that pass through nonprofits or LLCs can obscure the original source, which is why critics talk about dark money flowing through super PACs.

How does a super PAC spend money?

Mostly on TV and streaming ads, then digital, mail, texting and field programs. Because super PACs do not get candidate ad rates, their TV dollars buy less. Smaller super PACs usually lean on digital, mail and canvassing.

What is an independent expenditure?

It is spending on a communication that expressly advocates for or against a clearly identified candidate and is not coordinated with that candidate, their campaign or a party. Independent expenditures have no spending limit but must be reported, including on fast 24- and 48-hour reports near elections.

Can a super PAC use a candidate's public B-roll footage?

Not on the assumption that public means permitted. 11 CFR 109.23 treats paying to republish campaign-prepared material as a contribution unless a listed exception applies, and the FEC deadlocked 3 to 3 in the 2022 open-B-roll matters rather than approving the practice. Have counsel review the specific footage and ad before it airs.

Can a super PAC coordinate canvassing with a campaign?

In AO 2024-01, the FEC concluded that one committee's canvassing literature and scripts were not public communications and fell outside the coordinated-communication rules. The opinion is fact-specific and under legal challenge, and giving canvass data to a campaign below market value is still an in-kind contribution. Have counsel review the exact plan.

Can a super PAC and a campaign use the same consultant?

Only carefully. A common vendor that served the campaign within the past 120 days can create illegal coordination if it shares the campaign's plans. Firms that work both sides need a written, enforced firewall separating the teams.

How Leo Operations approaches this

Leo Operations is a national field, media and creative firm, founded in 2019 by Rodriquez Wright II, with political campaign work since 2012. Rodriquez served as Tennessee State Project Director for a statewide PAC voter-contact program in 2018, and he has directed petition drives and canvass programs in multiple states, so we know how independent spending has to run on the ground: fast, documented and fully separate from the candidate.

For outside groups we build field programs (paid canvassing, voter registration, GOTV), political ads, video and digital campaigns. We work under written firewall policies, we document dissemination dates so your treasurer can file 24- and 48-hour reports on time, and we report door-level and spend-level results.

Our field programs have knocked more than 650,000 doors, and we have served 40+ campaigns, officials and causes across 25 states. If you are planning independent expenditures in a race this cycle, email us your race, election date and budget, and we will tell you honestly what that money can buy and where it will do the most.