How Super PACs and Independent Expenditures Work, and How They Spend Money
FEC registration, independent expenditure reporting, coordination and firewall rules, disclaimers, and what a super PAC actually buys at $1 million, $10 million and $100 million.
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).
That one restriction defines everything else. A super PAC can say "Vote for Jane Smith" as loudly and as often as it can afford. It cannot ask Jane Smith's campaign what to say, when to say it, or which voters to target.
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?
| Traditional PAC (nonconnected, multicandidate) | Super PAC | |
|---|---|---|
| Individual contribution limit | $5,000 per year | Unlimited |
| Corporate and union money | Not allowed directly | Allowed |
| Can give to candidates | Yes, up to $5,000 per election | No |
| Can coordinate with campaigns | Contributions, yes | Never |
| Main activity | Contributions plus some independent spending | Independent expenditures |
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
- Pick a name and a treasurer. The treasurer is legally responsible for records and reports. Use an experienced one.
- Open a bank account in the committee's name.
- 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.
- Choose a reporting schedule. PACs file Form 3X monthly or quarterly. Committees above $50,000 in annual activity must file electronically.
- Set up compliance before spending a dollar: disclaimers, a vendor firewall policy, and a calendar for 24- and 48-hour reports.
- Hire counsel. Super PAC law is a minefield of advisory opinions and enforcement cases. A practical guide from Covington lays out issues for 2026 that consultants routinely trip on (Covington, 2025).
How much does it cost to start a super PAC? There is no FEC filing fee. Realistic startup costs are legal, treasurer and compliance software, which in our experience run from a few thousand dollars for a small committee to well into five figures a month for a large one (an experience-based range, not a published figure).
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):
| Report | Trigger | Deadline |
|---|---|---|
| 48-hour report | Independent expenditures aggregating $10,000 or more for an election, any time up to the 20th day before it | 11:59 p.m. Eastern on the second day after public dissemination |
| 24-hour report | Independent expenditures aggregating $1,000 or more after the 20th day, but more than 24 hours, before the election | Within 24 hours of public dissemination |
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).
Practical tip: have every vendor confirm in writing the date and time each piece goes public (first airing, mail drop, first ad impression, first text sent). 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):
- Payment. Someone other than the candidate or party pays for it.
- 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).
- 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).
This matters because the political vendor world is small. The same media buyers, pollsters, mail houses and field firms often work for candidates and outside groups in the same cycle.
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.
What super PACs can lawfully use
Super PACs can use publicly available information. Candidates sometimes post B-roll footage and message guidance on public websites, and outside groups read public polling, press releases and FEC reports. Using public information is not coordination. Asking the campaign for it privately is.
Disclaimer requirements
Every super PAC independent expenditure needs a disclaimer (FEC):
- 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.
For radio and TV there is a spoken "stand by your ad" statement. TV also needs a written disclaimer on screen for at least four seconds at a height of at least 4 percent of the picture. Print disclaimers go in a box set apart from the rest of the piece; 12-point type is a safe harbor for pieces up to 24 by 36 inches. Digital ads, texts and mail all need disclaimers too, with some format accommodations for small digital units.
How do super PACs spend money?
Mostly on paid media, then mail and digital, with a growing share going 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. Every race is different.
| Budget | Typical mix | What it looks like in practice |
|---|---|---|
| $1 million | 35 to 50% digital and streaming, 20 to 30% mail, 15 to 30% field or texting, 5 to 10% research, production and compliance | A House primary or a down-ballot statewide race. Broadcast TV is usually unaffordable except in small markets, so the money goes to targeted digital, CTV, several mail drops and a paid canvass or text program aimed at low-propensity supporters. |
| $10 million | 50 to 65% broadcast, cable and CTV, 10 to 20% digital, 10 to 15% mail, 10 to 20% field | A competitive House general or a smaller-state Senate race. Enough for several weeks of TV at real weight, a mail program and a serious door-knocking operation. |
| $100 million | 55 to 70% TV and CTV across many markets, 10 to 15% digital, 5 to 10% mail, 10 to 20% field and data | A presidential effort or a multi-state Senate program. Large field operations become possible, along with polling, analytics and creative testing at scale. |
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. Super PACs and their allied groups increasingly fund paid canvassing because door-to-door contact has the strongest experimental evidence for moving turnout. Canvassing for a super PAC is still an independent expenditure if the scripts expressly advocate, so the same reporting and disclaimer rules apply to walk literature. 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, OpenSecrets reported outside spending had reached $2.6 billion by early October and projected the full cycle would top $5 billion, inside a total federal election cost projected at $15.9 billion (CNN reporting on OpenSecrets data, 2024). By mid-August 2024, Make America Great Again Inc. had spent more than $239 million supporting Donald Trump and Future Forward more than $212 million supporting Democratic presidential candidates (OpenSecrets via ScheerPost, 2024).
The lesson for smaller groups: the headline money is concentrated in a handful of very large committees. Most super PACs are small, single-race efforts, and that is 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 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, so we understand what independent spending looks like on the ground.
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 across work in 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.