Super PAC reporting requirements: FEC Form 3X, 24-hour reports and 48-hour reports
What a federal super PAC has to file, when each report is due, how the independent expenditure clock works, and the 2026 to 2027 deadlines that matter right now.
A federal super PAC registers with the FEC on Form 1 within 10 days of raising or spending more than $1,000, then files regular reports on FEC Form 3X on a monthly or quarterly schedule. On top of those, it files a 48-hour report every time its independent expenditures in a race reach $10,000 (any time up to 20 days before the election) and a 24-hour report every time they reach $1,000 in the final 20 days. For the November 3, 2026 general election, the 24-hour window ran October 15 through November 1, and every PAC owes a Post-General Report by December 3, 2026, whether or not it spent a dollar.
What is a super PAC, for reporting purposes?
The FEC calls a super PAC an independent expenditure-only political committee. It can raise unlimited money from individuals, corporations and unions, but it cannot give to candidates. It carries the same disclosure duties as a traditional PAC, plus fast-turnaround reports, because nearly everything it buys is an independent expenditure.
The scale is large. In the 2023 to 2024 cycle, 2,526 independent expenditure-only committees reported $5.1 billion in receipts, and they accounted for $2.7 billion of the $4.4 billion in independent expenditures disclosed to the FEC that cycle.
If you want the strategy side (how super PACs decide what to buy and how coordination rules shape the work), read our companion guide on how super PACs and independent expenditures work.
How do you register a super PAC with the FEC?
Registration comes first, and it starts a clock. A group becomes a political committee once its contributions or expenditures pass $1,000 in a calendar year, and it then has 10 days to file a Statement of Organization, Form 1. You can register earlier, and most well-run groups do.
Two setup decisions shape your reporting life:
- Filing frequency. Choose monthly or quarterly. You can change once per calendar year, after notifying the FEC in writing (or electronically, if you e-file), per the FEC's October 2026 reporting reminder.
- Electronic filing. Committees that receive contributions or make expenditures over $50,000 in a calendar year, or expect to, must file electronically, according to the Form 3X instructions. Plan on e-filing from day one.
What goes on FEC Form 3X?
Form 3X is the Report of Receipts and Disbursements for committees other than candidate committees. The schedules a super PAC lives in:
| Schedule | What it discloses | Itemization trigger |
|---|---|---|
| Schedule A | Receipts: contributions, transfers, refunds, interest | Donors over $200 in the calendar year |
| Schedule B | Operating expenditures: payroll, rent, fundraising, compliance, overhead | Payees over $200 in the calendar year |
| Schedule D | Debts and obligations owed by or to the committee | Outstanding debts |
| Schedule E | Independent expenditures, by candidate, with support or oppose | Independent expenditures over $200 (smaller ones are subtotaled) |
Sources: FEC on reporting independent expenditures on Form 3X and Schedule E instructions.
Donor disclosure
Super PACs disclose their donors. For any individual whose contributions aggregate more than $200 in a calendar year, the report lists name, mailing address, occupation and employer. The committee must use "best efforts" to get that information, which means asking for it in writing on solicitations and making at least one follow-up request within 30 days of receiving the contribution if the donor leaves it blank. Corporate and union contributions are itemized under the organization's name.
Records behind the report
The treasurer keeps records for three years from the filing date of the report they support. Write disbursement purposes a stranger could understand.
When are super PAC reports due? Monthly vs. quarterly
Quarterly filers in an election year
A quarterly super PAC files at least five reports in an even year: April 15, July 15 and October 15 quarterlies, a Post-General Report, and a Year-End Report on January 31, according to the FEC's quarterly filer page. It also files a pre-primary or pre-general report for any election in which it makes contributions or expenditures, including independent expenditures, that were not already disclosed. Those reports close books 20 days before the election and are due 12 days before it.
That is the trap for quarterly filers: a group active in six primaries on six different dates can owe six pre-primary reports.
Monthly filers
Monthly filers report by the 20th of each month for the prior month. In an election year they file the Pre-General and Post-General reports in place of the November and December monthlies, then a Year-End Report. Monthly filers do not file pre-primary reports.
Odd years
In a nonelection year, a quarterly-schedule PAC files semiannually: a mid-year report due July 31 covering January through June, and a year-end report due January 31 covering July through December. Monthly filers stay monthly. Special elections can add reports in any year.
Deadlines from now through 2027
| Report | Coverage | Due |
|---|---|---|
| Post-General (all PACs, regardless of activity) | Close of last report through November 23, 2026 | December 3, 2026 |
| 2026 Year-End | November 24 through December 31, 2026 | January 31, 2027 |
| Monthly reports, 2027 (monthly filers) | Prior month | 20th of each month |
| 2027 Mid-Year (semiannual filers) | January 1 through June 30, 2027 | July 31, 2027 |
| 2027 Year-End | July 1 through December 31, 2027 (semiannual filers) | January 31, 2028 |
| 48-hour IE reports | Any qualifying IE, including in 2027 | Second day after dissemination |
Sources: FEC 2026 pre- and post-general dates, FEC 2026 Post-General reporting reminder, FEC semiannual filer schedule.
How do 24-hour and 48-hour reports work?
These sit on top of the regular schedule, and every independent expenditure they disclose also appears on Schedule E of the next regular Form 3X.
| 48-hour report | 24-hour report | |
|---|---|---|
| When it applies | Any time in the calendar year, including odd years, through the 20th day before an election | After the 20th day, up to 24 hours before the election |
| Threshold | Independent expenditures aggregating $10,000 or more for a given election | Independent expenditures aggregating $1,000 or more for a given election |
| Repeat trigger | Each additional $10,000 for the same election | Each additional $1,000 for the same election |
| Deadline | Received by 11:59 p.m. Eastern on the second day after public dissemination | Received by 11:59 p.m. Eastern on the day after public dissemination |
| Form | Form 3X, Schedule E | Form 3X, Schedule E |
Source: 11 CFR 104.4 and the FEC's nonconnected committee independent expenditure page.
The dissemination date controls the clock
The regulation measures aggregation "as of the first date on which a communication that constitutes an independent expenditure is publicly distributed or otherwise publicly disseminated" (11 CFR 104.4(f)). So the clock starts when the ad first airs or the mail drops, not when you sign the contract or wire the money.
Two examples on the 2026 calendar:
- A super PAC's $250,000 broadcast flight opposing a House candidate first airs Monday, September 14, 2026. That is more than 20 days out, so a 48-hour report is due by 11:59 p.m. Eastern on Wednesday, September 16.
- The same group drops a $40,000 mailer in that district on Tuesday, October 20. That is inside the 24-hour window, so the report is due by 11:59 p.m. Eastern on Wednesday, October 21.
Aggregation is per election and per office
Totals are added up per election and per office within the calendar year, according to the Form 3X instructions. So $5,000 spent on a Senate candidate and $5,000 on a House candidate does not trigger a 48-hour report, because neither race reached $10,000. It still shows up on the next regular report. A primary and a general are separate elections, so the count restarts.
Disclaimers are part of compliance too
Every independent expenditure needs a disclaimer naming who paid, giving a permanent street address, phone number or website, and stating that it was not authorized by any candidate or candidate's committee. The FEC's model line reads "Paid for by the Court Jesters Union PAC (www.jesterspac.net) and not authorized by any candidate or candidate's committee" (FEC). Radio and television ads carry an added spoken statement from a representative of the paying group, and print, TV, radio and internet ads each have format rules on the same FEC page. A missing disclaimer is its own violation, visible to every opponent.
What happens if a super PAC files late?
Regular reports that come in late are handled through the FEC's Administrative Fines Program. Late 24- and 48-hour independent expenditure reports sit outside that program and have gone through the FEC's enforcement process instead.
The FEC has signaled what those penalties look like. In an August 2024 proposed rule to bring these reports into the fines program, it reported that over the two prior election cycles it approved civil penalties for late 24-hour reports at about 7.61% of the amount in violation. It proposed two alternative formulas: $178 plus 10% of that amount, or a lower option of $178 plus 7.5% for late 24-hour reports and $178 plus 5% for late 48-hour reports. Under the 7.5% formula, a $500,000 ad buy reported late on a 24-hour report would carry a fine of roughly $37,700, for one filing. Under the 10% formula, it would be roughly $50,200.
The quorum question
The FEC has lacked a policymaking quorum since May 1, 2025, and its Inspector General calls the lapse the longest in FEC history. Do not read that as a pause. Filing deadlines never moved, staff kept processing reports, and the Congressional Research Service notes that the Justice Department may still pursue criminal enforcement on its own authority. Every report you file is public on FEC.gov the moment it posts, and opponents, reporters and a future full commission can all read it.
State super PACs and state independent expenditure reporting
Everything above governs federal races. Spending on governor, legislature, mayor, judge or ballot measure races is reported under state law. If you are spending in Virginia, Pennsylvania or North Carolina legislative races, for example, you report independent expenditures to that state, on its forms and its calendar, and the federal $1,000 and $10,000 lines do not apply. The state ethics or elections agency publishes the binding calendar.
Building a reporting system that holds up in October
Most super PAC reporting problems start with missing information. The treasurer cannot report an expenditure nobody told them about. The groups that file cleanly do a few things every week:
- Keep one running dissemination log: every ad flight start date, every mail drop date, every digital launch, by race and by candidate.
- Require vendors to send the dissemination date and final cost the same day a piece goes public, especially from October 1 forward.
- Track running totals per race against the $10,000 and $1,000 lines so the treasurer sees a report coming before it is due.
- File on the software your treasurer knows. The FEC's free web-based FECfile+ is built for a limited group of committees during its rollout, and others use the FECFile desktop application or a commercial vendor.
- Calendar every pre-primary and special election report in every state you touch, months ahead.
Compliance belongs in every serious political campaign budget, next to the TV and mail lines it reports on.
Frequently asked questions
What are the reporting requirements for a super PAC?
A federal super PAC registers on FEC Form 1 within 10 days of passing $1,000 in contributions or expenditures, then files Form 3X reports monthly or quarterly. It discloses donors over $200 and itemizes spending over $200. It also files 48-hour reports when independent expenditures in a race hit $10,000 and 24-hour reports when they hit $1,000 in the last 20 days before an election.
How often does a super PAC have to file with the FEC?
It depends on the schedule the committee picks. Monthly filers report by the 20th of every month, with pre- and post-general reports replacing November and December in election years. Quarterly filers report April 15, July 15 and October 15 in election years, plus pre-election reports when active, a Post-General and a Year-End, and file semiannually in odd years.
What is the difference between a 24-hour and 48-hour report?
A 48-hour report covers independent expenditures of $10,000 or more for an election, any time up to the 20th day before that election, and is due by 11:59 p.m. Eastern on the second day after dissemination. A 24-hour report covers $1,000 or more after the 20th day and is due by 11:59 p.m. Eastern the next day. Both are filed on Form 3X, Schedule E.
Do super PACs have to disclose their donors?
Yes. Super PACs itemize every individual whose contributions total more than $200 in a calendar year, with name, address, occupation and employer, and list corporate and union donors by name. Those reports are public on FEC.gov.
What is FEC Form 3X?
Form 3X is the Report of Receipts and Disbursements that PACs and party committees file. It includes a summary page plus schedules for receipts (A), operating expenditures (B), debts (D) and independent expenditures (E). Super PACs use it for regular reports and for their 24- and 48-hour reports.
What happens if a super PAC misses a 24-hour report?
Late 24- and 48-hour reports have gone through FEC enforcement rather than the fines program, and the FEC reported approving penalties of about 7.61% of the amount in violation for late 24-hour reports. File on time and amend later if a figure changes.
How Leo Operations approaches this
Leo Operations is a national field, media and creative firm headquartered in Nashville. Our political campaign work goes back to 2012, and we have served 40+ campaigns, officials and causes, with campaign, ballot and organizing work in 25 states. Our founder, Rodriquez Wright II, ran a statewide PAC voter-contact program in Tennessee in 2018 and directed petition drives for ballot measures in Arizona, Florida, Montana and Massachusetts, so we know what outside-group work demands of vendors.
We produce political media and campaign ads, video, and field programs, including paid canvassing. On an independent expenditure program, every first air date, mail drop and canvass launch is a reporting event. Your compliance team needs the date and cost the same day, because the 24-hour clock does not wait for an invoice. Keep creative and strategy work inside the firewall your lawyers set.
If you are planning an independent expenditure program for 2027 or 2028, email us your race and your budget and we will tell you what it takes.