Campaign Committee: Treasurer, Reporting, and Contribution Limits

Federal campaign committee registration and reporting is triggered by two separate dollar thresholds. A candidate must file a Statement of Candidacy with the Federal Election Commission within 15 days of raising or spending more than $5,000.¹ A political committee, including the principal campaign committee the candidate designates, must file a Statement of Organization within 10 days of crossing $1,000 in contributions received or expenditures made during a calendar year.² From there, the committee owes the FEC periodic financial reports until the Commission formally approves its termination.

Which Threshold Applies to You

The candidate filing and the committee filing are different obligations with different deadlines, and confusing them is one of the most common early mistakes.

You personally become a federal candidate the moment your fundraising or spending passes $5,000. Within 15 days of that point, you file FEC Form 2, which identifies you, your party, the office you are seeking, and the name and address of your principal campaign committee.¹ The principal campaign committee’s name must include your name.

The committee itself files FEC Form 1 (the Statement of Organization) within 10 days of crossing the separate $1,000 threshold. Form 1 captures the committee’s official name, mailing address, treasurer, custodian of records, and the bank where the committee holds its funds.² Committees expecting to raise or spend more than $50,000 in a calendar year must file electronically through the FEC’s e-filing system; committees below that amount may submit paper forms by mail.³ Once the FEC processes your filing, it issues a Committee Identification Number that you will use on every future report.

Committee Types and What Each Can Do

An authorized committee is one the candidate has specifically approved to receive contributions and make expenditures on their behalf. Among authorized committees, the candidate designates one as the principal campaign committee, which serves as the central fundraising and spending vehicle.⁴

Committees not authorized by any candidate include political action committees, which raise money from individuals and contribute to multiple candidates; separate segregated funds, which are PACs established and financially supported by a corporation or labor organization; and party committees, which operate at the national, state, or local level.⁴

Super PACs, formally called independent expenditure-only committees, may accept unlimited contributions from individuals, corporations, labor unions, and other PACs. In exchange, they are barred from making any contributions or coordinated expenditures to federal candidates or committees. They register on Form 1 like any other committee, within 10 days of the $1,000 threshold, and must check the box designating their independent-expenditure-only status.⁵

Appointing a Treasurer

Every political committee must have a treasurer in place before it can legally raise or spend a single dollar. The treasurer deposits contributions, authorizes expenditures, keeps records, and signs and files every report.⁶ If the position is vacant for any reason, the committee cannot accept contributions or make expenditures until someone fills it.

The role carries personal exposure. In enforcement actions, the FEC names both the committee and its treasurer as respondents. A treasurer who knowingly violates the law, recklessly ignores filing duties, or deliberately avoids learning facts that would reveal a violation can be held personally liable rather than only in an official capacity.⁷ Under the Administrative Fine Program, both the committee and the treasurer are jointly on the hook for any civil penalty for late reports.

The FEC strongly recommends designating an assistant treasurer on Form 1 who can step in when the treasurer is unavailable. If the committee files electronically, the assistant treasurer should also have an e-filing password.⁶

Bank Account and Recordkeeping

A committee must open a dedicated bank account and keep all political funds separate from the candidate’s personal money.⁸ Commingling campaign funds with personal finances draws FEC scrutiny quickly and makes accurate reporting nearly impossible.

Federal reporting rules use $200 as the key threshold for detailed recordkeeping. For any person whose contributions add up to more than $200 within the election cycle, the committee must record and eventually disclose the contributor’s name, mailing address, date and amount of each contribution, occupation, and employer. The same $200 threshold applies on the spending side: any payment to a person totaling more than $200 in the calendar year requires recording the recipient’s name and address along with the date, amount, and purpose of the expenditure.⁹

Track everything from day one anyway. Contributions aggregate over the cycle, and a $50 donor who gives four times crosses the $200 line. Reconstructing records months later is where committees get into trouble.

The Ongoing Reporting Cycle

Registration is the starting gate. The real workload is the cycle of periodic reports that continues until the committee formally terminates. Candidate committees file on FEC Form 3; PACs, party committees, and other unauthorized committees use Form 3X.¹⁰ Each report breaks down every dollar received and spent during the reporting period.

Quarterly and Monthly Filers

Most House and Senate candidate committees file quarterly, with reports due April 15, July 15, October 15, and January 31 of the following year, each covering the preceding calendar quarter.¹¹ Presidential campaign committees that have received or expect to receive $100,000 or more in contributions, or have made or expect to make $100,000 or more in expenditures, must file monthly instead.

In election years, quarterly filers also face additional pre-election and post-election reports. A pre-general-election report, for example, closes its books on October 14 and is due by October 22.¹² These pre-election reports apply to primaries, conventions, runoffs, and special elections as well, even when the candidate is running unopposed.

48-Hour Notices

Contributions and loans of $1,000 or more received by an authorized committee less than 20 days before an election, but more than 48 hours before, trigger a special notice. The committee must file it within 48 hours of receiving the contribution.¹³ The $1,000 threshold covers monetary and in-kind contributions, personal loans from the candidate, credit card draws, and endorsements of bank loans. Missing a 48-hour notice is where campaigns most often collide with the Administrative Fine Program.

Public Availability

All reports filed with the FEC are made available for public inspection through the Commission’s online database. A copy of each report must also be filed with the Secretary of State or equivalent officer in the state where the candidate is running.¹⁰

Contribution Limits and Prohibited Sources

For the 2025–2026 election cycle, an individual may contribute up to $3,500 per election to a candidate committee. Because the primary and general count as separate elections, one person can give up to $7,000 total to the same candidate across both. The limit is adjusted for inflation in odd-numbered years.¹⁴

Federal law flatly prohibits contributions from several categories of donors:

Corporations, including nonprofits, trade associations, and professional corporations such as law firms organized as corporations.
Labor organizations. Unions may not contribute directly, though both corporations and unions may fund separate segregated funds that make their own contributions.
Foreign nationals, meaning anyone who is not a U.S. citizen or lawful permanent resident.
Federal government contractors with a current federal contract.
Straw donors, meaning contributions made in the name of another person.

Committees are equally prohibited from soliciting or accepting these contributions.¹⁵ The foreign national ban covers not just direct donations but also expenditures and electioneering communications.¹⁶ Accepting a prohibited contribution, even unknowingly, can trigger an enforcement action, so verify donor eligibility before depositing funds.

Disclaimers on Campaign Communications

Every public communication paid for by a campaign committee must carry a “paid for by” disclaimer identifying who funded it. The specific wording depends on the relationship between the payer and the candidate. If the candidate’s authorized committee paid for it, the disclaimer says so. If the candidate authorized the communication but someone else paid, the disclaimer names the payer and states the communication is authorized by the candidate. If no candidate authorized it, the disclaimer names the payer with a full street address, phone number, or website and states that no candidate or candidate’s committee authorized it.

On printed materials, the disclaimer must appear in a box set apart from other text, in a font size large enough to be clearly readable, with reasonable color contrast against the background. For online communications, the disclaimer must be visible without clicking or scrolling, and video disclaimers must display for at least four seconds.¹⁷ Small items like buttons, bumper stickers, and pens are exempt when a full disclaimer is impractical.

Penalties for Late or Missed Filings

The FEC’s Administrative Fine Program imposes civil penalties for reports and notices filed late or not at all. Fines are calculated by formula and increase based on the amount of financial activity involved, how late the filing is, and whether the committee has prior violations.

For missed 48-hour contribution notices, the base penalty is $183 plus 10 percent of the unreported contribution amount, and that penalty increases by 25 percent for each prior violation within the current or previous two-year election cycle.¹⁸ A committee that misses multiple notices in the same cycle sees fines escalate quickly.

Both the committee and its treasurer are jointly liable for any penalty assessed.⁷ Beyond administrative fines, the FEC can pursue civil enforcement actions for more serious or willful violations, which carry their own penalties.

IRS Filings You May Still Owe

FEC reporting is not the only filing obligation a political organization has. Section 527 of the tax code governs the tax-exempt status of political organizations, and committees seeking 527 treatment generally must file IRS Form 8871 electronically within 24 hours of being established. Committees already required to report under the Federal Election Campaign Act, including all FEC-registered candidate committees, are specifically exempted from the Form 8871 requirement.¹⁹

Regardless of that exemption, any political organization with taxable income exceeding $100 after the specific deduction must file IRS Form 1120-POL, the income tax return for political organizations.²⁰ Taxable income for committees typically comes from investment returns or other non-contribution revenue. Most small candidate committees never trigger this requirement, but any committee that invests surplus funds or earns bank interest above the threshold should plan for it.

Ending the Committee Properly

Losing an election, or winning one, does not automatically end reporting obligations. The committee must keep filing on schedule until the FEC formally grants its request to terminate. Committees that simply stop filing face mounting administrative fines.

To qualify for termination, a committee must meet all of the following conditions:

It no longer receives or intends to receive contributions.
It no longer makes or intends to make expenditures.
It has no outstanding debts or has fully retired them.
It is not the subject of any pending FEC enforcement action, audit, or litigation.

The committee then files a termination report disclosing any previously unreported receipts and disbursements, any debt retirement activity, and how remaining funds will be used. Checking the “Termination Report” box on a regular disclosure form does not, by itself, end the filing obligation. The committee must keep filing on its normal schedule until it receives written confirmation from the FEC that termination has been approved.²¹

1
Federal Election Commission. Registering a Candidate
2
Office of the Law Revision Counsel. 52 U.S. Code 30101 – Definitions
3
Federal Election Commission. Electronic Filing Overview
4
Federal Election Commission. FEC Campaign Committee Terminology
5
Federal Election Commission. Registering as a Super PAC
6
Federal Election Commission. Appointing a Treasurer
7
Federal Election Commission. Treasurer’s Liability
8
Federal Election Commission. Getting a Tax ID and Bank Account
9
Office of the Law Revision Counsel. 52 U.S. Code 30104 – Reporting of Receipts and Disbursements
10
Federal Election Commission. Instructions for FEC Form 3 and Related Schedules
11
Federal Election Commission. Candidate Quarterly Reports
12
Federal Election Commission. 2026 Quarterly Reports
13
Federal Election Commission. 48-Hour Notices
14
Federal Election Commission. Contribution Limits for 2025-2026
15
Federal Election Commission. Who Can and Can’t Contribute
16
Office of the Law Revision Counsel. 52 U.S. Code 30121 – Contributions and Donations by Foreign Nationals
17
eCFR. 11 CFR 110.11 – Communications, Advertising, Disclaimers
18
eCFR. 11 CFR 111.44 – Schedule of Penalties for 48-Hour Notices
19
Internal Revenue Service. Instructions for Form 8871
20
Internal Revenue Service. Political Organization Filing Requirements – Who Must File Form 1120-POL
21
Federal Election Commission. Terminating a Committee