Super PACs are required to tell the public who gives them money and how they spend it. In practice, that disclosure has gaps, and by several measures, more money moved through those gaps in 2026 than in any past cycle. Some of the methods are plainly legal, some are legal but contested, and a few have drawn formal complaints alleging they break the law.
Here are the five main ways the real source of super PAC money, or where it ends up, can stay out of view, with examples from both parties.
1. Giving through a nonprofit (“gray money”)
Super PACs must disclose their donors, but some of those donors are nonprofit groups, usually organized under section 501(c)(4) of the tax code, that do not have to disclose their donors. When a nonprofit gives to a super PAC, the public sees the nonprofit’s name and nothing more. Because the donors are hidden one step back, this is often called “gray money,” as distinct from fully undisclosed “dark money.”
It is common on both sides, and it is how the party-leadership super PACs raise much of their money. Through late August 2026, according to an analysis by the investigative outlet Sludge reported by The Nation:
- One Nation, aligned with Senate Republican leadership, gave $70.7 million to the Senate Leadership Fund.
- Majority Forward, its Democratic counterpart, gave $61 million to Senate Majority PAC.
- American Action Network gave $44.3 million to the House Republicans’ Congressional Leadership Fund.
- House Majority Forward gave $21.7 million to the House Democrats’ House Majority PAC.
Sludge counted about $642 million in contributions from more than 130 nonprofits to PACs, roughly 14% of large itemized contributions. Separately, the watchdog group CREW identified a network of 13 connected nonprofits that had given more than $33.1 million to 31 super PACs this cycle, mostly to back Republican Senate candidates.
2. Giving through a new company
Since Citizens United, companies can give unlimited amounts to super PACs (see Which Corporations Gave the Most to Super PACs in 2026?). Most corporate donors are real businesses. But a donor can also give through a newly formed limited liability company, or LLC, whose owners are not public.
This is where the legal line matters. Federal law bans contributions “in the name of another,” known as straw donations. If an LLC is just a pass-through for someone else’s money, the real source must be disclosed. In one 2026 case, Kentucky 4th PAC spent nearly $6.7 million in the Republican primary for Kentucky’s 4th District. When it finally filed its report, weeks after the primary, it showed that all of its money came from Tamarack Aspen Inc., a company formed three days before the PAC registered with the FEC. The Campaign Legal Center, a nonprofit that advocates for stricter campaign finance enforcement, has filed a complaint alleging the company was an illegal straw donor.
3. Super PACs funding other super PACs
A super PAC can give unlimited sums to another super PAC. Sometimes that is simply how a group organizes its spending. The Senate Leadership Fund, for example, gave $158 million to Texas PAC, the group it created to back Ken Paxton in Texas, after receiving $158 million from Elon Musk. That chain was reported openly.
Other times, the extra layer hides who is behind the ads. In Illinois’ Democratic primaries in March, AIPAC’s super PAC, United Democracy Project, sent $5.3 million to two other PACs, Elect Chicago Women and Affordable Chicago Now, which ran ads under their own names. And in two Democratic primaries in Texas and Pennsylvania, a PAC called Lead Left spent more than $3.1 million supporting far-left candidates. A report filed after those primaries showed all of its money came from Conservative Americans PAC, a Republican-aligned committee, according to the Campaign Legal Center.
4. Forming late: the “pop-up” super PAC
Timing is the simplest way to keep donors out of view until after voters decide. Before the Nov. 3 general election, super PACs had to file a pre-general report covering donations through Oct. 14. Money received after that date does not have to be disclosed until the post-general report, due Dec. 3. Super PACs must report their spending within 24 or 48 hours as Election Day nears, but those quick reports do not name donors.
A group that forms in mid-October can therefore spend millions without revealing a single donor before the vote. One example: Our Heritage Matters registered on Oct. 15 and spent more than $8 million in 61 races, mostly supporting third-party candidates and opposing Republicans, according to IVN. Its donors are due Dec. 3. CNBC counted 22 late-forming super PACs that spent about $637 million on 2026 congressional races. See The Rise of the Pop-Up Super PAC for more.
5. Hiding where the money goes
Disclosure covers spending as well as donors. Super PACs must report who they pay, which normally shows whether money went to TV ads, digital ads, mail or consultants. If nearly everything is paid to a single intermediary company, the public learns very little.
That is the allegation against two super PACs in the AI industry’s Leading the Future network. According to the Nevada Current, Think Big, which spent more than $8 million against Alex Bores in a New York Democratic primary, paid nearly all of its money to Lantern Production Consultants LLC, listed at a mailbox rental in Sparks, Nevada. Its Republican-side twin, American Mission, paid nearly all of its money to Summit Ridge Media Group LLC in Henderson, Nevada. Neither company has a website or public presence beyond FEC filings. In May, the Campaign Legal Center filed an FEC complaint alleging the arrangement violates reporting rules by hiding the real vendors. The same group raised similar questions about the two new companies that handled Lead Left’s ads. None of these complaints has been resolved.
Who enforces the rules?
For most of the 2026 cycle, effectively no one. The Federal Election Commission needs four of its six commissioners to open investigations, issue fines or write rules. It fell below that quorum in May 2025, and as of early October 2026 it had only two commissioners, both Democrats, CBS News reported. President Trump nominated two Republicans in February 2026, but the Senate had not held a hearing on them. FEC staff can still accept complaints and publish reports, but complaints like those described above cannot move forward until the commission can act.
What has been proposed
Proposals to close these gaps include requiring super PACs to report large contributions within 48 hours in the final month before an election, as candidates already must in the final 20 days; requiring nonprofits that give to super PACs to disclose their own donors; and barring newly formed committees from switching reporting schedules to avoid pre-election reports. Supporters argue voters deserve to know who is paying for ads before they vote. Opponents, including many conservative and civil-liberties groups, argue that donor disclosure can expose people to harassment and that nonprofit donor privacy is protected by the First Amendment. Congress has not passed any of these proposals.
How to look for yourself
Every super PAC’s donors and payments are searchable on the FEC’s website. A few signs worth checking: a donor that is an LLC or nonprofit you have never heard of, a committee that registered only weeks before an election, and a super PAC whose payments almost all go to one company. For the terms used here, see our campaign finance glossary, and for how hybrid committees fit in, see What Is a Hybrid PAC?
Sources
- The Nation: “Gray money” is fueling a bipartisan arms race for control of Congress (Sept. 9, 2026), reporting Sludge’s analysis
- CREW: Dark money network spending more than ever in 2026 cycle (Aug. 11, 2026)
- Campaign Legal Center: “Pop-up” super PACs game the system to leave voters in the dark
- Campaign Legal Center: AI industry-funded super PACs unlawfully evaded transparency rules, CLC alleges (May 2026)
- Nevada Current: Pro-AI PAC sinks a New York City congressional candidate, from a Nevada mailbox (June 25, 2026)
- IVN: Pop-up super PACs with undisclosed donors spent millions days before midterms (Nov. 5, 2026)
- CNBC: “Pop-up” super PACs spend record sums (Oct. 31, 2026)
- United Democracy Project (Wikipedia, citing FEC records)
- AP via AJC: Musk’s $158 million to the Senate Leadership Fund (Oct. 2026)
- CBS News: Weeks before Election Day, the nation’s campaign finance regulator can’t enforce the law (Oct. 7, 2026)
- Federal Election Commission: Campaign finance data
Published by SuperPACs.com. Figures come from Federal Election Commission filings and the sources listed above. Read about how we work and our editorial standards.