22 Pop-Up PACs Hide $637 Million Donors Until December in Midterms

Twenty-two super political action committees formed in the final ten weeks before the 2026 midterm election have reported spending approximately $637 million on House and Senate races as of October 29. This figure represents about one-sixth of all independent spending reported in congressional contests this cycle. The groups are known as pop-up PACs because they register shortly before Election Day, delaying the public disclosure of their donors.

Federal law requires these committees to report large independent expenditures within 24 or 48 hours, detailing the amount spent and the candidates supported or opposed. However, donor identification occurs less frequently through periodic campaign finance reports. For groups formed after October 15, the first regular report identifying contributors is not due until December 3, a month after Election Day.

The surge in these late-forming groups has outpaced previous cycles. In 2022, five comparable groups spent about $18 million at the same point in the election. In 2018, three groups spent about $12 million. The current total has also surpassed the spending of comparable late-forming super PACs in the 2020 and 2024 presidential elections, which combined for less than $50 million in congressional races.

Michael Kang, a campaign finance professor at Northwestern Pritzker School of Law, stated that the primary reason for this trend is to avoid disclosure, even if only temporarily. He noted that known donors often find their cause undercut if their identity is public. Saurav Ghosh, director of federal campaign finance reform at the Campaign Legal Center, observed that the groups are spending more because the tactic works and they are getting away with it.

Many of these groups are linked to established political networks. Lower Costs Now, formed on September 10, disclosed an affiliation with Future Forward PAC, which backed Kamala Harris in 2024. Its first regular financial report, filed on October 15, showed that Senate Majority PAC had given the group $23 million. By October 29, Lower Costs Now had reported about $75.5 million in independent expenditures across eight Senate contests, including Iowa, Texas, Kansas, and Ohio.

Republican-linked PACs have used a similar strategy. No Going Back PAC formed on September 1 and began spending three days later. Public reporting linked it to MAGA Inc., Donald Trump’s marquee super PAC. Its formal financial report did not arrive until October 20, revealing that MAGA Inc. had supplied the group with $200 million. By October 29, No Going Back had spent roughly $242.2 million.

Fourteen of the 22 identified groups spent all of their money in a single congressional contest. The Maine Standard, formed on September 11, has spent $8.2 million opposing Democrat Troy Jackson in Maine’s Senate race. The Cornhusker Majority, formed on September 10, has spent about $7.1 million in Nebraska’s Senate race, almost all opposing independent Dan Osborn. Both groups were financed by Senate Leadership Fund, the GOP’s main Senate super PAC, a connection that did not appear in their regular reports until October 15.

Texas Forever, a Democratic group, launched on September 24 and had spent about $27.5 million by October 29 to help James Talarico in Texas. Unlike some other pop-up groups, its initial FEC filing identified the Senate Majority PAC as an affiliate. Texas PAC, which supports Republican Ken Paxton, had spent about $181.6 million by October 29. FEC filings showed Elon Musk had given Senate Leadership Fund $158 million, with the group transferring matching amounts to Texas PAC the day after each donation.

Texas PAC and No Going Back accounted for roughly two-thirds of all spending by the 22 million-dollar groups. Excluding these two, the remaining groups spent nearly 12 times as much as comparable late-forming super PACs did at the same point in 2022. Hilary Braseth, executive director of OpenSecrets, explained that locally branded PACs fragment the picture, causing voters to see a series of different groups operating race by race rather than one national organization.

The number of million-dollar late-forming super PACs has more than quadrupled since 2022, while their spending has grown nearly 35-fold. Kang noted that some donors may wish to hide away for a period while they are unpopular, such as with AI, while building a reputation for players inside the system.