The Money Map: Every Player and What Idaho Law Calls It

Every campaign dollar in Idaho moves through a short list of containers. Each container has a legal name, a set of things it may do, an office it reports to and a rule about whether its donors become public. Most mistakes, by new treasurers and by people reading their reports, come from putting a group in the wrong container. This lesson is the map. The rest of the course fills in each box.

This course is general education about Idaho and federal law, not legal advice. For an official answer on your own situation, contact the Secretary of State's elections division at sunshine@sos.idaho.gov or (208) 334-2852, your county clerk for local races, the FEC for federal races, or the IRS for tax status.

If you need the basic vocabulary first (contribution, independent expenditure, dark money), start with Campaign Finance Basics and Idaho's Sunshine Reports in the Elections and Campaign Finance course. This lesson goes a layer down.

For quick answers on which player may give to which, and when, use the matrix and Q&A in Who Can Give to Whom, and When.

Two rulebooks, one ballot

An Idaho general election ballot can carry a congressional race, a governor's race, a legislative seat, a county commission seat and a school levy. Two different bodies of law cover that one sheet of paper.

Idaho's chapter covers measures and "public office," which Idaho Code 67-6602(16) defines as local, legislative, judicial or state offices filled by election (the office of precinct committeeman is expressly left out). Measures are covered by their own definition in 67-6602(11). Federal offices are not on either list. The Secretary of State's September 2026 guidance on FEC-registered committees says it plainly: Idaho campaign finance law does not govern elections for federal office. Congress settled the same point from its side in 52 U.S.C. 30143, which says federal election law supersedes and preempts state law with respect to election to federal office.

So a candidate for the Idaho House follows Idaho limits and files on the state's Sunshine portal. A candidate for the U.S. House follows federal limits and files with the FEC. The same donor can give to both on the same day under two different limits.

A few federal rules reach into Idaho's own races anyway, and they trip people up:

• Foreign money. 52 U.S.C. 30121 bans contributions by foreign nationals "in connection with a Federal, State, or local election." Idaho added its own ban in 2021 (Idaho Code 67-6610D), which also bars foreign nationals from paying for independent expenditures or electioneering communications in Idaho races and makes a knowing violation over $1,000 in 12 months a felony. Lesson 2 covers both.
• National banks. 52 U.S.C. 30118 bars national banks and federally chartered corporations from contributing in connection with any election, state and local included.
• Tax law. A nonprofit's tax-exempt status depends on IRS rules no matter which race it gets involved in. A 501(c)(3) that endorses a city council candidate has an IRS problem even though the FEC has nothing to say about it.

The words Idaho law uses

Idaho Code 67-6602 is the dictionary for everything else in the chapter. A handful of its definitions decide who has to do what.

A candidate is someone seeking nomination or election who has done any one of four things: announced publicly, filed for office, received a contribution to promote the candidacy, or made an expenditure, contracted for services or reserved space to promote it. An incumbent is presumed to be a candidate for the next election until the filing deadline passes without a declaration. That last clause matters for officeholders who keep raising money between elections.

A contribution under 67-6602(3) is nearly anything of value given to support or oppose a candidate, political committee or measure: money, loans, pledges, forgiven debts, goods, and personal or professional services given for less than full price. It includes the candidate's own money and money of members of the candidate's household spent on the campaign, but not personal funds used to pay the candidate filing fee. It excludes part-time volunteer work, ordinary home hospitality and up to $25 of incidental expenses a volunteer pays personally. Lesson 2, Who Can Give and How Much, has the fine print.

A political committee is the box most groups land in. Under 67-6602(14) it is either (a) any person specifically designated to support or oppose any candidate or measure, or (b) any person who receives contributions and makes expenditures over $1,000 in a calendar year to support or oppose candidates or measures. "Person" in Idaho's chapter means an individual, corporation, association, firm, partnership, committee, party, club or any other group. A county, district or regional party committee is not a political committee until its expenditures exceed $5,000 in a calendar year.

Notice what is missing. Idaho's statute has no separate category called a ballot measure committee, an independent expenditure committee or a Super PAC. Those are political committees, described by what they spend on. The Secretary of State's Campaign Finance Disclosure Manual uses "political committee" for both PACs and party central committees.

A measure also has a precise start date. Under 67-6602(11), an initiative or referendum becomes a measure when the attorney general, county prosecutor or city attorney reviews it and gives it a ballot title, and a recall becomes one when the petition is approved as to form. Money raised before that point still counts if it is raised to support or oppose the effort, but the date matters for when some filings begin.

Other definitions catch people who never meant to become filers:

• An independent expenditure is spending on a communication that expressly advocates the election, passage or defeat of a clearly identified candidate or measure, made without cooperation, consent or consultation with the candidate or the committee on that side. Under 67-6611, any person spending more than $100 this way on one candidate, committee or measure files a statement, and spending of $1,000 or more in the last 16 days before an election (until 48 hours out) needs a statement within 48 hours.
• An electioneering communication unambiguously refers to a candidate within 30 days before a primary or 60 days before a general and reaches that office's voters, by broadcast, newspaper, billboard, mail, hand delivery, phone calls to homes or other distribution. Under 67-6628, whoever pays more than $100 files a statement that lists people who gave the filer $50 or more. Lesson 5, Independent Expenditures and Electioneering, works through both.
• A nonbusiness entity is a group not organized mainly for profit that got more than 10 percent of its receipts from contributions, gifts or dues. Under 67-6606, if it is not a political committee and spends more than $1,000 in a year on Idaho candidates or measures, it files within 30 days and names everyone who paid it more than $500 in either of the two prior years, or who paid or agreed to pay more than $500 in the current year.

The players, one at a time

Candidate committees

Idaho law speaks of a candidate and the candidate's political treasurer. In practice the campaign account is the candidate committee. It takes contributions within the limits in 67-6610A, spends on the campaign, and reports monthly in an election year. Every candidate must appoint a treasurer and certify the name to the Secretary of State before taking or spending a dollar (67-6603). County, city, special district and judicial candidates do not have to start filing reports until they raise or spend $500 (67-6608). Lesson 3, Running a Candidate Committee, is the how-to.

PACs, including candidate-run PACs

A PAC that supports or opposes several candidates is a political committee that may take unlimited contributions in Idaho, then give to candidates within the candidate's limits. Some are run by officeholders. The Idaho Capital Sun reported that Idaho Summit PAC, chaired by a legislator who co-chairs the budget committee, took a $200,000 contribution from one Boise individual on March 13, 2026, tied for the largest individual contribution in Idaho that year. That is legal: Idaho caps what a candidate may receive, not what a PAC may receive. The Secretary of State's campaign tip sheet adds that a candidate's PAC may spend only on other candidates, not on the candidate's own race.

Party committees

Party committees have their own limits for giving to their candidates under Idaho Code 67-6610A(2): any county or state central committee may give a legislative candidate up to $2,000 per election, and the state central committee may give a statewide candidate up to $10,000 per election (lesson 2 has the table). A county, district or regional committee becomes a political committee only above the $5,000 spending line in 67-6602(14)(c). In 2026 parties gained something new: after the U.S. Supreme Court's June 30, 2026 decision in NRSC v. FEC, the Secretary of State said in Guidance 2026-3 it will not enforce Idaho's limits against a party's coordinated spending for its nominees in the 2026 general election. Direct party gifts to candidates are still limited.

Ballot measure committees

A committee formed to pass or defeat an initiative, referendum, bond, levy or recall is a political committee. No Idaho law caps what it may raise. The Capital Sun reported that the Natural Medicine Alliance of Idaho PAC, backing a medical cannabis initiative, received $715,000 between February 17 and March 23, 2026 from an LLC of the same name, the Natural Medicine Alliance of Idaho LLC, the largest single source of Idaho campaign money that year to that point. Lesson 7, Ballot Measures and Issue Campaigns, covers measure campaigns in depth.

Independent spenders

Anyone can spend independently: an individual, a company, a union, a nonprofit. Idaho Education News reported in May 2024 that Melaleuca, an Idaho Falls corporation, spent about $5,900 on independent expenditures in one 2024 legislative primary, including $5,302 opposing one candidate. A business that does this does not become a PAC by the act alone; it files 67-6611 statements. If it starts raising money from others for the purpose, it is acting like a political committee and should register as one.

Nonbusiness entities

The Secretary of State's September 2026 guidance for nonprofits gives such a group a choice when it wants to spend on Idaho elections: form a PAC and disclose only the PAC's donors, or spend from the general fund and file a 67-6606 statement disclosing everyone who paid it more than $500 for any reason. The office recommends the PAC. The guidance also says unpaid activity (a public speech, an email to members, volunteer work, an unpaid social media post, or passing out materials someone else paid for and reported) generally does not require reporting.

Federal PACs and Super PACs

A committee registered with the FEC is still bound by Idaho law when it plays in Idaho races. In 2024, Senate Bill 1251 removed the exemption that had kept FEC-registered committees from counting as Idaho political committees. The Legislature's bill record shows it signed and effective April 4, 2024; the Secretary of State's guidance gives April 3. Under the Secretary of State's 2026 guidance, a federal PAC that only writes checks to Idaho candidates from its federal account does not have to register in Idaho, so long as the check comes from its federal account, it is current with the FEC, the money is not earmarked, and the Idaho recipient lists the PAC's FEC ID number on its report (the guidance's example: "Potato Lovers PAC (FEC ID: C00894758)"). A federal committee that raises money for Idaho races, makes in-kind gifts or runs its own Idaho campaign activity must register and report in Idaho.

A Super PAC is a federal committee that may take unlimited money, including from corporations and unions, to pay for independent spending, and may not give to federal candidates (a gift to an Idaho candidate falls under Idaho limits; see lesson 13). Its donors are reported to the FEC. A Hybrid PAC keeps two bank accounts, one unlimited for independent spending and one limited for candidate contributions. The FEC's page on nonconnected PAC types describes both. Lesson 4, Forming and Running a PAC, explains where they came from.

Nonprofits: 501(c)(3), (c)(4) and (c)(6)

The tax code sorts nonprofits by purpose, and the purpose sets how much election work they may do. The IRS comparison chart rates candidate election advocacy as "NO" for 501(c)(3) charities and "LTD" (limited) for 501(c)(4) social welfare groups, 501(c)(5) unions and 501(c)(6) business leagues such as trade associations and chambers of commerce. The IRS says 501(c)(3) groups are "absolutely prohibited" from intervening in campaigns for or against candidates, though nonpartisan voter education and registration are allowed. Ballot measures count as lobbying for a charity, not candidate intervention, which is a different and looser limit. Lesson 8, Nonprofits in Politics, goes deep.

One question comes up often enough to answer here. A 501(c)(3) may not give to an Idaho PAC that supports or opposes candidates, or to a party or candidate committee; the IRS says no in so many words. It may give to a committee formed only for a ballot measure, and the gift counts as lobbying. Lesson 8 walks through both answers in its section "Can a 501(c)(3) give to an Idaho PAC?"

Donor privacy is the part people care about. Under 26 U.S.C. 6104, the IRS does not make public the names and addresses of contributors to exempt organizations other than private foundations and 527 political organizations. A nonprofit's Form 990 is public. Its donor list generally is not.

527 political organizations

Every campaign committee and PAC is a "political organization" under section 527 of the tax code; the IRS's political organizations page says so in as many words. Some 527s that are not state or federal committees file donor reports with the IRS on Form 8872. The statute, 26 U.S.C. 527, excuses state and local candidate committees, state and local party committees and groups expecting less than $25,000 a year from the initial IRS notice. Lesson 4 explains which Idaho PACs still owe the IRS paperwork.

LLCs

An LLC can give to Idaho candidates within the limits and can give unlimited amounts to PACs and measure committees. Two rules keep this from becoming a loophole. Idaho Code 67-6610A(6) treats related entities as one contributor when they share most of a board, share two or more officers, have the same majority owners, or are parent and subsidiary. And Idaho Code 30-25-201 requires every Idaho LLC's certificate of organization to name at least one governor, which gives you a name to start with when an LLC shows up on a report. Federally, the FEC treats an LLC as a corporation or a partnership depending on how it files with the IRS, which decides whether it may give to federal candidates at all: a corporate LLC may not.

The whole map in one table

Player	What the law calls it	What it may do	Reports to	Donors public?
Idaho candidate committee	Candidate and political treasurer (67-6603)	Raise within 67-6610A limits; spend on the campaign and officeholder duties	Secretary of State, Sunshine portal (local candidates once at $500)	Yes: name, address and amount for anyone over $50 a year
Idaho PAC	Political committee (67-6602(14))	Raise unlimited; give to candidates within limits; spend independently; fund measures	Secretary of State	Yes, over $50
Party central committee	Political committee (county level only above $5,000)	Give within party limits; coordinated spending for nominees in the 2026 general without limit under SOS guidance	Secretary of State	Yes, over $50
Ballot measure committee	Political committee	Raise and spend unlimited on a measure	Secretary of State	Yes, over $50
Independent spender (person, business, union)	Person making independent expenditures (67-6611)	Unlimited express advocacy, uncoordinated	Secretary of State statements	Payees over $50 are listed; the spender's own funders are not, unless another rule applies
Electioneering sponsor	Person making electioneering communications (67-6628)	Ads naming candidates in the 30 or 60 day windows	Secretary of State statements	Yes: people who gave the filer $50 or more
Nonprofit spending from its general fund	Nonbusiness entity (67-6606)	Spend on Idaho candidates or measures	Secretary of State within 30 days of passing $1,000	Yes: anyone who paid it over $500 in either prior year, or paid or agreed to pay over $500 in the current year
Federal candidate committee	Principal campaign committee	Federal races only, federal limits	FEC	Yes, over $200, with occupation and employer
Federal PAC	SSF (connected) or nonconnected committee	Give to federal candidates; may give in Idaho races under Idaho rules	FEC; Idaho too if it takes part directly in Idaho races	Yes, over $200
Super PAC	Independent-expenditure-only committee	Unlimited independent spending; no gifts to candidates	FEC	Yes, but a donor may be a nonprofit or LLC
501(c)(3) charity	Charitable organization	No candidate intervention and no gifts to candidate PACs; nonpartisan voter work; limited lobbying, including on measures and gifts to measure-only committees	IRS Form 990	Generally no
501(c)(4), (c)(5), (c)(6)	Social welfare, labor, business league	Some political activity, not the primary activity	IRS Form 990; Idaho reports when it spends on Idaho races	Generally no to the IRS public; yes in Idaho if it files as a nonbusiness entity
Other 527 group	Political organization	Political activity is its purpose	IRS Forms 8871 and 8872 unless exempt	Yes, on Form 8872
LLC	Person; related entities count as one (67-6610A(6))	Give within limits to candidates; unlimited to PACs and measures	Shows up on the recipient's report	Its owners are not listed on campaign reports; Idaho business filings name a governor

Following money through layers: a real Idaho chain

Here is how the boxes connect, using money that was reported in public during the 2024 legislative primaries. Idaho Education News reported on May 10, 2024 that the sitting governor's campaign committee gave $500,000 to the Idaho Victory Fund in March 2023. The Idaho Victory Fund gave $660,000 to the Idaho Liberty PAC, a Boise PAC, which had spent more than $884,000 in the primaries since April, much of it against four sitting state senators.

A candidate committee to a fund to a PAC to ads. Three layers, every one on a public report, and every transfer legal on its face: a candidate may use campaign funds for other lawful purposes under 67-6610C, and Idaho caps no PAC's receipts.

The Idaho Capital Sun's May 28, 2024 roundup showed the same pattern arriving from outside the state. The Idaho Federation for Children, an Idaho PAC focused on school choice, took all $400,000 it raised before the primary from the American Federation for Children's Victory Fund, a Dallas-based national Super PAC. The Citizens Alliance of Idaho, another Idaho PAC, got $390,000 from Citizens Alliance Political Action Committee Inc., a federal PAC, and spent nearly $400,000 for and against legislative candidates.

Read side by side, the lesson is the same for all three. The Idaho report tells you the last stop before the voter. The FEC report, or the next Idaho report up the chain, tells you the stop before that. Where the chain reaches a nonprofit or an LLC, the public record usually stops, and you say so.

Questions and answers

These are the questions the Secretary of State's office, county clerks and new treasurers hear most about who counts as what. For the full give-to-whom matrix, see lesson 13.

Our homeowners association wants to send one mailer against a road bond. Does that make us a PAC?

Not by itself. An association that was not formed for the bond becomes a political committee only if it receives contributions and makes expenditures over $1,000 in a calendar year for the purpose, under 67-6602(14)(b). But a mailer that urges a no vote is express advocacy, so if it costs more than $100 the association files an independent expenditure statement under 67-6611. If the association spends more than $1,000 from its general fund, the nonbusiness entity statement in 67-6606 also comes into play, and that one names dues payers over $500. Many associations avoid the last result by forming a small PAC and asking members to give to it directly.

I'm running for precinct committeeman. Do I file Sunshine reports?

Not as a candidate. Idaho Code 67-6602(16) defines "public office" to exclude the office of precinct committeeman, so the chapter's candidate rules do not reach that race. A group that spends to help or hurt precinct candidates should still ask the Secretary of State's elections division how its spending is classified, because the chapter's other definitions turn on candidates and measures, not on who the spender is.

An incumbent says she isn't running again but keeps raising money. Is she still a candidate?

Yes, for reporting purposes. Under 67-6602(1) an incumbent is presumed to be a candidate for the next election until the filing deadline passes without a declaration of candidacy. Her committee keeps filing, and the contribution limits keep applying, until then.

When does an initiative turn into a "measure" under the Sunshine Law?

When the attorney general, county prosecutor or city attorney reviews it and gives it a ballot title, according to 67-6602(11). A recall becomes a measure when the petition is approved as to form. Paid signature gathering has its own reports under 67-6612 starting on the date petitioners receive the official ballot title. Lesson 7 covers petition campaigns.

We're a federal PAC. Do we need to register in Idaho to give a legislative candidate $1,000?

Usually not. Guidance 2026-4 says no separate Idaho registration is needed when the check comes from your FEC account, you are current on federal reports, and the money is not earmarked for that candidate. The candidate reports it with your FEC ID number. If you start raising money for Idaho races, make in-kind gifts or pay for campaign activity here, you register as an Idaho political committee.

Is there such a thing as an Idaho Super PAC?

Not as a legal category. Idaho has political committees, and any political committee may raise unlimited amounts, because 67-6610A limits what candidates receive, not what committees receive. A committee that only spends independently is often called a Super PAC in news stories, but on the Sunshine portal it is a political committee like any other. When it gives to a candidate, the candidate's limit applies.

An LLC gave $5,000 to a PAC. How do I find out who owns it?

Start with the Secretary of State's business records. Idaho Code 30-25-201 requires every Idaho LLC's certificate of organization to name at least one governor, and the record shows the registered agent. Owners beyond that often do not appear anywhere public. Report what the records show and say plainly where they stop.

Who gives an official answer on whether my group must register?

The Secretary of State's elections division, at sunshine@sos.idaho.gov or (208) 334-2852. Its guidance documents say questions about a specific transaction may be sent to the office before the transaction happens. For federal races ask the FEC, and for tax status ask the IRS.

Hard questions

Isn't disclosure just a way to expose donors to harassment?

It can be used that way, and courts have said so. In Buckley v. Valeo (1976) the Supreme Court upheld federal disclosure because it informs voters and deters corruption, but it also said a group that shows a reasonable probability of threats, harassment or reprisals can win an exemption case by case. In Citizens United v. FEC (2010) the Court upheld disclaimer and disclosure rules 8 to 1. Idaho's design draws its own line: candidates and committees list donors over $50, and a nonprofit can keep general donors off the public record by routing political money through a separate PAC, as Guidance 2026-5 recommends. People who want less disclosure and people who want more both have real cases to cite; lesson 8 covers Americans for Prosperity Foundation v. Bonta (2021).

Why can a PAC take a $200,000 check when I can give a legislative candidate only $1,000?

Because Idaho's limits in 67-6610A are written around candidates. They cap what a candidate and committees organized on the candidate's behalf may receive, and they leave other committees alone. The reasoning traces to Buckley, which upheld contribution limits to candidates as a guard against the reality or appearance of corruption, and to later federal rulings that money for independent spending does not carry the same risk. When that PAC gives to a candidate, the $1,000 limit applies to the PAC too. Whether the gap is a loophole or a fair line is a policy argument the Legislature can change; the current statute is what treasurers have to follow.

If donor names stop at a nonprofit or an LLC, what is the point of any of this?

The trail stops less often than people think. A nonprofit that spends more than $1,000 of its own money on Idaho races must name everyone who paid it more than $500 under 67-6606, and an electioneering sponsor names people who gave it $50 or more under 67-6628. Related LLCs count as one donor under 67-6610A(6). The real gap is a nonprofit funded by another nonprofit, where the list shows the first funder's name and stops. A reader is better off knowing exactly where that gap sits than being told the whole system is either airtight or useless.

Why should two neighbors with $1,200 be treated like a professional PAC?

The statute does not scale by size: once a group receives and spends more than $1,000 for an election purpose, 67-6602(14)(b) makes it a political committee. The law does soften the load for small local efforts. Under 67-6608, a committee designated for a local measure does not start filing until it raises or spends $500, and an undesignated one working on local races does not start until $1,000. The forms are online and free. The paperwork is a real cost for volunteers. The trade the law makes is that voters reading the mailer get to know who paid for it.

Why should federal law override Idaho in races for Congress?

Congress wrote it that way. 52 U.S.C. 30143 says federal election law supersedes and preempts state law with respect to election to federal office, so one set of limits and reports covers a House candidate whose donors may live in any state. Idaho keeps full control over state, legislative, judicial and local races and every Idaho measure. Some federal rules, such as the foreign national ban and the national bank ban, reach Idaho's own races because Congress wrote them to cover state and local elections too.