Political Action Committees (PACs)

There are many laws and rules pertaining to a candidate’s campaign activities.  We encourage candidates to contact the Board’s staff at (515) 281-4028 with any questions.   

Political Action Committees (PACs) Defined

Under Iowa Code section 68A.102, any organization or entity that accepts contributions, makes expenditures, or incurs debts in excess of $1000 to advocate for or against state, county or local candidates or for or against the passage of a ballot issue is a “political committee” or PAC. 

In Iowa, there are different types of PACs:

• An Iowa PAC (also known as a State PAC) advocates in favor or against statewide and legislative candidates.  
• A county PAC advocates in favor or against candidates for county office 
• A city PAC advocates in favor or against candidates for city office
• A school board and other political subdivision PAC advocates in favor or against candidates for school board or other political subdivision offices 
• A ballot issue PAC advocates in favor or against a ballot issue

Registering a PAC

An organization or entity that meets the definition of a PAC must register with the Ethics Board within ten days of crossing the $1,000 threshold.  An organization or entity registers a PAC by electronically filing a statement of organization.  A PAC that uses an abbreviation or acronym as part of its committee name shall provide in the description of the PAC the full word or words that are abbreviated or form the acronym.  The PAC name may not substantially duplicate the name of an already registered committee

A PAC must appoint both a chair and treasurer, each of whom shall be at least 18 years of age.  A PAC must either have an Iowa resident as the treasurer or maintain all of the PAC's funds in bank accounts in a financial institution located in Iowa. 

A PAC must update its statement of organization within 30 days of any changes to the statement’s information.  An amendment to the committee’s statement of organization must be done electronically using the Ethics Board’s web reporting system. 

The Chair and Treasurer’s Responsibilities

All PAC funds must be segregated from any other funds held by members, officers or associates of the committee.  However, a permanent organization that temporarily engages in activities that qualifies it as a PAC that only makes expenditures from its existing general operating funds is not required to open a separate account. 

No funds or property of a PAC may be used for the personal benefit of any officer or member of the PAC. 

Contributions to a PAC must be submitted to the PAC within 15 days of the date of the check.  This includes contributions from other PACs.  The PAC treasurer must deposit all contributions within 7 days of receipt.  PAC expenditures must be remitted to the designated recipient within 15 days of the date of the issuance of the payment.  

PAC treasurers must keep a detailed and exact account of the following: 

• All monetary and in-kind contributions
• The name and mailing address of every person making contributions in excess of $25 and the date and the amount of the contribution.  
• All disbursements made by the committee
• The name and mailing address of every person or entity to which any expenditure is made, the purpose of the expenditure, the date and amount of the expenditure 
• All unpaid debts 
• The name and mailing address of every person or entity to which any debt is owed, the purpose of the unpaid debt and the amount of the debt.  
• All loans
• The name and mailing address of every person or entity to which any loan is owed, and the amount of the loan. 

PAC treasurers must preserve all campaign records for a period of 5 years.  However, a committee is not required to keep records for more than 3 years from the certified date of the dissolution of the committee. 

Campaign Disclosure Reports

Every PAC is required to periodically report its financial activity to the Ethics Board using the Ethics Board’s web reporting system.  Reports must be electronically filed by 4:30 p.m. on the due date.  Reporting dates vary depending on the type of PAC and whether or not it is an election year.  See the Ethics Board’s brochure on reporting dates for the specific reporting deadlines by type of PAC.  A committee is required to file reports even if there is no financial activity during a reporting period until the committee is dissolved.      

Committees are responsible for knowing their reporting deadlines.  The Ethics Board strives to email every committee a reminder notice prior to every disclosure report filing deadline. However, these notices are merely a courtesy and the failure to receive a reminder notice is no excuse for an untimely report. Please contact the Board's staff if you need assistance determining your disclosure report filing deadlines.

Campaign Contributions

Iowa does not have campaign contribution limits.  A PAC may accept monetary and in-kind contributions from individuals, other PACs, and any entity that is not a prohibited contributor under section 68A.503 of the Code of Iowa.  Prohibited contributors are corporations, banks, credit unions, and insurance companies.  A committee must obtain the name and address of every contributor that gives more than $25, including through payroll deduction.  

A PAC or lobbyist may not give a candidate for statewide or legislative office a contribution on any during the regular legislative session and in the case of a gubernatorial candidate, during the 30 days following the adjournment of a regular legislative session.  See Iowa Code section 68A.504 for the exceptions for candidates running for federal office or a special election.  

A “paid for by” attribution statement is required on a PAC’s published material that is designed to expressly advocate the nomination, election or defeat of a candidate or the passage or defeat of a ballot issue.  Published material means any newspaper, magazine, shopper, outdoor advertising facility, poster, direct mailing, brochure, internet web site (including social media pages), campaign sign, or any other form of printed general public political advertising.  Published material also includes television, video, or motion picture advertising.  

An attribution statement is not required on bumper stickers, pins, buttons, pens, political business cards, matchbooks, t-shirts, caps, and other articles of clothing.  An attribution statement is also not required on yard signs that are 32 square feet or less in size.  However, an attribution statement is required on campaign signs affixed to buildings or vehicles regardless of size, except for bumper stickers.  

The attribution statement shall say “paid for by [name of registered PAC].”  See Iowa Code section 68A.405 and Iowa Administrative Code rules 351 4.38-4.39 for more detailed information about attribution statement.      

A PAC has a continuing obligation to file periodic disclosure reports until the committee is dissolved by filing a statement of dissolution using the Board’s web reporting system.  

A committee shall not dissolve until all loans and debts are paid, forgiven, or transferred, and the remaining funds in the committee’s campaign account are distributed. 

Prohibition on Iowa PACs

A PAC may not be established to advocate for or against only one candidate except for a judge standing for retention (68A.202(2)).  Thus PACs need to be careful when choosing a name for the committee (Citizens for Jones PAC is a bad idea) and must make sure to contribute to, or do work for, more than one candidate.

Candidates for state office may not establish, direct, or maintain a PAC (68A.303(5)).

PACs may not solicit or receive from an insurance company, savings and loan association, bank, credit union, or corporation any money, property, or thing of value belonging to any such entity for purposes of advocating for or against candidates (68A.503).

• Ballot issue PACs are NOT subject to this prohibition (68A.503(1)). 
• Use of corporate facilities is permitted when reimbursement is provided (rules 351-4.44 through 4.52).
• The parent entity of a PAC that would otherwise be prohibited from providing anything of value to the PAC may pay for the administrative costs of the PAC (rule 351-4.52) including:
  • Full or partial compensation of PAC staff (wages and benefits).
  • Expenses of transportation and travel for PAC staff (does not include expenses of transportation or travel if provided to a candidate or for expenses of meals or events held on behalf of a candidate).
  • Printing and office supplies related to routine office administration.
  • Postage and stationery including mailing contributions to candidates and for providing advocacy materials to PAC members only.
  • Expenses of maintaining committee records and preparing campaign reports.
  • PAC promotional materials (pens, coffee mugs) so long as the materials do not promote candidates.

The parent entity of a PAC that would otherwise be prohibited from providing anything of value to the PAC may also pay for the costs of soliciting the stockholders, administrative officers, and members for contributions to the PAC (68A.503(3) and rule 351-4.52).

• Employees who cannot be solicited may voluntarily contribute to the PAC.
• The Ethics Board defined "member" in IECDB Advisory Opinion 2000-20 to include individuals who are authorized to vote on corporate matters pursuant to by-laws or other organizational documents.
• In IECDB Advisory Opinion 2000-20, the Board opined that the prohibition on solicitations extended to non-supervisory personnel, clerical staff and associates.          

PACs may not contribute to, act as an agent or intermediary for contributions to, or arrange for the making of monetary or in-kind contributions to state officeholders (both executive branch and legislators) or candidates for state office (statewide and legislative) on any day during the legislative session.  The prohibition extends for an additional 30 days after session for contributions to the Governor or any gubernatorial candidate (68A.15A).

• The prohibition does not apply if the officeholder is seeking federal office and the contribution is made to the federal campaign.
• The prohibition does not apply to a special election held during session so long as at least two candidates have been nominated.
• In IECDB Advisory Opinion 2001-01, the Ethics Board opined that the prohibition applied only during the "regular legislative session" and did not apply during any "special session."

PACs may not receive anonymous contributions in excess of $25 (68A.501).  Such funds must escheat to the State of Iowa general fund.  

Contributions shall not be made or received in the name of another person (68A.502).  Campaign reports must disclose the actual name of the person who made the contribution.

•  If a PAC receives a contribution that is "earmarked" to then be given to a specific candidate or committee, the PAC is required to disclose on its campaign report the name of the contributor and the committee that the contribution has been earmarked.  When transferring the money to the subsequent committee, the PAC must inform the treasurer of the recipient committee the name of the individual contributor.  The committee receiving the earmarked contribution must disclose both the name of the original contributor and the PAC that forwarded the contribution (rule 351-4.33).

Candidates are not permitted to make contributions to PACs from campaign funds (68A.302 and 68A.303) except for the purchase of PAC fundraiser ticket and the candidate attends the event.  The candidate may also pay for one guest to attend the fundraiser if the attendance of the guest would enhance the candidate's candidacy (rule 351-4.25(1)"h").

All PAC expenditures must be by check. Cash withdrawals and petty cash are not permitted.  If PAC fundraising event requires a cash drawer for making change or other cash transactions, the PAC may issue a check payable to a PAC officer to be cashed (rule 351-4.36).        

PACs may not use any resources or property of the government to advocate for or against candidates or ballot issues unless the governmental entity has a written policy that would allow any group (regardless of whether or not for political purposes) to use the resources or property of the governmental entity (68A.505A).

Out-of-State PACs/Federal PACs (VSR filings)

Information on this page is for out-of-state and federal PACs seeking to contribute to committees in Iowa. See 351 IAC - 4.32 for specific guidance.

Use the IECDB Web Reporting System to obtain a new out of state committee to file VSRs with us.