In the 2024 election cycle, super PACs spent a reported $2.7 billion at the federal level, up from roughly $1.4 billion in 2022. And in 2025, super PACs poured tens of millions into state and local races, including the New Jersey gubernatorial race and the New York City mayoral race. As we head into the 2026 mid-term election year, super PACs are set to again spend significant sums at various government levels, from U.S. House and Senate races to mayoral campaigns.
Despite the significance of super PACs in today’s elections, political consultants seeking to set them up still have little real-world guidance to draw upon. In 2016, Covington published a guide of rules and practical steps for forming and operating federal super PACs. In response to that guide’s popularity—and evolving legal requirements—we have updated the information for the 2026 elections. Importantly, unlike our prior guidance, this roadmap discusses how these powerful spending vehicles operate in states and localities as well.
In this alert, we address key legal compliance topics, as well as best practice tips that Covington has developed over more than a decade advising large and small super PACs across the country.
