Dark Money on TV in the 2024 Elections

(MIDDLETOWN, CT) March 14, 2025 – The Wesleyan Media Project (WMP) has examined the sponsorship of advertising on television in federal races during the 2023-24 election cycle.  In this report, the WMP is focusing on advertising by outside groups, looking specifically at different group types.  In partnership with OpenSecrets, the Wesleyan Media Project classifies groups in two ways.  First, we identify groups by their tax and regulatory classifications, such as Super PACs, traditional PACs, or non-profit 501c4s.  Second, we label groups based on their donor disclosure.  Classifications on this measure fall into three types: full-disclosure groups (meaning they disclose contributor lists to the relevant reporting agency at the federal or state level), non-disclosing dark money groups (which are not required to disclose publicly their donors; these are most often 501c4 non-profits), and partial-disclosure groups (those that disclose donors but also accept contributions from dark money sources; many Super PACs fall into this category).  For quick primers on these classifications, check out the overviews from OpenSecrets on PACs and dark money.

Dark money advertising can appear in elections as either ads sponsored directly by non-disclosing groups or ads from partially-disclosing groups that accept contributions from dark money sources.  In this report, we break out spending by all three disclosure types but pay specific attention to ads sponsored by non-disclosing groups.  As we note below, these groups spent over $276 million on television ads in federal races during the 2023-24 election cycle.   This total, and our figures below, exclude spending by outside groups on local cable stations, streaming applications, digital platforms (e.g., Meta), and radio.  They only consider spending on local broadcast stations (e.g., the ABC affiliate in Green Bay) or national cable and network stations.

In Table 1, we list the top 20 outside groups by ad airings from the full cycle.  These twenty groups jointly sponsored nearly 1.1 million ad airings, which comprises two-thirds of all outside group TV spots in federal races.  Of the top 20 groups, 15 percent of their airings–168,000 spots–were from dark money, non-disclosing groups.  The most active non-disclosing group was One Nation, which sponsored over 46,000 ad airings in seven Senate races.  Notably, One Nation stopped its ad buys on September 4, right at the start of the 60-day federal reporting window for ads aired before general elections.  Only one non-disclosing group from Table 1 aired ads well into the fall general election–Last Best Place PAC, which is a Super PAC.  We expand on the timing of ad airings at the end of this report.

In Table 2, we break out spending by disclosure for the presidential race and in congressional races.  All told, outside groups sponsored over $2.2 billion in broadcast television ads, with $900 million in the presidential race (inclusive of the primary and general election phases of the cycle), $775 million in Senate races, and $560 million in U.S. House races.  Of the total outside group spending, 12 percent was directly from non-disclosing groups.  Two-thirds of outside group spending was from partially disclosing groups.

Discussions of dark money can be complicated because some non-disclosing groups are so labeled in our data because they are super PACs that accept only dark money contributions.  This kind of Super PAC still reports to the Federal Election Commission (FEC).  For example, Last Best Place PAC, as noted above, sponsored 39,000 ad airings in the Montana Senate race right up until Election Day.  Its primary donor, however, was Majority Forward, which is itself a 501c4 non-profit.  This donor arrangement obscures the interests behind Last Best Place PAC.  Groups that are 501c4s that sponsor ads directly in federal races, without expressly advocating for a candidate, are not required to report to the FEC if their ads air outside the so-called electioneering communication windows, which are 30-days before a primary election and 60-days before a general election.  As we note below, many 501c4 groups target their ad buys outside these windows, avoiding both spending reporting requirements and donor disclosure mandates.

In Table 3, we show the distribution of spending by these types of groups, comparing PACs (of all stripes) with non-profits, corporate spenders, and coalitions.  All told, these non-disclosing groups sponsored $242 million in ads during the 2023-24 election cycle.  A very small percentage of this spending was from groups that are modestly transparent, including some ads from a 501c5 union and nearly $840,000 in ads from a coalition that was labeled as partially disclosing.

As noted, 501c groups can avoid reporting to the FEC if they air ads outside the electioneering communication windows.  To get a general sense of the timing of outside group efforts in House and Senate races, we show in Figure 1 (for House) and Figure 2 (for Senate) the volume of broadcast ads by outside groups over the course of calendar year 2024. In the top panel, we show the volume of ads by group disclosure type for each week in the election year. The bottom panel shows the percentage of group-sponsored ads aired each week by disclosure type.  We previously reported on this at the end of the election, but we update the figures through Election Day in Figures 1 and 2.  Of primary interest in these graphs are the sponsor breakdowns of ads in the final 60 days of the general election period, which cover the final nine or so weeks of the campaign.  (A more comprehensive overview of spending around the 30-primary window would need to consider different primary dates in different states.)

For both House and Senate races, the volume of ads by groups rises considerably as Election Day approaches, particularly in House races over the last few weeks. Notably the vast majority of outside group ads in the past seven weeks were from partially disclosing groups.  A spike in partially disclosing groups matches the start of the 60-day pre-election window, where outside group ads must be reported to the Federal Election Commission if they mention or picture a federal candidate. By funding those ads through partially disclosing super PACs, the sponsors can still obscure their underlying donor base.

Brendan Glavin from OpenSecrets notes the following about partially disclosing groups: “It is crucial to shed light on the increasing amounts of dark money we are seeing in our elections. In fact, much of it is being spent under the pretense of full disclosure by super PACs that are substantially funded by non-disclosing groups, such as nonprofits.”

Beyond this, a brief case study is worth making clear the way groups time their ads to avoid disclosure.  Consider ads from One Nation in the Wisconsin Senate race.  The primary election in Wisconsin took place on August 13, 2024.  Neither party’s primary was competitive, but the general election was expected to be a toss-up.  One Nation sponsored 3,700 broadcast spots in the period between August 14 (the day after the primary) and September 3 (3 days before the start of the 60-day reporting window).  As such, none of this spending–which totaled nearly $4 million–was reported to the Federal Election Commission as election-related.