This bill amends the Federal Election Campaign Act to force corporations, labor organizations, Super PACs, and similar entities to disclose detailed information about campaign‑related spending and the people who ultimately control or fund them. It creates a new 24‑hour reporting obligation once an entity’s campaign‑related disbursements exceed a $10,000 trigger in an election reporting cycle, requires beneficiary/beneficial‑owner disclosure for many non‑public corporations, treats certain transfers between entities as reportable, and directs FEC coordination with FinCEN.
The DISCLOSE Act also expands the statutory ban on foreign money to cover many digital placements, paid online promotions, electioneering communications, some ballot initiative activity by certain covered foreign principals, and disbursements that fund covered transfers; it creates a new felony for forming entities to conceal foreign contributions, centralizes judicial review of constitutional challenges in D.C., and tightens ad disclaimers (the “Stand By Every Ad” provisions) including top‑funder disclosure and adapted disclaimers for short or digital ads. Together, these changes aim to reduce ‘dark money’ in elections and make large third‑party spending more traceable — at the cost of new compliance obligations for nonprofit and corporate spenders and operational burdens for platforms and regulators.
At a Glance
What It Does
The bill requires any covered organization that makes more than $10,000 in campaign‑related disbursements during an election reporting cycle to file 24‑hour disclosure statements with the FEC listing recipients, large funders, and (for many corporations) beneficial owners. It expands the foreign‑national prohibition to include many paid online placements, court‑nomination advertising, and certain ballot initiative activity by specified foreign principals, and it creates criminal liability for using entities to hide foreign contributions.
Who It Affects
Non‑public corporations, 501(c) organizations (other than 501(c)(3)), limited liability companies not treated as corporations, labor unions, Super PACs and political organizations accepting non‑compliant accounts, major online platforms and third‑party ad vendors meeting user/traffic thresholds, and the FEC, FinCEN, and DOJ as enforcement partners.
Why It Matters
The bill operationalizes disclosure in the digital era: it treats many paid internet placements and third‑party transfers as within scope of campaign finance law and forces donor transparency up the ownership chain. That narrows anonymity channels used for large political expenditures and creates new enforcement tools — but it also raises compliance, privacy, and administrative questions for platforms, nonprofits, and regulators.
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What This Bill Actually Does
H.R.7802 creates a new, fast‑paced reporting regime for outside spenders. If a covered organization (think non‑public corporations, most 501(c) political actors, labor unions, and similar entities) makes campaign‑related disbursements that total more than $10,000 in an election reporting cycle, it must start filing statements with the FEC within 24 hours of the disclosure date.
The required statement must list payments over $1,000, recipients of those payments, the election or nominee impacted, and, where applicable, the names and addresses of persons who gave $10,000 or more to the entity during the lookback period. The bill distinguishes funds held in segregated accounts used solely for campaign disbursements and imposes slightly different disclosure rules for those accounts.
For companies that are not public issuers, the bill requires a beneficial‑owner disclosure: the entity must identify natural persons who exercise substantial control or receive substantial economic benefits, and it must trace control where those persons use other legal entities to exert influence. The bill lists standard exceptions (minor children, bare nominees, employees whose control derives solely from employment, creditors, etc.) but includes an anti‑abuse rule to prevent circumvention.
Organizations that claim harassment or reprisal risk can seek limited withholding of identifying information under a narrow safety exception, but the FEC will determine eligibility for this protection and must publish exemption materials (with redactions) and require reapplication every four years.The bill also tightens what counts as a disbursement under the foreign‑national ban. It explicitly brings expenditures, independent expenditures, electioneering communications, paid placements on websites/web apps and other digital apps, and certain internet activity that promotes or opposes candidates within the ban when paid for by designated ‘‘covered foreign nationals’’ (which includes foreign principals, agents of such principals, and specially designated nationals).
It adds a separate rule applying the foreign‑money prohibition to transfers that fund campaign activity — so money that moves through intermediaries to pay for political ads can be caught if the transfer meets the statute’s criteria.To stop concealment strategies, the bill creates a federal offense (up to 5 years in prison) for establishing or using a corporation or entity with intent to hide an activity by a foreign national that the ban would prohibit. For judicial nominations the bill treats disbursements for communications promoting or opposing a judicial nominee as campaign‑related for reporting purposes, with separate dollar accounting and a calendar‑year reporting cycle; the intent standard is not required — the content and medium control coverage.
Finally, the bill strengthens ad disclaimers: many non‑authorized audio, video, text, and graphic communications must carry an “I approve this message” style identifier from an individual (CEO, highest ranking officer, or payer), display a Top Five or Top Two Funders list when paid with campaign‑related funds (with adapted short‑ad rules), and provide a mechanism or landing page for detailed funder information. Several effective‑date rules apply: some provisions take effect on enactment, while major reporting, advertising, and foreign‑money expansions phase in (or explicitly apply) on or after January 1, 2027; the FEC must issue implementing regulations for certain exemptions within six months.
The Five Things You Need to Know
A covered organization must file a sworn FEC disclosure within 24 hours once campaign‑related disbursements exceed $10,000 in an election reporting cycle; the statement covers payments over $1,000 and names payment recipients.
Many non‑public corporations must list beneficial owners (natural persons who exercise substantial control or receive substantial economic benefits), including nested ownership chains, subject to narrow exceptions and an anti‑abuse rule.
The bill treats ‘‘covered transfers’’ as reportable where transfers were designated, solicited, discussed, or where the transferor knew the recipient would make $50,000 or more in campaign spending within two years; special affiliate rules and $50,000 aggregation thresholds apply.
An online platform is in scope if it sells qualified political ads and has 50,000,000+ unique monthly U.S. users for a majority of months in the prior year, or if a third‑party ad vendor aggregates 50,000,000+ unique monthly U.S. visitors on ad inventory it buys/sells.
The statute makes it a federal crime (up to 5 years imprisonment, fine, or both) for an officer, owner, attorney, or incorporation agent to form or use an entity with intent to conceal an activity of a foreign national prohibited by the foreign‑money ban.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Clarifies contribution/disbursement definitions under the foreign‑national ban
This section refashions 52 U.S.C. 30121(b) to define ‘‘contribution or donation’’ to include disbursements to political committees that accept non‑compliant money and payments to persons for expenditures, independent expenditures, or electioneering communications. Practically, it closes a legal gap that allowed funds to pass through intermediaries or into committees with permissive acceptance practices and escape the statutory foreign‑money prohibition.
GAO 4‑year study and report on illicit foreign money
The Comptroller General must study each 4‑year presidential cycle (starting with the cycle ending 2024) and report on the incidence of illicit foreign money in Federal elections, including available evidence of targeting of specific communities; the requirement sunsets after the 2036 cycle. This creates a recurring, centralized information task to inform Congress and enforcement agencies.
Extends foreign‑national prohibition to certain ballot initiatives for covered foreign principals
The bill amends section 319 to define ‘‘Federal, State, or local election’’ to include ballot initiatives and referenda—but only when the actor is a ‘covered foreign national’ (foreign principals, agents, nationals on OFAC lists, or persons controlled/financed in whole or major part by such principals). That narrows a path where foreign interests could influence state or local ballot measures through intermediaries.
Expands the statutory list of disbursements subject to the foreign‑money ban
This provision adds explicit coverage for expenditures, independent expenditures, electioneering communications, many paid online placements and promoted communications, internet activity that promotes or attacks candidates, and Federal judicial nomination communications when paid for by covered foreign nationals. The bill also defines ‘‘online platform’’ (50M+ unique monthly U.S. users or large third‑party ad vendors) and excludes distribution facilities of traditional broadcasters and publications, drawing a line between platform inventory and legacy media distribution.
Creates a criminal offense to conceal foreign national election contributions
Adds a new felony in 18 U.S.C. chapter 29 making it unlawful for an owner, officer, attorney, or incorporation agent to establish or use an entity with intent to conceal an activity of a foreign national prohibited under section 319; punishment is up to 5 years imprisonment, a fine, or both. The statute targets purposeful concealment but will raise questions about mens rea standards during enforcement.
24‑hour campaign‑related disbursement reporting and beneficial‑owner disclosure
This central reporting section requires covered organizations to file sworn statements with the FEC within 24 hours after each disclosure date once $10,000 in campaign‑related disbursements has been reached during an election reporting cycle. Reports must itemize disbursements over $1,000, name recipients, identify the relevant election or nominee, certify lack of coordination, and disclose donors who gave $10,000+ (with lookback). For many corporations the statement must include a list of beneficial owners with names and addresses and identify cases where control is exercised through other legal entities. The statute also defines campaign‑related disbursements, applicable public communications, covered transfers (including $50,000/2‑year thresholds and affiliate rules), and exemptions such as ordinary‑course commercial receipts and narrow harassment protections.
Special reporting rules for Federal judicial nomination communications
The bill treats disbursements promoting or opposing Federal judicial nominees as campaign‑related, requires separate dollar accounting and reporting for those communications (on a calendar‑year basis), and defines ‘Federal judicial nomination communication’ broadly to capture paid broadcasts, paid internet/digital ads, newspapers, and other general public political advertising that promotes or opposes a nominee. The section is structured to reveal who is shaping judicial selection despite existing FECA coverage gaps.
Stand By Every Ad: expanded disclaimers and top‑funder disclosure rules
Adds new disclaimer requirements for many audio, video, text, and graphic communications not authorized by candidates. Paid communications must include an individual or organizational approval statement (who approves) and, when campaign‑related funds partially finance the ad, a Top Five or Top Two Funders list (with thresholds and adapted short‑ad mechanisms), plus rules for prerecorded telephone calls and exceptions for certain party/committee content. The FEC must issue rules governing short‑duration and adapted disclaimers; the law provides mechanics for online adapted disclaimers and landing pages.
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Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Voters and the public — gain clearer, faster information about who is funding campaign ads and transfers, including identifying beneficial owners behind non‑public entities that finance political messaging.
- Campaigns and candidates — receive better transparency on outside spenders and potential foreign influence, helping detect coordination or targeted attacks funded by opaque actors.
- Regulators and investigators (FEC, FinCEN, DOJ) — obtain statutory authority and mandated interagency data sharing to trace transfers, identify beneficial owners, and pursue concealment or foreign‑money schemes.
- Journalists and researchers — access to 24‑hour disclosure filings and published exemption materials (with redactions) improves the ability to investigate dark‑money flows and donor networks.
- State and local election officials and watchdogs — benefit indirectly from the bill’s expansion of the foreign‑national ban to certain ballot initiative activity by covered foreign principals, aiding protection of local ballot integrity.
Who Bears the Cost
- Nonprofit advocacy groups and trade associations (501(c)(4) and similar entities) — face new reporting obligations, beneficial‑ownership disclosure (for some entities), and donor‑tracking work; these compliance costs may be significant for groups that run frequent digital campaigns.
- Corporations that engage in political communications (non‑public) — must identify beneficial owners, certify communications, and implement tighter internal controls to avoid criminal exposure for concealment schemes.
- Large online platforms and third‑party ad vendors meeting the 50M‑user threshold — must adapt ad‑serving and reporting systems to support adapted disclaimers, landing pages, and top‑funder disclosures, and to cooperate with FEC/FinCEN inquiries.
- Donors seeking privacy — individuals and businesses used to contributing anonymously will face reduced anonymity; even where harassment exceptions exist, many donors will incur privacy tradeoffs.
- The FEC, FinCEN, and DOJ — will need increased staffing, technical capacity, and funding to process 24‑hour filings, evaluate beneficial‑owner data, coordinate investigations, and litigate new statutory standards.
Key Issues
The Core Tension
The central dilemma is between transparency and the protection of speech and privacy: the bill strengthens disclosure to uncover dark money and foreign influence, but doing so inevitably reduces donor anonymity, increases regulatory burdens on nonprofits and platforms, and risks chilling lawful issue advocacy — all while shifting the practical success of the effort onto under‑resourced agencies and contested legal definitions.
The bill pushes disclosure into fast timeframes and into the digital ad ecosystem, but several implementation challenges and trade‑offs remain. The beneficial‑owner requirement fills a real investigative gap, yet tracing indirect control through layered entities is technically complex and may generate litigation over definitions (substantial control, substantial economic benefit) and the scope of exceptions.
The FEC will need clear regulation and resources to process 24‑hour reports, adjudicate harassment exceptions, and publish exemption decisions without leaking sensitive personal information. Its historical enforcement capacity is limited; the statute leans on FinCEN coordination but does not itself appropriate new funds, so the law’s practical efficacy depends on agency resourcing and data‑sharing protocols.
The advertising and foreign‑money expansions further blur lines between issue advocacy, paid public interest speech, and express electioneering. ‘‘Applicable public communication’’ and the coverage of paid internet placements introduce functional‑equivalence tests that can be hard to apply consistently across formats. Platforms and third‑party ad vendors may face significant technical changes to implement adapted disclaimers and landing pages, and the 50 million unique monthly U.S. user threshold could capture some large vendors while leaving fast‑growing niche platforms outside the regime.
Finally, the new criminal provision targets deliberate concealment, but proving intent in complex corporate formations can be difficult and may chill legitimate business incorporations or legal structuring unless prosecutors and courts clarify mens rea standards.
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