More than $1 billion in political spending in 2026 will come from organizations that never have to reveal their donors. The dark money ecosystem has grown every election cycle since Citizens United. Here is who is spending and what we cannot know.
- $1B+ projected undisclosed political spending in 2026 — up from ~$300M in 2010, the first post-Citizens United midterm
- Largest R dark money: Crossroads GPS (Karl Rove-affiliated 501(c)(4)); largest D: Arabella Advisors network (Sixteen Thirty Fund + New Venture Fund)
- Citizens United v. FEC (2010) enabled unlimited 501(c)(4) "issue advocacy" — no donor disclosure required, unlike Super PACs which must report to FEC
- DISCLOSE Act passed the House twice (2010, 2022) — blocked by Senate filibuster every time; Republican senators have unanimously opposed disclosure requirements
Dark Money Growth Since Citizens United
| Election Cycle | Est. Dark Money Spent | R vs. D Ratio | Primary Channels |
|---|---|---|---|
| 2010 (first post-CU mid.) | ~$300M | R 60 / D 40 | TV ads; issue advocacy |
| 2012 Presidential | ~$400M | R 58 / D 42 | TV; direct mail |
| 2014 Midterms | ~$500M | R 57 / D 43 | TV; digital expanding |
| 2018 Midterms | ~$750M | R 50 / D 50 | D dark money surged post-2016 |
| 2022 Midterms | ~$900M | D 52 / R 48 | Arabella network dominated D side |
| 2026 Midterms (proj.) | $1B+ | Near parity projected | Digital, TV, ground game grants |
The Arabella Network: Democratic Dark Money at Scale
The Arabella Advisors-managed network became the largest dark money infrastructure in American politics during the 2020–2022 cycle. The network includes the Sixteen Thirty Fund (the primary fiscal sponsor), the New Venture Fund, the Windward Fund, and dozens of pop-up campaign organizations that appear and disappear around specific elections. Donors give to the network; the network allocates funding to campaigns and issue ads without the donor names appearing in FEC disclosures.
The network’s total spending in 2020 exceeded $1.6 billion across all activities, including both electoral and non-electoral advocacy. The electoral component is harder to isolate. Investigative reporting by OpenSecrets, the Lever, and the Washington Free Beacon has traced significant portions of the spending to congressional races in Georgia, Arizona, Nevada, and Pennsylvania during the 2020–2022 cycle.
Republican Dark Money: Post-Rove Evolution
Karl Rove’s Crossroads GPS was the dominant Republican dark money vehicle from 2010 to 2014. After several high-profile expensive losses in 2012, the Republican dark money ecosystem diversified. Koch brothers-affiliated organizations, including Americans for Prosperity (now more focused on policy advocacy) and the 85 Fund (judicial nominations), represent a different wing of the network than Rove’s campaign-focused operations.
In the Trump era, Republican dark money increasingly flows through Trump-adjacent organizations and MAGA-affiliated 501(c)(4) groups rather than the traditional establishment infrastructure. The fragmentation of Republican dark money makes it harder to track than the Arabella network’s centralized structure, but the total volume has grown comparably. For 2026, the Republican Attorneys General Association (RAGA) and allied groups are also expected to deploy significant undisclosed spending in competitive states.
The DISCLOSE Act: Why It Has Not Passed
The DISCLOSE Act, which would require 501(c)(4) organizations making independent expenditures to disclose donors above $10,000, has been introduced in every Congress since 2010. It has majority support in the House and among the American public (polls consistently show 70%+ supporting donor disclosure in politics). But it has never cleared the Senate filibuster, which requires 60 votes.
Republicans argue the act would chill political association by exposing donors to harassment campaigns. Democrats argue it is essential for democratic accountability. The political reality is that Republicans benefit from the current system nearly as much as Democrats, despite rhetoric to the contrary, and neither party leadership has made dark money disclosure a non-negotiable priority. The FEC, with 3-3 partisan deadlock on most enforcement questions, has also declined to use existing authority to require additional disclosure.