Do advocacy groups disclose payments to protesters under campaign finance or nonprofit rules?

1. How the law frames “payments for politics” versus ordinary nonprofit work

Federal campaign‑finance statutes draw a bright line around expenditures that are the functional equivalent of directly supporting or opposing a candidate: disclosure requirements apply to independent expenditures and electioneering communications once they meet defined thresholds (for example, $10,000 aggregate in a calendar year triggers FECA filing obligations) ^{[1] [2]}. Courts have repeatedly linked constitutionally permissible disclosure to funds used for express advocacy or its functional equivalent, meaning money spent on neutral issue work or generic “get out the vote” activity often falls outside mandatory federal disclosure ^{[2] [5]}.

2. Nonprofit tax status creates “dark money” pathways that complicate payments to protesters

501(c), (c), and (c) advocacy nonprofits can accept unlimited donations and make substantial political expenditures without revealing their donors to the public, provided political spending does not exceed certain practical limits tied to their overall activities and the groups comply with tax‑exemption rules and case law constraints ^{[3] [4]}. That structural opacity is the origin of so‑called “dark money,” which, at the federal level, has been documented as a major source of undisclosed political spending ^[4].

3. When would paying protesters trigger campaign disclosure rules?

If a payment is part of an expenditure that rises to express advocacy or an electioneering communication — for instance, clearly coordinated or intended to influence an identified federal election, or aggregated above statutory thresholds — it can require filings under FECA and related rules ^{[1] [2]}. The FEC and legal commentators also emphasize that donations “designated” or solicited for express advocacy are reportable, whereas unrestricted donations that later fund such activity may not be ^[6].

4. Coordination and the “independent expenditure” distinction matter — and they are contested

Groups may spend freely on independent political activity if they do not coordinate with a candidate or party, a principle reinforced by Supreme Court decisions that struck down expenditure limits so long as activity remains independent; this interpretation makes it harder to treat payments to on‑the‑ground actors as attributable to a campaign unless coordination can be established ^{[7] [5]}. Enforcement and rulemaking at the FEC have been uneven and politically contested, leaving gray areas where payments could be structured to avoid disclosure ^{[6] [8]}.

5. State laws, FEC guidance and enforcement gaps leave uneven reporting on protest payments

States have varied disclosure regimes that cover contributions, independent expenditures and electioneering communications differently, so a payment that triggers disclosure in one jurisdiction may not in another ^{[9] [10]}. The FEC has issued guidance clarifying donor‑reporting for groups paying for political ads, but commissioners’ statements are not binding law, and courts have narrowed some rules, producing further uncertainty ^{[6] [1]}.

6. What reporting sources and the record do — and do not — show about payments to protesters

Public data compilations and watchdog reporting document large sums flowing through nonprofits into political activity and highlight gaps in donor transparency, but none of the sources examined provide a definitive, universal rule that every payment to a protester must be disclosed; disclosure turns on purpose of the funds, how they are solicited or designated, the form of communication, thresholds met, and whether coordination with campaigns exists ^{[4] [11] [6]}. The available reporting therefore demonstrates that payments can be disclosed in some circumstances and remain undisclosed in others, and that the law and enforcement leave meaningful loopholes for opacity ^{[3] [4]}.