Monetary contributions are not the only things of value received by campaigns.  Frequently, contributors will donate goods and services in lieu of or in addition to making monetary donations

Exempt from Disclosure

Incidental in-kind contributions

Small amounts of good or services donated to a committee that either singly or in conjunction with other in-kinds from the same contributor do not exceed $25 in value during the election cycle.  Carefully track these incidental contributions because they become reportable if the contributor gives additional contributions and the aggregate total exceeds $25.

Volunteers' Out-of-Pocket Expenditures

The first $50 in the aggregate a volunteer spends out-of-pocket on the campaign is not an in-kind contribution. Once a volunteer spends more than $50 out-of-pocket, report all of that volunteer’s expenditures as in-kind contributions.  Subsequent expenditures by the volunteer must be disclosed on future reports as additional contributions.  If someone who is not a volunteer purchases something for the campaign and spends more than $25, the campaign will report the expenditure as an in-kind contribution.

Member Organizations' Communications to Members

A committee is not required to report an association's cost of communication with members conveying support for the committee.  Note, though an association pay request that members directly contribute to the committee, but the association is not allowed to collect the contributions and then deliver them to the committee.   Associations and other entities may arrange to have their members provide volunteer services political committee without an in-kind contribution occurring so long as the coordination involved in this activity only results in incidental expenditures to the association as discussed above.

Volunteer Services

As discussed under Volunteer Services, the personal services of campaign volunteers who perform common volunteer functions are not reportable as in-kind contributions so long as the volunteers are not paid by anyone for the campaign work they do.  


In-Kind Contributions That Must Be Disclosed

Common examples of in-kind contributions that are reportable include donated office space, free or reduced cost printing or polling services, training of campaign workers or managers or help with preparing political advertising at no cost to the campaign or at less than fair market value.  Committees who received donated staff time from employers must report the contribution from the employer.  The same is true if a union or some other person or entity were pays an individual for the time or the services rendered to a campaign.  Whenever the committee receives an item or service that meets the definition of contribution and is not incidental (as discussed above), and the campaign does not pay full value for the item or service, a reportable in-kind contribution has been received.



Valuing In-Kind Contributions

The value of an in-kind contribution is determined by the circumstances involved.  For example, if a contributor

  • buys supplies or equipment for the campaign, the in-kind contribution equals the amount spent on the purchase;
  • takes out an advertisement supporting a candidate (after collaborating with or receiving approval from the candidate or the candidate's campaign or agent), the in-kind contribution equals the cost of the ad;
  • loans your campaign the use of a computer or copier, the in-kind equals the cost of leasing a similar piece of equipment for the period of time in question;
  • prints campaign literature at a cost below the printer's normal charge for a similar job, the in-kind equals the amount of the discount;
  • provides food or beverages for a campaign event, the in-kind contribution equals the amount spent on the items provided or, in the case of a business that already has the items on hand, the amount that business would normally expect to receive from the sale of the items.

The overriding principle governing the value of an in-kind contribution is "the amount a well-informed buyer or lessee, willing but not obligated to buy or lease, would pay; and the amount a well-informed seller, or lessor, willing but not obligated to sell or lease, would accept." 

Generally, this means the amount the contributor would ordinarily expect to receive if someone were paying him or her to provide the item or service.  For example, if a candidate is given materials by a local retail hardware store for the construction of yard signs, an in-kind contribution has been made equal to the normal retail selling price of the materials.  However, if the business donating the materials is a wholesale supplier, the in-kind contribution is equal to the amount this wholesaler charges its customers for the materials



Disclosing In-Kind Contributions

In-kind donations that are not incidental must be fully reported in Part 1 of Schedule B to the C-4 with the following details:

  • the date the contribution was received;
  • the name and full address of the contributor;
  • a brief description of the contribution;
  • its fair market value;
  • the cumulative total this contributor has given for the primary or general election, whichever applies;
  • a designation whether this contribution is for the primary or general election; and
  • if the contributor is an individual who has cumulatively given more than $100 to the campaign, including both primary and general contributions, identify the individual's employer (by name, city and state) and occupation.