The Minnesota Campaign Finance and Public Disclosure Board (CFB) has acted to implement the U.S. Supreme Court’s recent decision in National Republican Senatorial Committee v. Federal Election Commission. Consistent with that case, the CFB will no longer enforce limits on how much a political party can spend in coordination with its candidates for public office in Minnesota. However, the CFB will continue to enforce limits on cash contributions from parties to candidates.
This development follows several important Minnesota legislative changes adopted on the last day of the legislative session in May. These developments limit disclosure of donors’ addresses on campaign finance reports and modify the disclaimers that candidates and PACs must print on campaign materials.
Additionally, Minnesota has relatively new reporting requirements for groups – other than candidates, parties and PACs – who make “electioneering communications” within 30 days before the primary (August 11) or 60 days before the general election (November 3).
Political Parties Can Now Spend More Freely in Support of Candidates
On June 30, 2026, the Supreme Court announced its blockbuster decision in NRSC v. FEC. In a six-to-three decision, the Court held that long-standing limits on the amount national political parties could spend in coordination with federal candidates violate the First Amendment. The Court reasoned that the limits on “party coordinated expenditures” impair parties’ “traditional forms of communication,” and the limits cannot survive the “closely drawn scrutiny” that the Court applies to statutory limits on contributions. Importantly, however, the Court did not strike down the limits on contributions to political parties or to candidates. Nonetheless, the decision will allow political parties to greatly increase their spending in support of their candidates, and the decision may motivate additional contributions to political parties.
Like federal campaign finance law, Minnesota law imposes a limit on the amount that political parties can contribute to candidates for legislative or statewide office in Minnesota.1 Immediately after the NRSC decision, questions arose about the constitutionality of that law. On July 9, 2026, the CFB determined that it could not enforce a limit on the amount of in-kind contributions from a party to its candidates. In other words, a party can now spend unlimited amounts on expenditures that are coordinated or approved by its candidates. The CFB also decided, however, that it would continue to enforce the limit on cash contributions from parties to candidates.
The NRSC decision and the CFB’s action will have important implications that extend beyond the political parties and candidates. Groups in Minnesota, including political action committees (PACs), often work with parties to back their endorsed candidates. Until these developments, Minnesota parties needed to structure many of their activities to fit within the “multi-candidate exception,” which excludes certain communications that name three or more candidates from the limits on contributions from parties. Now, with that exception no longer relevant, PACs and political parties may be able to have a greater, more candidate-specific impact. But important limitations remain, including that no PAC or other donor may earmark a contribution to a party for the benefit of a specific candidate.
In its guidance regarding NRSC v. FEC, the CFB emphasized that a political party may not solicit or accept an earmarked contribution (i.e., a contribution with the express or implied condition that the contribution be directed to a particular candidate). Violation of Minnesota’s prohibition on earmarking or of circumventing the contribution limits is a gross misdemeanor and may also be subject to a civil penalty of up to $3,000.
Minnesota Legislative Changes
On the last day of the 2026 legislative session, the Minnesota Legislature adopted some important changes to Minnesota’s campaign finance and lobbying laws.
Donor Addresses Will No Longer Be Publicly Disclosed
Until this legislation was enacted, candidates, political parties and PACs were required to list the names, addresses and employer or occupation of each of their donors of more than $200 in the aggregate during the year, and this information was included on public reports available on the CFB’s website. Now, however, a donor’s street address – i.e., the “name or number of the building, the name of the street on which the building is located, and any unit number” – will not be available on the public versions of these reports. Filing entities, such as candidates and PACs, will still need to report this information to the CFB, which can use it for compliance purposes.
This is a very significant change that will help address political donors’ privacy and security concerns, which were heightened after the tragic death of former Minnesota House Speaker Melissa Hortman and her husband, and other acts of political violence.
Donors should be aware, however, that their address information may still become public in certain circumstances. For example, if the recipient entity is registered and files reports with the FEC, those reports still require address information and it is permissible to use a business address.2 In addition, PACs with gross receipts of more than $100,000 per year must file Form 990s with the IRS.3 Those information returns are posted to the IRS’s website, and the relevant PACs must list donors of more than $5,000.
New Disclaimer Rules Apply to Campaign Communications
Minnesota law has long required candidates, political parties and PACs to include a “prepared and paid for by” disclaimer on their “campaign materials” – i.e., material that is disseminated for the purpose of influencing voting. The 2026 legislation modifies these requirements.
Formerly, the disclaimer needed to include the entity’s mailing address or a website that displayed the entity’s mailing address. Now, the disclaimer may include an “actively monitored email address” rather than a mailing address or website, and it is permissible to use a website that displays an “actively monitored email address” rather than a mailing address.
The new law also clarifies the duration, location, and visibility requirements for disclaimers. The applicable statute now requires:
- For written communications other than an outdoor sign, website or social media page, the disclaimer must be printed in 8-point font or larger and provided in black text, or in color text that is in high contrast, on a white background.
- Disclaimers on websites and social media must be clearly legible without manual adjustment or magnification by the user.
- Audiovisual advertisements must display the disclaimer for a minimum of four seconds at the end of the advertisement. [This is a significant change that aligns with federal disclaimer rules for internet communications.6]
- Advertisements that only consist of audio must contain a disclaimer that is delivered at a volume, speed and cadence that can be easily understood.
- For signs that are smaller than two feet by three feet, the disclaimer must be printed in 12-point font or larger and provided in black text, or in color text that is in high contrast, on a white background.
- For signs at least two feet by three feet but not larger than four feet by eight feet, the disclaimer must be at least one inch tall and printed in black text, or in color text that is in high contrast, on a white background.
- For signs larger than four feet by eight feet, the disclaimer must be at least six inches tall and printed in black text, or in color text that is in high contrast, on a white background.
The new requirements for disclaimers on signs apply to those printed on or after January 1, 2027. Signs printed prior to January 1, 2027, may continue to be used.
Note that there are different disclaimer requirements that apply to many communications that advocate for or against federal candidates.7
Grassroots Lobbying Ads Now Require Disclaimers
The newly enacted legislation requires a disclaimer on paid advertisements that urge the public to contact public or local officials to influence legislative or administrative action, or the official action of a political subdivision. In other words, the requirement applies to certain grassroots lobbying advertisements in Minnesota. The disclaimer must include the name of the organization (called a “principal”) that is responsible for the content of the advertisement, along with a phone number, email address or website. The size and visibility requirements are the same as those described above.
This is a notable change because prior law did not require a disclaimer on lobbying communications.
Electioneering Communication Rules Remain Easy to Trigger
In recent legislative sessions, the Minnesota Legislature created disclaimer and reporting requirements for “electioneering communications.” There are several exceptions and caveats, but groups – other than political parties, candidates or PACs – should be cautious about distributing communications, including digital communications capable of generating 2,500 or more contacts, within 30 days before a party convention at which the candidate may be endorsed, within 30 days before a primary, or within 60 days before the general election, if those communications refer to a clearly identified candidate for state office.8 A communication may be an electioneering communication even if it does not take a position on the election or expressly advocate for or against a candidate – it merely needs to refer to a clearly identified candidate.
The remaining relevant periods for 2026 are:
- July 12 – August 11 (within 30 days before the primary); and
- September 4 – November 3 (within 60 days before the general election).
A communication made during those windows that clearly identifies a candidate for state office may need to carry a disclaimer like those described above.9 If a group distributing electioneering communications spends more than $10,000 in the aggregate on them in a calendar year, it must file a detailed report within 24 hours of the “disclosure date” on which the threshold is crossed, and an additional 24-hour report for each subsequent disclosure date that crosses the $10,000 threshold.10
Key Takeaways for Your Organization
Minnesota nonprofits, advocacy organizations and politically active groups should revisit their campaign finance compliance practices before election activity accelerates. The elimination of limits on party-coordinated expenditures, expanded donor privacy protections, revised disclaimer standards, and ongoing electioneering communication requirements create both new opportunities and new compliance considerations.
Organizations that communicate about candidates, engage in public policy advocacy, work with political organizations, or sponsor grassroots lobbying campaigns should ensure their communications, reporting practices and internal review procedures reflect these developments.
If you have questions about how these Minnesota legislative changes may impact your organization, please contact Wade Hauser or Sarah Duniway, or your regular Lathrop GPM attorney.
1 Minn. Stat. § 10A.27, Subd. 2.
2 Federal Election Commission Record, Vol. 35, No. 12, December 2009. In addition, donors can request exemptions from the donor disclosure requirement if there is a “reasonable probability” that the disclosure would subject the donors to “threats, harassment, or reprisals from either Government officials or private parties.” Buckley v. Valeo, 424 U.S. 1, 74 (1976).
3 I.R.C. § 6033(g).
4 Minn. Stat. § 211B.04.
5 Ibid, Subd. 5.
6 11 CFR § 110.11(c)(5).
7 See 11 CFR § 110.11(c)(5); Federal Election Commission, Advertising and Disclaimers.
8 See Minn. Stat. § 10A.201 & 10A.202.
9 Minn. Stat. § 10A.202, Subd. 4.
10 Minn. Stat. § 10A.201, Subd. 5.