In-kind contributions are quiet. They arrive as favors—a supporter who pays the printer, a law firm that doesn’t send an invoice, a venue that “waives” the rental fee for a fundraiser, and a candidate who buys $900 of yard signs on a personal credit card and never asks for the money back.

None of that money passes through your bank account. All of it is a contribution.

Thomas Datwyler has served as treasurer for more than 400 committees. In his experience, in-kind contributions are the easiest reporting requirement to miss — the goods or services arrive as a favor, so nobody thinks of them as a contribution. Recording them correctly, on both sides of the ledger, keeps cash on hand accurate.

What counts as an in-kind contribution

Per the FEC, an in-kind contribution is a non-monetary contribution. It arises whenever:

• Goods or services are offered free or at less than the usual charge.
• A person or entity pays for goods or services on the committee’s behalf.
• An expenditure is made in cooperation, consultation, or concert with, or at the request or suggestion of, a candidate’s campaign. Coordination converts an “independent” expenditure into an in-kind contribution.

Which sweeps in a lot of things that don’t feel like contributions:

• A donor who pays your mailhouse directly
• A discounted venue, discounted printing, discounted polling
• A supporter who covers catering for a fundraiser
• A candidate’s unreimbursed personal spending on the campaign
• A staffer’s advance of personal funds for a campaign expense, until reimbursed
• A coordinated communication paid for by someone else
• Free use of an office, a mailing list, equipment, or a vehicle

And a critical exception: truly volunteered services are not contributions. When an individual donates time and nobody pays for it, no contribution results. The moment someone is compensated by a third party for working on your campaign, that changes.

How to value it: the usual and normal charge

The value of an in-kind contribution is the usual and normal charge — and the FEC breaks this into three rules:

1. Goods — equipment, supplies, facilities, mailing lists — are valued at their normal purchase or rental price at the time of the contribution.
2. Services — advertising, printing, consulting, polling — are valued at the prevailing commercial rate at the time the services are rendered. That is, what was paid, or what would have been paid.
3. Discounts are valued at the amount discounted: the difference between the usual and normal charge and what the committee actually paid.

The discount rule has a carve-out that matters enormously to vendors: a discount offered in the ordinary course of business — a volume discount available to any comparable customer — is not a contribution. A “friends of the candidate” rate that no other client receives is.

For a corporation, that distinction is not academic. Corporate treasury funds cannot be contributed to a federal candidate. A corporate vendor who quietly extends a special rate has made a prohibited in-kind contribution, and the campaign is the one that has to explain it.

The contributor is responsible for telling you the value. The FEC expects the contributor to notify the recipient committee of the value of an in-kind contribution — the treasurer needs it to monitor the donor’s aggregate totals and report correctly. In practice: ask, in writing and keep the answer.

When it happened: the date rule

An in-kind contribution is made on the date the goods or services are provided—not the date an invoice was issued and not the date anyone paid it.

This single rule causes more misdated entries than anything else in campaign accounting. A donor pays your printer on October 30 for signs delivered October 8. The contribution is dated October 8. That is what determines which reporting period it lands in, and — inside a pre-election window — whether it triggers a 48-Hour Notice.

It counts against the limit

The value of an in-kind contribution counts against the contributor’s contribution limit exactly as a check would.

For 2025–2026, an individual may give $3,500 per election to a federal candidate. A $2,000 in-kind and a $2,000 check from the same donor for the same election is a $500 excessive contribution that must be refunded, redesignated, or reattributed within 60 days.

In-kinds count against the contributor’s limit for the next election unless otherwise designated. See our full breakdown of FEC contribution limits.

How to report it: both sides, always

An in-kind contribution is reported twice on the same report: once as a receipt, once as an offsetting disbursement. The reason is arithmetic. If you report only the contribution, you have added money to your committee that never entered your bank account — and your cash on hand is now overstated by the value of the in-kind, permanently, until someone finds it.

For candidate committees (Form 3)

• Receipt side. Report on Line 11(a) for individuals, 11(b) for party committees, 11(c) for other PACs, and 11(d) for contributions from the candidate.
• Treat it exactly like a monetary contribution. Itemize on Schedule A once contributions from that individual aggregate over $200 for the election cycle. In-kinds from other political committees are itemized regardless of amount.
• Disbursement side. The amount must also be included in total operating expenditures on Line 17 to avoid inflating cash on hand.
• Schedule B. Itemize the offsetting expenditure on Schedule B supporting Line 17 only if the contribution had to be itemized on Schedule A.
• The purpose of disbursement must say so. Begin it with “In-Kind:” — for example, “In-Kind: Printing and Mailing Expenses.” The payee on Schedule B is the contributor’s name.

Unreimbursed candidate spending

When a candidate pays campaign expenses from personal funds and will not be reimbursed, the committee reports it as an in-kind contribution from the candidate on Lines 11(d) and 17.

One extra step: if the candidate’s unreimbursed payments to any single vendor exceed $200 for the election cycle, the committee must identify the ultimate payee — the actual vendor — in a separate memo entry on Schedule B, linked to the in-kind entry.

For PACs making in-kind contributions (Form 3X)

A PAC reports an in-kind contribution to a candidate on Line 23, itemized on Schedule B regardless of amount. The date reported is the date the good or service was provided to the campaign.

Because the PAC usually pays its vendor on a different date, it also reports the payment as a memo entry on Line 21(b), with a notation linking it back to the original in-kind — for example, “In-kind: See Schedule B, Line 23 of September Monthly.” See the FEC’s guidance on making in-kind contributions to candidates.

The bookkeeping trick that makes this painless

In QuickBooks Online, create a clearing account named In-Kind Clearing.

When an in-kind donation arrives: book the contribution income against the clearing account and book the expense against the clearing account. The account nets to zero. Your bank balance never moves. Both sides exist. Your report is correct by construction rather than by memory.

Special cases worth knowing

Appreciating assets. If a committee receives stock, artwork, or another item whose value may appreciate, itemize the initial gift as a memo entry on Schedule A at fair market value on the date received—and do not include it in the Line 11(a)(i) total. When the item is sold, report the sale price as a contribution if the purchaser is known or as another receipt if not.

Fundraiser tickets. The entire price of a ticket to a political fundraiser is a contribution, regardless of what the meal cost the committee.

Advances of personal funds. Payments a staffer or volunteer makes with personal funds are in-kind contributions until reimbursed, with special reporting rules once reimbursement occurs.

Coordinated communications. Anything paid for by a third party in coordination with the campaign is an in-kind contribution — subject to limits and source prohibitions. This is where an “independent” expenditure becomes a violation.

Why this matters more than it looks

Unrecorded in-kind donations inflate cash on hand. Inflated cash on hand fails to reconcile to the bank. Cash on hand that doesn’t reconcile to the bank is the single most visible signal a committee can send that its books are not under control — and it sits near the top of the reporting mistakes that draw FEC audit.

How 9Seven Consulting can help

9Seven Consulting captures in-kind contributions at the point they occur—not at filing—with written valuation confirmations from contributors, correct provision-date entry, and both-sides recording in cloud-based books that reconcile to the bank every month.

Thomas Datwyler has filed over 4,000 FEC reports across 400+ committees. He has never once found an in-kind problem that got easier by waiting.

Frequently Asked Questions

Q: What is an in-kind contribution to a political campaign? A: A non-monetary contribution. It arises when goods or services are given free or at less than the usual charge, when someone pays a committee’s expenses on its behalf, or when an expenditure is coordinated with the campaign.

Q: How do you value an in-kind contribution? A: At the usual and normal charge. Goods are valued at their normal purchase or rental price; services at the prevailing commercial rate when rendered; discounts at the amount discounted—unless the discount is offered in the ordinary course of business.

Q: Do in-kind contributions count against FEC contribution limits? A: Yes. The value counts against the contributor’s limit exactly as a monetary contribution does — $3,500 per election from an individual to a federal candidate in the 2025–2026 cycle.

Q: Why is an in-kind contribution reported twice? A: Because it never entered the bank account. It is reported as a receipt and again as an offsetting operating expenditure so that the committee’s cash on hand is not inflated by the value of something it never received in cash.

Q: What date do you use for an in-kind contribution? A: The date the goods or services were provided — not the date of the invoice, and not the date of payment.

Thomas Datwyler is the founder of 9Seven Consulting LLC and a nationally recognized FEC treasurer and campaign finance compliance expert. Since 2013 he has guided more than 400 political committees and filed over 4,000 FEC reports for Republican campaigns, conservative PACs, and advocacy organizations nationwide.

Not sure whether that favor was a contribution?

Contact 9Seven Consulting for a free consultation.

9Seven Consulting LLC · 9sevenfec.com · Hudson, WI · Est. 2013

This article is provided for general informational purposes and is not legal advice.