The Elections Transparency Act, enacted in April 2023, introduced important changes to New Jersey campaign-finance and pay-to-play laws. And one perhaps overlooked provision of the ETA is now set to take effect on January 1.
Under the law, contribution limits for all candidates and committees will now be subject to inflation adjustments in odd-numbered years. This inflation adjustment is new for every recipient other than gubernatorial candidates. (Gubernatorial adjustments will continue on the regular four-year schedule.)
What this means is that, starting January 1, essentially all the contribution limits will go up. The following chart summarizes the new limits that apply to contributions made from individuals, corporations, unions, and associations:
| Recipient | Old Limit | 2025 New Limit |
| Candidate Committee | $5,200 per election | $5,500 per election |
| Political Committee | $14,400 per election | $15,200 per election |
| Continuing Political Committee (PAC) | $14,400 per calendar year | $15,200 per calendar year |
| Legislative Leadership Committee | $75,000 per calendar year | $79,000 per calendar year |
| State Political Party Committee | $75,000 per calendar year | $79,000 per calendar year |
| County Political Party Committee | $75,000 per calendar year | $79,000 per calendar year |
| Municipal Political Party Committee | $14,400 per calendar year | $15,200 per calendar year |
Political party committees, PACs (CPCs), and legislative leadership committees that follow the calendar year as the reporting period will simply have a higher limit on January 1, 2025 when each contributor’s limits re-set to $0 anyway for the new calendar year. For political party committees with housekeeping accounts, those housekeeping accounts may in 2025 accept additional contributions of $39,500 per calendar year, an increase from the current level of $37,500 (by law, the limit for a housekeeping account is half of the limit for the general account).
For candidates, whose limits apply on a per-election basis, the increase will apply to the current or next election. For example, an Assembly candidate who is running in the 2025 primary will be able to accept an additional $300 from a contributor who had maxed out in 2024 once the increase goes into effect on January 1. (This means that candidates running in the 2025 primary election will be able to solicit again all contributors to reach the new maximum.) Then the new $5,500 limit will be in place from the start of the 2025 general election.
In addition, ELEC is applying inflation adjustments to 24/72 hour reporting and independent-expenditure reporting for spenders using their own funds (in 2025, the threshold will increase from $200 to $300 for both categories).
The new limits that will be in place in a few weeks highlight the importance for each individual, business, union, and political organization to keep accurate and complete records of their political contributions. Understanding election cycles, contribution dates, and now biennial shifts in contribution limits will make the difference between a legally permissible political contribution and one that exceeds legal limits.
Compliance Tip: Even though the general campaign-finance limits are increasing in January, these adjustments do NOT apply to the reportable threshold of $200 per reporting period. This means that contributors who wish to stay under the reportable threshold—which necessitates reporting of detailed contributor information on a recipient’s campaign-finance reports—must stay at $200 or less per election for a candidate and $200 or less per calendar year for a political party committee, PAC (CPC), or legislative leadership committee. This $200 threshold also has important implications for pay-to-play compliance for those business entities that hold or pursue New Jersey government contracts.
Avi D. Kelin is a founding partner of PEM Law LLP, and chairs the firm’s Political Law and Non-Profit Law practices. He helps businesses, organizations, individuals, and political organizations to influence policy while complying with the law.
This column is for educational and informational purposes only and is not intended and should not be construed as legal advice. It is recommended that readers not rely on this column, but that professional advice be sought for individual matters.
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New Jersey recently received campaign-finance inflation adjustments, which will have significant implications for political candidates and committees in the state. These adjustments were made in accordance with the state’s campaign-finance laws, which require periodic updates to account for inflation and ensure that contribution limits remain fair and equitable.
Insider NJ, a leading source of political news and analysis in New Jersey, has provided some valuable insights into what these adjustments mean for those involved in the political process. According to Insider NJ, the adjustments will impact both individual contribution limits and reporting requirements for political committees.
Individual contribution limits have been raised to $2,700 per election cycle for gubernatorial candidates and $1,000 per election cycle for all other candidates. This increase reflects the rising cost of political campaigns and allows candidates to raise more funds from individual donors to support their campaigns.
In addition to the changes in contribution limits, political committees will also be required to report their financial activities more frequently. Under the new rules, committees must file quarterly reports detailing their contributions and expenditures, as well as any loans or debts incurred during the reporting period. This increased transparency will help ensure that political committees are operating in compliance with campaign-finance laws and that the public has access to information about who is funding political campaigns.
Overall, these adjustments are aimed at promoting transparency and accountability in the political process, and ensuring that candidates and committees are operating within the bounds of campaign-finance laws. By staying informed about these changes and complying with the new requirements, political actors in New Jersey can help maintain the integrity of the state’s electoral system and build trust with voters.
In conclusion, the campaign-finance inflation adjustments in New Jersey are an important development for those involved in the political process. By following the guidance provided by Insider NJ and staying up-to-date on the latest requirements, candidates and committees can navigate these changes successfully and continue to engage in fair and transparent political campaigns.
