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The Money Desk · Blog
Re:

When Can Campaign Funds Pay for Physical Security or Cybersecurity? The FEC’s 2024 Rule

Federal campaigns may pay reasonable costs for qualifying security measures, including certain physical devices and cybersecurity, when the FEC’s ongoing-threat and pricing conditions are met.
From TheFinanceBase Team3 min to read
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Federal campaign funds may pay reasonable costs for certain physical security and cybersecurity measures, but not every security-related purchase qualifies. Under the Federal Election Commission’s rule, a measure must address an ongoing danger or threat connected to the person’s status or duties as a federal candidate or officeholder, and the charge must be usual and normal. The FEC’s examples identify eligible categories, not automatic approval of any particular product or expense.

What the FEC’s rule allows

On September 19, 2024, the Federal Election Commission (FEC) approved a final rule amending 11 CFR part 113. The Commission announced it on September 25, 2024. New paragraph 11 CFR 113.1(g)(10) allows campaign funds to cover the reasonable cost of security measures for federal candidates and officeholders, their family members, and employees of a candidate’s campaign or an officeholder’s office, as defined by the regulation. The measures must address ongoing dangers or threats that would not exist irrespective of the individual’s status or duties as a candidate or officeholder. Read the FEC’s final-rule announcement.

This provision sits within the campaign-finance prohibition on converting campaign contributions to personal use. Personal use generally involves a commitment or expense that would exist regardless of the campaign or federal-office duties. The FEC evaluates expenses outside its enumerated categories case by case; the new security provision codifies prior treatment and addresses issues raised in earlier opinions.

Which security expenses may qualify?

The FEC lists examples in four broad categories. They remain subject to the ongoing-danger-or-threat and reasonable-cost conditions; an example is not a blanket ruling that every proposed purchase is permissible.

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  • Non-structural physical devices: hardware, locks, alarm systems, motion detectors, and security camera systems.
  • Structural security measures: wiring, lighting, gates, doors, and fencing, when intended solely to provide security rather than to improve the property or increase its value.
  • Security personnel: bona fide, legitimate, professional security services.
  • Cybersecurity: software, devices, and services.

The FEC says these examples are not exhaustive. Its candidate and officeholder security guidance describes the categories and conditions.

How to assess the ongoing-threat condition

The rule requires an ongoing danger or threat that would not exist irrespective of the individual’s federal candidacy or officeholder status or duties. The FEC clarified in an August 11, 2025 treasurer tip that a candidate or officeholder does not have to show that someone made a threat directly against them. That clarification does not eliminate the need for an ongoing danger or threat connected to the person’s status or duties. See the FEC treasurer tip.

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What counts as a usual and normal charge?

Even when a measure addresses a qualifying danger or threat, its cost must be reasonable and paid at the “usual and normal charge.” The FEC explains the standard differently for goods and services:

Expense FEC’s pricing standard
Goods, such as a camera system or lock The market price in the market where the goods are ordinarily purchased.
Services, such as professional security personnel or cybersecurity support A commercially reasonable prevailing hourly or piecework rate when the services are rendered.

Those standards are relevant to the charge, but satisfying them alone does not establish that a purchase addresses a qualifying danger or threat.

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How earlier cybersecurity opinions fit

The 2024 rule follows case-specific advisory opinions involving cybersecurity. They offer context, not blanket approval for all candidates, devices, accounts, or services.

  • AO 2022-17: Issued September 15, 2022, the opinion concluded that Senator Elizabeth Warren’s principal campaign committee could use campaign funds for reasonable cybersecurity measures to protect her home network, based on the facts presented. View the official record for AO 2022-17.
  • AO 2018-15: Issued December 13, 2018, the opinion concluded that Members of Congress could use campaign funds for certain cybersecurity-related expenses protecting personal electronic devices and accounts. View the official record for AO 2018-15.
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What the rule does not establish

The regulation and FEC examples do not preapprove a specific device, service, or individual purchase. A camera, lock, cybersecurity subscription, or other item still has to meet the rule’s conditions. Nor does the treasurer tip require a direct, documented threat made against the individual; it preserves the broader requirement that the measure address an ongoing danger or threat related to their federal status or duties.

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