Are campaign contributions and lobbying activities complements, substitutes, or unrelated forms of organizational political engagement? Researchers and laypeople often conflate lobbying expenditures and campaign contributions under the umbrella of “money in politics.” For example, in popular discourse, campaign donations often are treated as simple replacement goods for lobbying, as if they are the same. Moreover, most Americans do not distinguish between lobbying expenditures and campaign contributions. According to a 2023 report by the Pew Research Center, “large majorities of Republicans and Democrats alike say campaign donors, lobbyists, and special-interest groups have too much influence” (Daniller and Cerda Reference Daniller and Cerda2023).
Similarly, media outlets and journalists often conflate campaign contributions and lobbying activities. In an article published in the Washington Post about a month before the 2024 elections, two veteran journalists wrote a retrospective piece about Donald Trump’s 2016 promise to “drain the swamp” (Stanley-Becker and Dawsey Reference Stanley-Becker and Dawsey2024). The authors chronicled how high-paid lobbyists “ponied up” to candidate Trump through memberships at his resort, suggesting that he is “accessible” to lobbyists. The article documents how corporate executives contributed to his campaign and hosted fundraisers for fellow executives, and it discusses several corporate political action committees (PACs) that raised money for Trump while insinuating that the donors are lobbying the candidate over cocktails and “rubber-chicken” dinners.
The New York Times similarly discussed lobbying and campaign finance. In an article on K Street (i.e., a major DC thoroughfare known as a hub for lobbying and a metonym for the US lobbying industry) preparations for a possible Kamala Harris administration, it discussed the ostensible Harris “open-door” policy for lobbyists and the industry’s practice of raising money for her campaign (Vogel Reference Vogel2024). These insinuations obfuscate the line between lobbying and campaign donations.
Because the practice of conflating electioneering and lobbying is so common, it easily could be considered benign, especially given that it is likely due to a genuine and widespread belief that campaign contributions and lobbying are synonymous. However, this confusion has real-world consequences. In the 2008 Honest Leadership and Open Government Act—the most recent law passed to significantly impact money in politics at the federal level—the law itself conflates the two. For the first time, the law requires a select group of citizens who qualify as “lobbyists” under the Lobbying Disclosure Act (LDA) of 1995 to separately report individual contributions to parties, candidates, and other political committees. In fact, under Title II of this Act, Section 203 is subtitled “Additional Lobbying Disclosure Requirements.” Nevertheless, it does not require additional lobbying disclosure; it compels lobbyists to disclose campaign contributions.
Furthermore, the Act does not require registered lobbyists to report campaign donations to the Federal Election Commission (FEC), the independent agency that is charged with enforcing all campaign-finance laws. The law instead requires lobbyists to “disclose” contributions to the Clerk of the House or the Secretary of the Senate, as if it were simply another “lobbying activity” as defined by law. The Clerk and the Secretary have no legal authority to enforce the law because they are mere administrative officials in the House and the Senate. Moreover, in reality, a campaign contribution by any person—lobbyist or otherwise—is an election-and-campaign activity. It is not lobbying at all. Thus, these disclosures do nothing to disentangle whether lobbyists’ contributions are First Amendment–protected expressions of individual electoral preferences or serve as de facto quid pro quo lobbying expenditures.
The LDA law has been in effect since 2010. Since then, little has changed in the public’s understanding of the difference between PAC contributions and lobbying expenditures, despite the supposed increase in “lobbying” transparency. Likewise, little has changed in the behavior of PACs and lobbying organizations—other than that there is now more of both. Section 203 has failed to accomplish the goal of “getting rid of money in politics” because the law’s authors and advocates muddled the meaning of money in politics.
These examples of lobbying and campaign-donation conflation may be excused because the media and good-government advocates aim to draw attention to problems, not to rigorously study the causes and effects of money in politics. Nevertheless, scholars also explicitly or implicitly treat these phenomena the same, thereby implicitly failing to aid the public, media, and even politicians in their efforts to construct a governing system in which they have more faith.
The basic premise underlying this conflation is that groups make contributions to buy access (Fouirnaies and Hall Reference Fouirnaies and Hall2018; Hall, Van Houweling, and Furnas Reference Hall, Van Houweling and Furnasn.d.; Hojnacki and Kimball Reference Hojnacki and Kimball2001; Kalla and Broockman Reference Kalla and Broockman2016; McKay Reference McKay2018a; Powell and Grimmer Reference Powell and Grimmer2016; Wright Reference Wright1989; see also Chin, Bond, and Geva Reference Chin, Bond and Geva2000 and Furnas et al. Reference Furnas, LaPira, Hertel-Fernandez, Drutman and Kosar2023 for contrary experimental evidence). Underlying this premise is the idea that groups must be engaging in both campaign contributions and lobbying. We suggest a need for conceptual and empirical clarification because we do not have a clear record of the extent to which this is actually true. It is true that interest groups intend to buy access with campaign contributions and to place their priorities on party agendas (Bawn et al. Reference Bawn, Cohen, Karol, Masket, Noel and Zaller2012; Noel Reference Noel2014). It also is true that most organizations do not use campaign donations in tandem with their lobbying strategy (Baumgartner et al. Reference Baumgartner, Berry, Hojnacki, Kimball and Leech2009). However, although scholars may have ideas about the relationship between lobbying and PACs, we currently lack an accurate accounting of how many interest groups—and what types of organizations—participate in both campaign contributions and lobbying activities, or in one or the other.
Disentangling campaign-financier groups from lobbying organizations provides the opportunity to disambiguate access seekers from partisan activists. Indeed, interest groups and policy demanders often are at the center of our theories about the outcomes of electoral processes (Bawn et al. Reference Bawn, Cohen, Karol, Masket, Noel and Zaller2012)—and rightfully so. Campaign and election literature, for example, discusses the financial consequence for members who are exiled from important congressional committee positions: a loss of PAC contributions, seemingly because they represent an attempt to influence legislation in these committees (Grimmer and Powell Reference Grimmer and Powell2013; Powell and Grimmer Reference Powell and Grimmer2016).
In short, it is clear that many policy demanders do perceive elections as a path to political access. However, what is the set of exclusively election-oriented organizations and what is the set of exclusively policy-oriented interest groups? How significant is the intersection between the two?
Campaign contributions and lobbying are distinct activities. Lobbying involves no direct transfer of capital between organized interests and members of Congress—or, quid pro quo bribery—whereas campaign contributions do constitute a transfer.Footnote 1 We distinguish between organizations with affiliated PACs and those with lobbying enterprises to measure the overlap.
Ultimately, we find that there is remarkably little overlap between organizations that engage in lobbying and those that make campaign contributions. Contrary to much of the existing scholarship on money in politics (Langbein Reference Langbein1993; Milyo, Primo, and Groseclose Reference Milyo, Primo and Groseclose2000), lobbying and campaign contributions should be considered as conceptually distinct activities, undertaken by different yet occasionally overlapping sets of interest groups.
CAMPAIGN CONTRIBUTIONS AND LEGISLATIVE OUTCOMES
Interest groups clearly act as though contributions matter; their PACs tend to donate to those who work on the issues that they care about and generally not to first-term legislators (Hall and Wayman Reference Hall and Wayman1990; Powell and Grimmer Reference Powell and Grimmer2016). Incumbents and committee members tend to receive more donations because they are more likely to influence legislation (Grimmer and Powell Reference Grimmer and Powell2013; Powell and Grimmer Reference Powell and Grimmer2016; Stratmann Reference Stratmann1991). In other words, campaign contributions often seem to be aimed at buying access to legislators who are in a position of leadership, power, and influence. Among foreign lobbyists—for whom we have detailed lobbying contact disclosures—it is common for them to request access to legislators to whom they have made a campaign contribution (Liu Reference Liu2022). However, campaign contributions do not necessarily lead to favorable legislative outputs (Baumgartner et al. Reference Baumgartner, Berry, Hojnacki, Kimball and Leech2009; Hall and Wayman Reference Hall and Wayman1990; Milyo, Primo, and Groseclose Reference Milyo, Primo and Groseclose2000; Welch Reference Welch1982). The timing of campaign contributions seems to indicate that PAC contributions are targeting both election outcomes and congressional voting: more money is donated in an election year and when there is an important issue on the legislative agenda (McKay and Lazarus Reference McKay and Lazarus2023; Stratmann Reference Stratmann1998).
Theoretically, access-oriented PAC contributions suggest a strong link between campaign contributions and lobbying: political giving opens the door and interest-group lobbyists walk through it to advocate for particularized benefits. In such a world, we should observe organizations with PACs frequently engaging in lobbying and organizations that lobby frequently should have PACs. If PAC contributions are mostly about affecting election outcomes, however, contributing and lobbying need not be linked. Similarly, if organizations believe that they can lobby effectively without donating, there should be many organizations that lobby but do not contribute.
LOBBYING AS A DISTINCT ACTIVITY
Does all of this hypothetically PAC-purchased access equate to outcomes? A meta-analysis of research published in major political science and sociology journals suggests that the data on interest-group influence are not as concrete as we instinctually might be inclined to believe. In fact, although interest groups have a non-zero impact, they are much less influential than political parties when it comes to policy outcomes (Burstein and Linton Reference Burstein and Linton2002). Other researchers have concluded that lobbying ultimately has minimal to no effect on legislation (Brown Reference Brown2016; Milyo, Primo, and Groseclose Reference Milyo, Primo and Groseclose2000); still others have found that lobbying can be specifically influential during the rulemaking process at the regulatory level of policy making (Dwidar Reference Dwidar2022).
However, firms clearly behave as though they benefit from lobbying, whether for the purpose of influencing new legislation (comparatively rare) or simply by protecting the stability of the status quo (Brock Reference Brock2021; Drutman Reference Drutman2015; LaPira and Thomas Reference LaPira and Thomas2017)—an outcome that may be desirable but often is difficult for researchers to observe or measure (Baumgartner et al. Reference Baumgartner, Berry, Hojnacki, Kimball and Leech2009). Moreover, lobbying sometimes appears to result in a “big bang for its buck” (see, e.g., Alexander, Mazza, and Scholz Reference Alexander, Mazza and Scholz2009). However, high returns on lobbying seem to be more likely when interest groups rely on “revolving-door” lobbyists who possess strong networks of relationships with members of Congress (LaPira and Thomas Reference LaPira and Thomas2017; McCrain Reference McCrain2018; McKay and Lazarus Reference McKay and Lazarus2023). This suggests that lobbying success may hinge more on a lobbyist’s relationship with Congress than on the campaign contributions that a corporation makes through its PACs.
This study disentangles organizational campaign contributions from lobbying, specifically investigating the overlap between the sets of interest groups engaged in these two activities. Because these are distinct although intertwined activities, conflating the two under the broad umbrella of “money in politics” obscures the strategies that interest groups may rely on to exert influence over policy and which activities they may avoid or believe are ineffective.
Indeed, there is evidence that interest groups deliberately rely on different strategies to guide their influence efforts; not all view engaging in both PAC activities and lobbying as absolutely necessary. In fact, we find that only a small minority of interest groups engage in both. This empirical finding aligns with qualitative work on lobbying. The following interview with an anonymous lobbyist describes PAC giving and lobbying as distinct, separate strategies:
We don’t engage in electoral politics at all. We don’t contribute to campaigns, we don’t have a PAC, so we basically don’t have money. But we have lots and lots of members.…So that’s what we are best known [for], both for our legislative and campaign development work in DC.…But we don’t play in the campaign-finance game at all. So, we’re not in that neck of the woods. And we don’t litigate.” (Brock Reference Brock2023, 43–44)
This interview reveals that the decisions to lobby and to contribute are self-conscious, strategic, and deliberate.
There undoubtedly is overlap between interest groups that engage in electioneering and in lobbying, particularly among well-resourced groups that are high policy demanders and engage heavily in extensive political spending (Tripathi, Ansolabehere, and Snyder Reference Tripathi, Ansolabehere and Snyder2002). However, we anticipated that many interest groups engage, at least some of the time, in only one or the other. The choice over activity will be underpinned by various possible motivations, about which we did not speculate. This article demonstrates that lobbying and making campaign contributions are not synonymous activities; rather, the majority of active organizations engage in one or the other but not both. This suggests that future research should begin to tackle the question about why and when organizations choose to engage in some activities and to forgo others.
DATA AND METHODS
We analyzed the lobbying and campaign-finance activities of interest groups using data from the Center for Responsive Politics (CRP)Footnote 2 from 1998 to 2018. These data are curated from LDA Registrations and Activity Reports (LaPira and Thomas Reference LaPira and Thomas2020) and FEC disclosures of campaign contributions by interest groups and their PACs. We relied on an extensive, expert-curated crosswalk from CRP linking organizations in the lobbying and campaign-contribution databases to compile interest-group lobbying and campaign giving. Because we are interested in specific, official organization-level strategies, we looked only at campaign donations from the interest groups (or their officially affiliated PACs) and did not count contributions from interest-group employees or contract lobbyists as contributions from the organization. We also did not observe so-called dark-money campaign contributions because, by definition, they are unaffiliated with organizations that publicly disclose their lobbying. In our assessments of an interest-group’s total lobbying activity, we included lobbying expenditures on both in-house and contracted-firm lobbyists.
RESULTS
Figure 1 displays the percentage of organizations that register to lobby only, make PAC contributions only, and engage simultaneously in both in the same year.Footnote 3 Throughout the decades of data reported herein, the number of organizations engaging in political activity fluctuated. The 2008 and 2010 campaign cycles represented peaks in political activity, with a subsequent slight decline, leveling out somewhat in the 2014–2018 period (although still considerably higher than in the late 1990s and early 2000s). It is important, however, to note that how organizations are engaging in politics has remained fairly consistent over time.
Count of Organizations That Register to Lobby, Make PAC Contributions, and Do Both from 1998 to 2018
The majority of organizations engaging in politics are doing so by registering to lobby exclusively. A smaller percentage of organizations exclusively make PAC contributions. Only a select minority of organizations engage in both lobbying and PAC activities simultaneously. Of the 9,076 organizations reporting involvement in politics in 1998, 24% made campaign contributions, 64% registered to lobby, and only 12% reported making PAC contributions and registering to lobby. A decade later, far more organizations were reporting political activity; however, the ways in which they engaged remained similar. Of the 15,729 organizations reporting political activity, 20% reported making PAC contributions, 70% registered to lobby without making PAC contributions, and only 10% reported engaging in both lobbying and PAC activity.
The majority of organizations engaging in politics are doing so by registering to lobby exclusively. A smaller percentage of organizations exclusively make PAC contributions. Only a select minority of organizations engage in both lobbying and PAC activities simultaneously.
We then moved beyond these counts of organizations to measure activity in terms of expenditures and contribution amounts. Figure 2 breaks down the share of yearly lobbying spending (figure 2a) and PAC contributions (figure 2b) by type of organization according to whether it engaged solely in lobbying, making campaign contributions, or both. Figure 2 reveals that between 1998 and 2018, approximately 75% of lobbying expenditures were made by organizations that also contributed through PACs. In contrast, we observe a decline in the share of PAC contributions from organizations that also lobby from more than 65% in 1998 to approximately 30% in 2018.
(a) Percentage of Lobbying Expenditures by Organization Type. (b) Percentage of Contribution Spending by Organization Type.
Total lobbying activity as measured by expenditures clearly is dominated by organizations that make PAC contributions; the large organizations that spend a substantial amount on lobbying also contribute, whereas the smallest lobbying organizations do not. In short, a significant percentage of money spent on lobbying is by only a few organizations, some of which also make campaign contributions.
Figure 3a presents the average PAC contributions broken out by whether an interest group only contributes or both lobbies and contributes. Similarly, the average lobbying spending (figure 3b) is presented, broken out by whether an interest group only lobbies or both lobbies and contributes. The full distribution of organizations is presented as a dot plot, with an overlaid violin density plot and the mean, interquartile range (IQR), and 2.5 and 97.5 percentiles indicated.
(a) Distribution of Average Yearly PAC Contributions by Organization Type. (b) Average Yearly Lobbying Spending by Organization Type
By delving into the volume of spending by politically active interest groups, figure 3a illustrates the distribution of average PAC spending among organizations that also lobby compared to those that do not. Organizations that make PAC contributions but do not lobby contribute less on average (mean: $7,857; IQR: $2,000–$33,566) than organizations that engage in both activities (mean: $31,167; IQR: $8,227–$1,082,366). However, the distribution of average PAC contributions for organizations has a higher variance, with the largest contributors reaching more than $100 million in average contributions (e.g., Crossroads GPS, Restore Our Future, and Priorities USA). Figure 3b shows that organizations that both lobby and contribute through PACs have substantially higher lobbying expenditures (mean: $403,435; IQR: $118,825–$1,558,597) than organizations that only lobby but do not contribute (mean: $64,000; IQR: $30,000–$130,000).
Organizations that engage in lobbying and contribute through their affiliated PACs both lobby and contribute more than organizations that do only one or the other; however, these organizations comprise a small minority of all politically active organizations, as shown in figure 4. During the entire period from 1998 to 2018, approximately 34,000 organizations lobbied but did not contribute; approximately 9,500 organizations contributed but did not lobby; approximately 7,500 organizations were registered as PACs or lobbying but were not active; and only 3,427 organizations (6.3%) engaged in both lobbying and campaign contributions through their PACs.
Scatterplot of Total Lobbying Spending and Total PAC Contributions by Organizations on a Log-Log Scale, with Marginal Histograms
Interest groups are colored and labeled by the types of activity in which they engage.
IMPLICATIONS
Our results are surprising but fairly straightforward. Our objective was to empirically validate the simple claim that donations and lobbying expenditures are not only distinct in a legal sense but also appear to be distinct in practice across the interest group population. Our findings have implications for public discourse and research.
Public Discourse
We hope that our results inform public discussion about money in politics. Our findings suggest that the overlap between organizations that lobby and those that contribute through PACs is considerably less than what the public likely assumes. The umbrella terminology of “money in politics” is imperfect and nonspecific. The concept may work as a superordinate category of all things concerning American political economy. However, it frequently hedges meaning by encompassing interest groups that are deliberately engaging in distinct political-influence strategies. Many interest groups that engage in political spending focus their efforts on lobbying.
Our findings suggest that the overlap between organizations that lobby and those that contribute through PACs is considerably less than what the public likely assumes. The umbrella terminology of “money in politics” is imperfect and nonspecific…[and] frequently hedges meaning by encompassing interest groups that are deliberately engaging in distinct political influence strategies.
The specific spending patterns discovered in this study also reiterate that not all money in politics is created equal. Spending on lobbying tends to begin at a higher level, and the average spending on these activities is high, with the concentration of interest groups spending between $10,000 and $1 million (in other words, a substantial amount) and few disclose spending of less than $10,000. This finding aligns with the evidence that the startup costs of lobbying are high but that active interest groups often find more reasons to continue engaging (Drutman Reference Drutman2015). It also supports the notion that lobbying increasingly is a long-term game, requiring significant and ongoing resources for interest groups that want to exert meaningful influence (Brock Reference Brock2023).
Spending on PAC contributions, however, is more uneven, with many interest groups making lower-level contributions of less than $10,000. This may be because making a PAC contribution can be a one-off event, with no ongoing commitment to repeat interactions, whereas hiring a lobbyist—even to work on only a single issue—is an event that necessarily stretches over months or years, given the prolonged nature of policy making (Brock Reference Brock2023; Brock and Mallinson Reference Brock and Mallinson2024).
For the relatively few interest groups that engage in both lobbying and PAC spending, the startup cost appears to be correspondingly as high as it is for all interest groups that lobby. In the case of an organization engaging in both, PAC spending appears to occur in addition to lobbying spending.
Research
Without being pedantic about terminology in American political economy, we think it is incumbent on researchers to be clear about what type of money in politics they study rather than putting the whole concept into a single, poorly conceived category. Researchers who work on political influence and advocacy should be careful not to conflate lobbying and electioneering because these activities rarely coincide, except for the most prominent players.
Our findings highlight further avenues of research into the notion that PAC and other campaign-donation spending buys access. But access for whom? If most PACs are not affiliated with a lobbying enterprise, what and whom are they accessing? Likewise, if lobbying enterprises are not affiliated with a PAC, how do they access the policy makers that they seek to influence? Non-PAC lobbying organizations are unlikely to fail when continually knocking on doors on Capitol Hill; therefore, the overwhelming majority must gain access and seek influence without any real or imagined quid pro quo. If there is no quid, there can be no quo.
Several possible rationales exist for most interest groups being insignificant campaign-donation players. First, organizations may need to lobby more effectively, unaware that they need to make PAC contributions to effectively engage in advocacy. However, with all of the national media coverage that conflates lobbying and campaign donations, the default error should be reversed. If this were true, lobbying organizations would learn that they must “pay to play or go home.”
Second, lobbyists may be making contributions as private individuals, perhaps considering this to be part of their job description. There are many political-law attorneys in Washington whose job is to ensure that lobbyists are not exceeding any illegal campaign-contribution limits. It is quite rare for lobbyists to be sued or indicted for campaign violations, so they mostly must play by the rules. It is unclear how an individual lobbyist’s limited campaign contributions could equate to a sophisticated organizational influence strategy. Organizational clients may piggyback on their lobbyists.
Individual spending to increase advocacy influence undoubtedly is a testable hypothesis. Most literature on campaign contributions supports this second interpretation. Most campaign contributions come from individuals, and evidence suggests that corporate PAC contributions are distinct from the contributions that lobbyists make as individuals. Indeed, lobbyists use their personal funds to donate to members of Congress working on issues of particular concern (McKay Reference McKay2018a). They also most often donate to legislators who are perceived to be more effective (Gui Reference Gui2023) and to those who share their party identification (Koger and Victor Reference Koger and Victor2009).
The relative success of interest group political access mediated by lobbyists who contribute as individuals is worth further exploration. Current literature provides limited insights: when lobbyists host fundraisers for lawmakers, they are more likely to see favorable amendments added to legislation (McKay Reference McKay2018b). Fundraising events provide lobbyists with professional networking opportunities and facetime with members of Congress who have limited availability to meet them during business hours. This relationship building often is the initial, professionally “polite” step to enable future questions (Occhiuto Reference Occhiuto2021). However, this relationship is complicated by questions about how those recipients of the contributions perceive the money.
Additional research is needed about the relationship between individual lobbyists, their donations, and how influential they or their clients are. Do these donations make them more effective lobbyists, or are the donations perceived as coming from the interest groups they work for funneled through lobbyists? This is particularly worth future study because, as indicated by our research, interest groups are not engaging in electioneering at the levels that we might expect.
Similarly, more investigation is needed into the relationship between individual contributions by corporate executives—either directly to candidates or to alternative funding mechanisms such as Super PACs—and lobbying. Like donations by lobbyists, the motivation and relationship between giving and potential access are more difficult to trace.
Third, our finding that in any given year there is only a 10% to 15% overlap between interest groups registered to lobby and those making campaign contributions suggests that these two activities may be viewed differently regarding the associated reward. Moreover, the organizations that engage in both are likely to be the most well resourced (Tripathi, Ansolabehere, and Snyder Reference Tripathi, Ansolabehere and Snyder2002) and more conservative on average than those that do not contribute (Crosson, Furnas, and Lorenz Reference Crosson, Furnas and Lorenz2020).
These findings also have implications for our understanding of how elections and interest-group activities are linked to substantive policy access. The notion of policy demanders who shape elections to influence policy outcomes is complicated because many who lobby evidently do not contribute. Ultimately, we conclude (at a minimum) that the relationship between campaign contributions and lobbying is much less straightforward or direct than historically has been assumed, in both scholarship and popular culture.
The notion of policy demanders who shape elections to influence policy outcomes is complicated because many who lobby evidently do not contribute….the relationship between campaign contributions and lobbying is much less straightforward or direct than historically has been assumed, in both scholarship and popular culture.
ACKNOWLEDGMENTS
The authors thank Dan Auble for sharing data and Jesse Crosson and Geoff Lorenz for their encouragement.
DATA AVAILABILITY STATEMENT
Research documentation and data that support the findings of this study are openly available at the PS: Political Science & Politics Harvard Dataverse at https://doi.org/10.7910/DVN/H2BGV8 (Furnas, LaPira, and Brock Reference Furnas, LaPira and Brock2025).
CONFLICTS OF INTEREST
The authors declare that there are no ethical issues or conflicts of interest in this research.
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