A super PAC called Our Heritage Matters was registered with the Federal Election Commission on October 15.
Five days later, he began spending to promote third-party candidates and attack Republicans. As of Oct. 29, the group had spent about $1.2 million on 10 House and Senate races, according to a CNBC analysis of FEC filings.
What voters still can’t see is who provided the money.
Because Our Heritage Matters was formed after a campaign financial reporting deadline of October 15, its first regular report identifying its donors is not due until December 3, a month after Election Day.
The group is an extreme example of a broader wave reshaping midterm elections: late-formed super PACs, including the latest “pop-up PACs,” pouring money into races before voters know where it came from.
Federal law requires super PACs and political committees to report their significant independent expenditures within 24 or 48 hours, depending on the proximity to Election Day, indicating how much they spent and which candidates they supported or opposed. Their donors, however, are less frequently disclosed in periodic campaign finance reports.
And in 2026, the practice of creating new PACs at the last minute has exploded. Both parties use this tactic, with Republican-linked PACs spending about twice as much as Democratic-linked ones.
Twenty-two super PACs registered with the FEC in the last 10 weeks before Election Day each spent at least $1 million on congressional races, according to CNBC’s analysis. Together, they had reported about $637 million in independent spending as of Oct. 29, or about one-sixth of all reported independent spending in House and Senate races this election cycle.
The number of late-forming million-dollar super PACs has more than quadrupled since 2022, while their spending has increased nearly 35-fold.
At the same point in the 2022 midterms, just five comparable groups had spent a combined roughly $18 million, according to CNBC’s analysis. As of 2018, three of them had spent about $12 million. The total eclipsed even the last two presidential elections, when comparable, late-formed super PACs together spent less than $50 million on congressional elections in 2020 and 2024, according to CNBC’s analysis.
“The reason for this is almost entirely to avoid disclosure, even if only temporarily,” said Michael Kang, a professor at the Northwestern Pritzker School of Law who studies campaign finance. “Often, if the donors were known, it would hurt their cause.”
CNBC’s analysis includes super PACs formed in the last 10 weeks before Election Day that spent at least $1 million on House or Senate races before Oct. 29. Expenses include regular FEC filings and 24- and 48-hour reports, with duplicates removed.
From Zero to Millions in Late PAC Spending
One of the defining characteristics of late-forming super PACs is speed.
Of the 22 groups analyzed by CNBC, 18 started spending within 30 days of launch, and almost all started spending before filing their first regular campaign finance report showing where their money came from.
“It’s happening more often, and they’re spending more money on it because it works, and they’re getting away with it,” said Saurav Ghosh, director of federal campaign finance reform at the Campaign Legal Center. The group is a nonpartisan, nonprofit organization founded by a former Republican FEC chairman.
Despite their late start, the groups accounted for more than 22% of independent spending in congressional races during CNBC’s 2026 window, up from less than 2% at the same time in each of the previous two midterms.
Many are only new on paper. CNBC found financial or organizational ties between nine of the 22 groups and established political networks.
Lower Costs Now, for example, formed on September 10 and revealed an affiliation with the Future Forward PAC, the main outside group that supported former Vice President Kamala Harris’ 2024 presidential campaign. Nineteen days later, Lower Costs Now began spending in Senate races.
But voters didn’t get a fuller picture of its funding until Oct. 15, when its first regular financial report showed that Senate Majority PAC, the main super PAC working to elect Democrats to the Senate, had given the group $23 million, according to FEC filings.
As of Thursday, Lower Costs Now had reported about $75.5 million in independent spending for eight Senate races, including Iowa, Texas, Kansas and Ohio, according to CNBC’s analysis.
The Republicans used the same model.
No Going Back PAC formed on September 1 and began spending three days later. Public reports quickly linked him to MAGA Inc., President Donald Trump’s super PAC. But its official financial report did not arrive until October 20, more than six weeks after the spending began.
By then, No Going Back had already spent approximately $187.8 million, according to FEC filings, which revealed that MAGA Inc. provided the group with $200 million. As of Thursday, the super PAC had spent about $242.2 million, according to FEC filings.
“They are a vehicle designed to come out of nowhere and spend a lot of money on an election” before voters can know “who is providing that money and what their motivations might be,” Ghosh said.
PACs built for a single race
Many of the new groups are also narrowly targeted.
Fourteen of the 22 super PACs identified by CNBC spent all their money on a single congressional race.
Take the Maine standard. It formed on September 11 and began operating five days later. Since then, he has spent $8.2 million, all against Democrat Troy Jackson in Maine’s Senate race, according to FEC filings.
The Cornhusker majority followed almost the same pattern. It was formed on September 10, began spending on September 16, and has spent about $7.1 million in the Nebraska Senate race, almost all of it opposing independent Dan Osborn, according to FEC filings. Osborn is running against incumbent Republican Sen. Pete Ricketts in a tight race.
The connection between the two groups did not appear in their regular financial reports until October 15: both were funded by the Senate Leadership Fund, the GOP’s main Senate super PAC.
On the Democratic side, Texas Forever launched on September 24 and began spending five days later, according to FEC filings. As of Thursday, he had spent about $27.5 million to help Texas Democratic Senate candidate James Talarico, according to the FEC. However, unlike some other pop-up groups, its initial filing with the FEC identified the Senate Majority PAC as an affiliate.
“A locally branded PAC doesn’t necessarily hide where the money is coming from, but it fragments the picture. Instead of seeing one national organization spending tens of millions of dollars across the country, voters see a series of different groups operating race by race,” said Hilary Braseth, executive director of OpenSecrets, a nonpartisan nonprofit that tracks such spending.
But even identifying the national group behind a pop-up PAC can still hide another layer of financial trail.
The Texas PAC formed on August 28 and quickly began spending to help Republican Ken Paxton in the Texas Senate race. The money flowed through the SLF, but Musk’s role was not made public until October 12, more than a month after the spending began.
On October 15, FEC filings showed that Musk gave the SLF $158 million in two contributions, with the group transferring the matching amounts to the Texas PAC the day after each donation.
As of Oct. 29, the Texas PAC had spent about $181.6 million in the race, according to FEC filings, making it one of the largest late-forming super PACs identified by CNBC.
Together, Texas PAC and No Going Back accounted for about two-thirds of the groups’ total spending of $22 million. But the push was much broader than those two giants: Even excluding them, the remaining groups spent nearly 12 times as much as comparable super PACs that formed late at the same time in 2022.
“The growth is huge this year,” Kang said. “Maybe you don’t want to be known in this election, or you want to hide for a while while you might be unpopular, like AI is right now, but you want to kind of build a reputation for the players in the system.”
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