PolicyBrief
S. 1849
119th CongressMay 21st 2025
Zeroing Out Money for Buying Influence after Elections (ZOMBIE) Act
IN COMMITTEE

The ZOMBIE Act mandates that candidates' authorized committees and Leadership PACs must spend down all unexpended funds after an election, unless they immediately run again, and requires former candidates who become lobbyists or foreign agents to certify compliance with these new disbursement rules.

Michael Bennet
D

Michael Bennet

Senator

CO

LEGISLATION

ZOMBIE Act Forces Candidates to Empty Campaign Coffers by 2026, Targeting Post-Election Influence Money

The Zeroing Out Money for Buying Influence after Elections, or ZOMBIE Act, is a direct shot at the practice of former politicians sitting on massive, unspent campaign war chests. Starting with the November 2026 election, this bill forces candidates’ authorized campaign committees and Leadership PACs to empty their accounts within a six-month window after an election, provided they aren't immediately running for the next cycle.

The Six-Month Clock to Zero

Think of this as a hard deadline for political cleanup. Under Section 2, once the “applicable disbursement period” starts—a six-month window beginning after the last day to qualify for the next election—the committee must strictly follow a spending hierarchy. First, the money goes to paying off any outstanding bills incurred during operations. If there’s cash left over, it can only be used for two things: returning contributions to donors or making donations to approved charities (those described in section 170(c) of the IRS Code). The goal here is simple: eliminate the slush fund potential for influence peddling once the campaign is over.

The Anti-Nepotism Clause

This bill gets specific about where the leftover money cannot go (Section 2). Committees are strictly prohibited from giving money to any charity that was set up by the candidate, uses the candidate’s name, or employs the candidate or a relative. Furthermore, candidates cannot use the funds to pay a relative unless it’s for a documented, legitimate committee obligation. This provision is designed to cut off the flow of residual campaign funds into personal or family-controlled foundations, which often serve as a soft landing for political cash.

The Lobbyist Loophole Check

For those candidates who lose or retire and then pivot straight into lobbying or foreign agent work, the ZOMBIE Act adds a new layer of accountability (Sections 3 and 4). If a former candidate registers as a lobbyist or a foreign agent after November 2026, they must certify on their registration paperwork that their former campaign committee and Leadership PAC have fully complied with the new fund disbursement rules. This creates a direct link between a politician’s old campaign finances and their new career influencing policy, making it harder to use lingering campaign cash as a subtle form of leverage or access.

The 'Always Running' Exception

While the intent is to zero out these funds, the bill includes a significant exception that could allow some war chests to remain full indefinitely (Section 2). If a candidate plans to run in the very next election for the same office or another Federal office, the mandatory spend-down requirement doesn't apply. They just need to file the paperwork to qualify for the next race. For the busy person, this means that if a politician commits to running in every subsequent election cycle, they can essentially keep their campaign funds banked, which somewhat softens the impact of the bill for those who maintain a continuous political presence.