Generative AI has become an official line item on campaign budgets. A Washington Post analysis of Federal Election Commission (FEC) filings found that 39 congressional candidates reported paying for OpenAI subscriptions during the current election cycle — a figure that likely understates actual usage, given how easily a $20-per-month ChatGPT Plus plan can be expensed under vague budget categories.

Two of those candidates disclosed that they used their OpenAI subscriptions specifically for advertising purposes, which directly violates OpenAI's usage policies prohibiting the generation of political ads. A third candidate went further, admitting to using unspecified AI tools for drafting and personalizing messages or creating synthetic media.

Who Is Spending What

Rep. Mike Lawler, a Republican representing New York, tops the individual spending chart with roughly $3,260 in OpenAI payments since 2025. On the committee side, the Republican National Committee reported approximately $9,700 in payments to OpenAI, making it the largest spender among political action committees.

These figures only reflect what campaigns voluntarily disclosed in their FEC filings. Campaign staffers can pay for personal subscriptions, rely on free tiers, or route payments through vendors and consultants whose invoices do not specify the underlying tools. The reported spending is small relative to overall campaign budgets — House races routinely cost millions of dollars — which is precisely why subscription payments can slip into broad categories like software, consulting, or digital services without attracting attention.

The Policy Problem

OpenAI's usage policies prohibit generating content for political advertisements, a restriction the company put in place well before this election cycle. Yet at least two campaigns apparently treated those terms of service as more suggestion than rule. OpenAI does not employ campaign compliance officers to review every ChatGPT conversation, and enforcement mechanisms for violations of such policies remain limited.

A Regulatory Vacuum

Federal election law has not caught up with generative AI. The FEC has been debating whether to require disclosure of AI-generated campaign content, but as of mid-2026, no binding rules have been finalized. Some states have moved faster, passing laws that require disclaimers on AI-generated political ads or ban synthetic media depicting candidates, creating a patchwork of state-level requirements that federal campaigns must navigate.

The 39-candidate figure from this cycle marks a significant increase from the early days of ChatGPT's public availability in late 2022 and 2023, when AI use in campaigns was largely anecdotal. Without mandatory disclosure requirements, campaigns face no obligation to label content that was drafted, refined, or entirely produced by a language model. Whether the FEC finalizes binding disclosure rules — and how vendors like OpenAI adjust their enforcement of political-use bans — will shape how transparent campaign AI use becomes in future cycles.