Colorado Revised Statutes

Colo. Rev. Stat. § 1-45-106 (2026)

Unexpended campaign contributions

✓ current as of July 2026
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(1) (a) (I) Subject to the requirements of section 3 (3)(e) of article XXVIII of the state constitution, unexpended campaign contributions to a candidate committee may be: (A) Contributed to a political party; (B) Contributed to a candidate committee established by the same candidate for a different public office, subject to the limitations set forth in section 3 of article XXVIII of the state constitution, if the candidate committee making such a contribution is affirmatively closed by the candidate no later than ten days after the date such a contribution is made; (C) Donated to a charitable organization recognized by the internal revenue service; (D) Returned to the contributors, or retained by the committee for use by the candidate in a subsequent campaign. (II) Except as authorized by section 1-45-103.7 (6.5) and subsection (1)(b)(VI) of this section, in no event shall contributions to a candidate committee be used for personal purposes not reasonably related to supporting the election of the candidate. (III) A candidate committee for a former officeholder or a person not elected to office shall expend all of the unexpended campaign contributions retained by such candidate committee, for the purposes specified in this subsection (1), no later than one year from the date such officeholder's term expired or from the date of the election at which such person was a candidate for office, whichever is later. (b) In addition to any use described in subsection (1)(a) of this section, a person elected to a public office may use unexpended campaign contributions held by the person's candidate committee for any of the following purposes: (I) Voter registration; (II) Political issue education, which includes obtaining information from or providing information to the electorate; (III) Postsecondary educational scholarships; (IV) To defray reasonable and necessary expenses related to mailings and similar communications to constituents; (V) Any expenses that are directly related to such person's official duties as an elected official, including, but not limited to, expenses for the purchase or lease of office equipment and supplies, room rental for public meetings, necessary travel and lodging expenses for legislative education such as seminars, conferences, and meetings on legislative issues, and telephone and pager expenses; (VI) For purposes specified in section 1-45-103.7 (6.5), in connection with the person's official duties as an elected official. (2) (Deleted by amendment, L. 2000, p. 123, § 4, effective March 15, 2000.) (3) Unexpended contributions to an issue committee may be donated to any charitable organization recognized by the internal revenue service or returned to the contributor. (4) This section shall apply to unexpended campaign contributions transferred from a political committee formed prior to January 15, 1997, to a candidate committee registering after January 15, 1997, pursuant to section 1-45-108. (5) Notwithstanding any other provision of law, any unexpended campaign contributions retained by a candidate committee for use in a subsequent election cycle shall be counted and reported as contributions from a political party in any subsequent election in accordance with the requirements of section 3 (3)(e) of article XXVIII of the state constitution.

Source: Initiated 96: Entire article R&RE, effective upon proclamation of the Governor, January 15, 1997. L. 98: (1) amended, p. 955, § 3, effective May 27. L. 2000: (1)(a) and (2) amended, p. 123, § 4, effective March 15. L. 2003: IP(1)(a)(I) amended and (5) added, p. 2157, § 2, effective June 3. L. 2010: (1)(a)(I)(B) amended, (SB 10-041), ch. 151, p. 522, § 1, effective July 1. L. 2019: (1)(a)(II) amended, (SB 19-229), ch. 354, p. 3260, § 2, effective September 1. L. 2023: (1)(a)(II), (1)(a)(III), and IP(1)(b) amended and (1)(b)(VI) added, (SB 23-276), ch. 399, p. 2395, § 48, effective June 6.

Editor's note: This section is similar to § 1-45-109 as it existed prior to 1996.

Notes of Decisions
Cited in 8 cases, 1988–2005 · leading case: Colorado Common Cause v. Meyer, 758 P.2d 153 (Colo. 1988).
Colorado Common Cause v. Meyer, 758 P.2d 153 (Colo. 1988). · cites it 4× “Section 1-45-106, IB C.R.S. (1980), provides as follows: (1)(a) Every political committee supporting or opposing a candidate, statewide issue, or issue shall file a statement of organization with the appropriate officer [z.”
Williams v. Teck, 113 P.3d 1255 (Colo. Ct. App. 2005). · cites it 7× “Based on the April 2003 report, Williams claimed that Teck’s committee had failed to satisfy the reporting requirements of article XXVIII, § 3(3)(e) and § 1-45-106(5), C.R.S. 2004. In Williams’s view, the committee was not merely required to report the amount of unexpended…”
Citizens for Responsible Gov't State Political Action Comm. v. Buckley, 60 F. Supp. 2d 1066 (D. Colo. 1999). · cites it 8× “96-S-2973, challenging the regulation of unexpend-ed campaign contributions set forth in Colo. Rev.Stat. § 1-45-106(1), the court’s records reflect that Plaintiff Panckey's only remaining claim is Claim XV in Civil Action No.”
W-470 Concerned Citizens v. W-470 High. Auth., 809 P.2d 1041 (Colo. Ct. App. 1990). · cites it 2× “The Committee is a registered political action committee under § 1-45-106, C.R.S. (1980 Repl.Vol. IB), formed to promote the highway’s construction.”
Am. Constitutional Law Found., Inc. v. Meyer, 870 F. Supp. 995 (D. Colo. 1994). · cites it 2× “C.R.S. §§ 1-45-106 & 108 (Supp.1994). These reports must be submitted 11 days before and 30 days after the election.”
League of Women Voters of Colorado v. Davidson, 23 P.3d 1266 (Colo. Ct. App. 2001). “It is a class two misdemeanor for a person willfully and in *1271 tentionally to violate § 1-45-104 (contribution limits), § 1-45-105 (voluntary spending limits), § 1-45-106 (use of unexpended campaign contributions), and § 1-45-107 (independent expenditures), C.”
Citizens for Responsible Gov't State Political Action Comm. v. Davidson, 236 F.3d 1174 (10th Cir. 2000). · cites it 2× “Although Plaintiff Panckey [sic] continued to argue his Claim XIV in Civil Action 96-S-2973, challenging the regulation of unexpended campaign contributions set forth in Colo.Rev.Stat. § 1-45-106(1), the court’s records reflect that Plaintiff Panckey’s [sic] only remaining claim…”
Citizens for Respon. Gov. State Polit. v. Buckley, 60 F. Supp. 2d 1066 (D. Colo. 1999). · cites it 11× “*1093 Section 1-45-106 was amended by the General Assembly of the State of Colorado on May 27, 1998.”
— Colo. Rev. Stat. § 1-45-106(1) — 4 cases
Colorado Common Cause v. Meyer, 758 P.2d 153 (Colo. 1988). “Section 1-45-106, IB C.R.S. (1980), provides as follows: (1)(a) Every political committee supporting or opposing a candidate, statewide issue, or issue shall file a statement of organization with the appropriate officer [z.”
Citizens for Responsible Gov't State Political Action Comm. v. Buckley, 60 F. Supp. 2d 1066 (D. Colo. 1999). “96-S-2973, challenging the regulation of unexpend-ed campaign contributions set forth in Colo. Rev.Stat. § 1-45-106(1), the court’s records reflect that Plaintiff Panckey's only remaining claim is Claim XV in Civil Action No.”
Citizens for Responsible Gov't State Political Action Comm. v. Davidson, 236 F.3d 1174 (10th Cir. 2000). “Although Plaintiff Panckey [sic] continued to argue his Claim XIV in Civil Action 96-S-2973, challenging the regulation of unexpended campaign contributions set forth in Colo.Rev.Stat. § 1-45-106(1), the court’s records reflect that Plaintiff Panckey’s [sic] only remaining claim…”
Citizens for Respon. Gov. State Polit. v. Buckley, 60 F. Supp. 2d 1066 (D. Colo. 1999). “*1093 Section 1-45-106 was amended by the General Assembly of the State of Colorado on May 27, 1998.”
— Colo. Rev. Stat. § 1-45-106(2) — 3 cases
Citizens for Responsible Gov't State Political Action Comm. v. Buckley, 60 F. Supp. 2d 1066 (D. Colo. 1999). “96-S-2973, challenging the regulation of unexpend-ed campaign contributions set forth in Colo. Rev.Stat. § 1-45-106(1), the court’s records reflect that Plaintiff Panckey's only remaining claim is Claim XV in Civil Action No.”
Citizens for Responsible Gov't State Political Action Comm. v. Davidson, 236 F.3d 1174 (10th Cir. 2000). “Although Plaintiff Panckey [sic] continued to argue his Claim XIV in Civil Action 96-S-2973, challenging the regulation of unexpended campaign contributions set forth in Colo.Rev.Stat. § 1-45-106(1), the court’s records reflect that Plaintiff Panckey’s [sic] only remaining claim…”
Citizens for Respon. Gov. State Polit. v. Buckley, 60 F. Supp. 2d 1066 (D. Colo. 1999). “*1093 Section 1-45-106 was amended by the General Assembly of the State of Colorado on May 27, 1998.”
— Colo. Rev. Stat. § 1-45-106(3) — 1 case
Colorado Common Cause v. Meyer, 758 P.2d 153 (Colo. 1988). “Section 1-45-106, IB C.R.S. (1980), provides as follows: (1)(a) Every political committee supporting or opposing a candidate, statewide issue, or issue shall file a statement of organization with the appropriate officer [z.”
— Colo. Rev. Stat. § 1-45-106(5) — 1 case
Williams v. Teck, 113 P.3d 1255 (Colo. Ct. App. 2005). “Based on the April 2003 report, Williams claimed that Teck’s committee had failed to satisfy the reporting requirements of article XXVIII, § 3(3)(e) and § 1-45-106(5), C.R.S. 2004. In Williams’s view, the committee was not merely required to report the amount of unexpended…”
— Colo. Rev. Stat. § 1-45-106(l)(a)(II) — 1 case
Williams v. Teck, 113 P.3d 1255 (Colo. Ct. App. 2005). “Based on the April 2003 report, Williams claimed that Teck’s committee had failed to satisfy the reporting requirements of article XXVIII, § 3(3)(e) and § 1-45-106(5), C.R.S. 2004. In Williams’s view, the committee was not merely required to report the amount of unexpended…”
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