Introduction
As cryptocurrency has become an increasingly mainstream financial instrument, state legislatures and election officials have grappled with how to treat digital currency contributions to political committees. This article provides a comparative analysis of the diverse regulatory approaches states have adopted—from explicit statutory authorization or outright prohibition to advisory opinions and informal guidance.
At the federal level, the Federal Election Commission approved Advisory Opinion 2014-02 on May 8, 2014, allowing cryptocurrency contributions to federal political committees, treating them as “in-kind” contributions comparable to stocks, bonds, and art objects. Most states that have permitted cryptocurrency contributions have not imposed separate limits beyond traditional contribution limits, though some states like Washington and Colorado have imposed specific dollar limits on cryptocurrency contributions. Several states explicitly ban cryptocurrency contributions, while others have prohibited them through advisory opinions citing volatility and valuation concerns.
States Permitting Cryptocurrency Contributions
California
Under California Code of Regulations Title 2, Section 18421.2, political committees may accept cryptocurrency contributions, but only if converted to dollars upon receipt. Contributions must be made through a U.S.-based cryptocurrency payment processor registered with FinCEN that utilizes know your customer (KYC) protocols to verify contributor identity.
Colorado
Under 8 CCR 1505-6, Rule 10.7, Colorado permits cryptocurrency contributions up to the acceptable limit for cash contributions. The value is determined at the time of contribution, and any subsequent gain or loss must be reported as other income or receipts.
Tennessee
Under Tennessee Code Annotated Section 2-10-113, political committees may accept digital currency as “monetary contributions” valued at market value upon receipt. Any increase in value must be reported as interest, and the digital currency must be sold and deposited into a campaign account before funds can be spent.
Texas
Under 1 Texas Administrative Code Section 22.37, Texas classifies virtual currency contributions as “in-kind” contributions reported at fair market value upon receipt. Committees must report any gain from the sale if it exceeds applicable reporting thresholds.
New York
As discussed in a recent article published by Holtzman Vogel, the New York State Board of Elections (NYSBOE) approved an advisory opinion on February 12, 2026, allowing political committees to accept cryptocurrency contributions. The NYSBOE determined that cryptocurrency falls within the definition of “contribution” in Election Law Section 14-100 and should be treated as in-kind contributions.
Iowa
In 2022, the Iowa Ethics and Campaign Disclosure Board issued an advisory opinion permitting cryptocurrency contributions to political committees.[1] The Board determined that cryptocurrency contributions should be treated as in-kind contributions, consistent with the approach taken by the Federal Election Commission and other states.
Ohio
In 2022, the Ohio Elections Commission approved an advisory opinion permitting in-kind Bitcoin contributions (2021ELC-03).[2] The Commission determined that cryptocurrency donations must be treated as in-kind contributions and valued at fair market value at the time of contribution.
States Prohibiting Cryptocurrency Contributions
Oregon
Under Oregon Revised Statutes Section 260.011, persons are prohibited from making contributions to political candidates or committees using cryptocurrency, defined as “digital or virtual currency that relies on cryptography to effect transfers and a decentralized network to record transactions.”
Maryland
Under Maryland Election Law Code Annotated Section 13-238, persons may not make monetary contributions using any currency other than United States currency, effectively prohibiting cryptocurrency contributions.
Michigan
In 2018, the Michigan Department of State issued an advisory opinion prohibiting the use of cryptocurrency for campaign contributions.[3] The Department cited concerns about market volatility and the resulting inability to ascertain contribution values with certainty, which could impede compliance with contribution limits and reporting requirements.
North Carolina
Also in 2018, the North Carolina State Board of Elections and Ethics Enforcement issued an advisory opinion prohibiting cryptocurrency contributions to political committees.[4] Similar to Michigan, the Board expressed concerns about cryptocurrency volatility and the inability to determine contribution values with certainty, which could undermine the integrity of contribution limits.
States Without Explicit Statutory Frameworks
The majority of states have not enacted statutes or regulations explicitly addressing cryptocurrency contributions to political committees. This regulatory silence creates uncertainty for political committees seeking guidance on whether and how to accept digital currency contributions.
However, some states in this category have addressed the issue through advisory opinions—much like the opinion recently issued by the New York State Board of Elections—that provide guidance to political committees without requiring legislative action. These advisory opinions allow election regulators to adapt to emerging technologies while operating within existing statutory frameworks.
Other states have taken an even less formal approach by implicitly including cryptocurrency within their existing campaign finance frameworks.
Arizona
Arizona’s Secretary of State Campaign Finance Guide identifies acceptable methods of contribution to include, among other things, “any other method of online or electronic payment, including contributions in the form of cryptocurrency.”[5] By doing so, the Secretary of State has effectively treated cryptocurrency as a form of “electronic transfer” permitted under Arizona Revised Statutes § 16‑907(F). At the same time, the Guide cautions political committees to consult legal counsel regarding the acceptance, retention, and valuation of cryptocurrency for campaign finance reporting purposes. This framework reflects an administrative interpretation that cryptocurrency contributions are permissible under existing law, without requiring express legislative authorization.
Georgia
Georgia has not issued a formal advisory opinion or enacted legislation addressing cryptocurrency contributions. However, the 2022 Campaign Finance Commission’s Executive Director, David Emadi, stated that cryptocurrency contributions are legal in the state, provided that the receiving committee immediately converts the donation into hard currency.[6] While this informal guidance provides some direction for political committees, it lacks the binding authority of a formal advisory opinion or statute.
Washington
In 2018, the Washington Public Disclosure Commission issued guidance permitting cryptocurrency contributions to political committees, subject to specific limitations.[7] Contributions are limited to $100, and committees must convert cryptocurrency to legal tender and deposit the funds within five business days of receipt.
Conclusion
The regulatory landscape for cryptocurrency contributions to political committees remains fragmented. Candidates, party leaders, and political committees should carefully review applicable law in their jurisdiction and, where statutes are silent and the regulatory landscape is uncertain, consider seeking formal guidance from election authorities. Additional reporting requirements may be forthcoming as regulators continue to adapt to this evolving area. Political committees should consult with experienced campaign finance counsel.
[1] Iowa Ethics & Campaign Disclosure Bd., Advisory Op. No. 2022‑01 (Feb. 17, 2022), https://ethics.iowa.gov/rulings/advisory-opinions/iecdb-ao-2022-01.
[2] Ohio Elections Comm’n, Advisory Op. No. 2021ELC‑03 (Dec. 16, 2021),
https://www.ohioelectionintegrity.gov/opinions-decisions/advisory-opinions/by-year/2021elc03.
[3] Mich. Dep’t of State, Interpretive Statement re William Baker Request (Nov. 28, 2018),
https://www.michigan.gov/documents/sos/Baker_Final_639618_7.pdf.
[4] N.C. State Bd. of Elections & Ethics Enf’t, Written Op. (July 20, 2018),
http://reports.oah.state.nc.us/ncac/title%2008%20-%20elections/chapter%2014%20-%20written%20opinions/written%20opinion%20-%202018-07-20.html.
[5] Ariz. Sec’y of State, 2025–2026 Candidate Campaign Finance Guide (rev. Sept. 19, 2025),
https://azsos.gov/sites/default/files/docs/2025-2026-Candidate-Campaign-Finance-Guide-2025-0919.pdf.
[6]Emma Hurt, Georgia Candidates Accept Crypto Campaign Donations, Axios (Jan. 7, 2022), https://www.axios.com/local/atlanta/2022/01/07/georgia-candidates-accept-crypto-campaign-donations.
[7] Wash. State Pub. Disclosure Comm’n, How to Report Cryptocurrency Donations (Oct. 24, 2018),
https://www.pdc.wa.gov/news/2018/how-report-cryptocurrency-donations.
