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June 24, 2026: Restoration of Match Caps and a Warning about 2028
The Small Donor Elections program requires $2.2 million annually to have a reasonable chance of solvency in the 2026 and 2028 elections. However, in recent budgets, it received only $1.3 million in ongoing funding. Because of this 41% shortfall, last year the Portland Elections Commission had to lower match caps to 35%, to avoid running out of matching funds prior to the 2026 and 2028 elections.
Thanks to City Council and the Mayor, the FY2025-26 and FY2026-27 budgets provided enough additional funding to cover the program's needs for 2026. However, because this support came in the form of one-time funds, the program still lacks the $2.2 million in ongoing funding it requires.
Nonetheless, the additional one-time funds were enough to close the funding shortfall for 2026 and, as a result, the Portland Elections Commission has restored match caps to their statutory levels for 2026:
| Office | Statutory Match Caps | 6/2025 Reduction to 50% | 1/2025 Reduction to 35% |
|---|---|---|---|
| Mayor | $750,000 | $375,000 | $262,500 |
| Auditor | $50,000 | $25,000 | $17,500 |
Council- Tier 1 Tier 2 Tier 3 |
$100,000 $200,000 $300,000 |
$50,000 $100,000 $150,000 |
$35,000 $70,000 $105,000 |
These statutory amounts – in combination with small contributions – provide just enough to run a competitive campaign. When candidates can win using small contributions and matching funds alone, Portland's elected officials are more accountable to all Portlanders, not a narrow set of large campaign contributors.
A democracy centered on small donors from across the city and a government that is accountable to all is necessary to restore public trust in city government.
Future underfunding remains a serious threat to the 2028 elections
Because the appropriation that restored the caps was with one-time funds, the program's ongoing appropriation remains $1.3 million, not the needed $2.2 million. This means the Small Donor Elections program is severely underfunded for future years.
Our intent is to provide the most matching funds possible and to treat the Mayor, Auditor, and all four District Council races the same. However, unless adequate ongoing funding is appropriated, the Mayor's and District 1 and 2 Council races cannot be treated the same as the Auditor and District 3 and 4 Council races. Match caps will have to be cut approximately 50% for 2028.
At that level, candidates cannot mount competitive campaigns on small contributions and matching funds alone, undermining the program's core purpose and public trust in our democracy and government.
April 28, 2026: Portland Elections Commission responds to Mayors budget with Memo to Mayor and Council
In an update to the March 9, 2026 letter offering the legally-required notice that the Small Donor Elections program requires $2.2 million of ongoing funding to have a reasonable chance of remaining solvent through the 2026 and 2028 elections. The Mayor's proposed budget includes some additional funding, but it is one-time and leaves the program critically underfunded.
| Mayor's Proposed Budget | Funding Needed |
|---|---|
$1.34 million in ongoing funding + $450,000 in one-time funding | $2.2 million in ongoing funding |
At the Mayor's proposed funding level, match caps for the 2026 and 2028 elections still must be cut:
| Office | Statutory Match Cap | Match Caps before last year's budget (cut 65%) | Match Caps after last year's budget (cut 50%) | Likely Match Caps under Mayor's proposed budget (cut ~45%) |
|---|---|---|---|---|
| Mayor | $750,000 | $262,500 | $375,000 | $412,500 |
| Auditor | $50,000 | $17,500 | $25,000 | $27,500 |
Council Tier 1 Tier 2 Tier 3 |
$100,000 $200,000 $300,000 |
$35,000 $70,000 $105,000 |
$50,000 $100,000 $150,000 |
$55,000 $110,000 $165,000 |
To adequately fund the program for the 2026 and 2028 elections, the Portland Elections Commission voted unanimously to request that Council provide the program $2.2 million in ongoing funding. Without increasing the $1.3 million in ongoing funding to $2.2 million, the program will continue to be critically underfunded for the 2026 and 2028 elections. Ongoing funding of $2.2 million would eliminate the continual underfunding crisis for the program and the need for Council to pass a budget amendment to provide adequate funding every year.
This funding level is the lowest amount needed for the program to achieve its purpose. The statutory match caps are based on the Commission's assessment of the realistic cost to get one's message out to enough voters in the current campaign finance landscape.
March 09, 2026
Portland's Independent Elections Commission reports that the Small Donor Elections program is significantly underfunded. To remain solvent and function as intended, the program needs $2.2 million in ongoing annual funding for FY2025‑26 through FY2028‑29. The current ongoing funding level of $1.3 million leaves the program 41% underfunded, forcing the Commission to cut candidate match caps by 50%. The underfunding stems from a decade of gradually declining appropriations relative to the originally required 0.2% of the General Fund. Fully funding the program is essential to maintain fair, competitive, and equitable elections, avoid mid‑cycle funding shortfalls, and support broad small‑donor participation. The Commission unanimously urges the Mayor and Council to provide full ongoing funding.
October 27, 2025: Final Administrative Rules, effective November 3, 2025
Effective on November 3, 2025, here are the final administrative rules for the Small Donor Elections program:
If you would like to see tracked changes, this document tracks the changes from the prior administrative rules to the final October 27, 2025 rulemaking. It is provided as a courtesy, not as an exact redline.
August 6, 2025: Portland Elections Commission Partially Restores Small Donor Elections Match Caps for 2026 after Council provided full funding in the FY2025-26 budget
In an update of the March 20, 2025 announcement below, the Portland Elections Commission voted unanimously to partially restore the match cap reductions necessitated by program underfunding after Council fully funded the program in the FY2025-26 budget. This one-time full funding is insufficient to fully restore match caps at this point, but the Portland Elections Commission has committed to fully restore the caps with ongoing full funding.
| Office | Statutory Match Cap | March 2025 Match Cap Reduction | August 2025 Partial Restoration |
|---|---|---|---|
| Mayor | $750,000 | $262,500 (35%) | $375,000 (50%) |
| Auditor | $100,000 | $35,000 (35%) | $25,000 (50% of lowered cap of $50,000) |
Council Tier 1 Tier 2 Tier 3 |
$100,000 $200,000 $300,000 |
$35,000 (35%) $70,000 (35%) $105,000 (35%) |
$50,000 (50%) $100,000 (50%) $150,000 (50%) |
March 20, 2025: Portland Elections Commission Reduces Small Donor Elections Match Caps for 2026 and 2028 due to Anticipated Underfunding
The Small Donor Elections program’s purpose is to ensure the public can trust elections and its elected leaders. It matches the first $20 Portlanders give to participating candidates 9-to-1. This enables candidates to run for office using small contributions and matching funds alone, restoring confidence of Portlanders that their elected officials are working in all Portlanders’ best interests.
The Mayor and Council decide how much funding to provide the Small Donor Elections program. If the program is underfunded, City Council requires the Portland Elections Commission to ask Council for additional funds and second to prevent mid-election cycle program insolvency by reducing match caps and/or reducing the match rate.
Sufficient funding is necessary for the program to meet its goal of increasing public trust in elections and our elected leaders. We realize that severe cuts to the match caps undermine the purpose of Small Donor Elections and understand that a fully funded program serves to make elections accessible to a diverse array of candidates and an elected leadership accountable to all Portlanders. If match caps can be increased without the program running a high risk of running out of funds before the election, we will increase them as much as funding permits.
Funds Needed
The Small Donor Elections program requires $2.2 million in FY2025-26, FY2026-27, FY2027-28, and FY2028-29. This conservative estimate would provide the program a reasonable chance not to have to lower match caps, or to have to lower them only modestly for the 2026 and 2028 election cycles.
According to the City Administrator’s Recommended Budget, the program is projected to receive only $1.3 million. This approximately 0.13% of the General Fund, significantly less than the 0.2% that the program was estimated to need annually when it was passed in 2016.
With the $1.3 million of funding in the City Administrator’s Recommended Budget, match caps and match rates will have to be lowered by 65%, to 35%.
Reason for the disparity
The current Mayor and City Council inherited the circumstances that led to this disparity. There are two reasons for it. First, when the program was adopted into code in 2016, it was estimated that the program would require 0.2% of the general fund every year in order to be solvent over the long term, but a series of small cuts over several years has reduced the share it receives to 0.13% of the general fund. It requires 0.2% because, as the general fund grows, the program’s budget grows, to account for the fact that the cost of elections grows over time. If it was receiving 0.2%, that would be approximately $2 million in FY2025-26.
The second reason for the disparity is that the city changed its elections and government. These changes both cost and save the program money: (1) eliminating the primary and having one ranked election saves money in Council elections, (2) increasing the number of Councilors from 4 to 12 costs money, (3) changing city-wide Council elections to district-based saves money, and (4) single transferable vote for multi-member Council elections saves money.
The extra cost and the savings will, to some extent, cancel one another out, but we won’t have a precise idea of the extent until we have data from 2026 and 2028 elections. The 2024 cycle provided some data, but it was an unusual election cycle, so there are limits to what it can tell us.
Lowering the Match Caps
If the program receives inadequate funding, the Portland Elections Commission is tasked with lowering the match caps or match rate, or both, so the program does not run out of matching funds in the middle of the election cycle. We dislike having to lower match caps and match rates as much as participating campaigns, because we know that the program’s
ability to meet its goals to make Portland’s democracy and government strong, healthy, and equitable is undercut when the program cannot operate as it was designed. The number one reason similar programs have failed in other states and cities is that they were unable to permit participating campaigns to run viable campaigns in the campaign finance climate.
We only lower match caps and the match rate only when absolutely necessary, having the program run extremely lean before cutting match caps. We also lower match caps as little as possible.
If the program receives the $1.3 million funding level in the City Administrator’s FY2025-26 Budget Recommendations, not the $2.2 million needed, the Commission must lower match caps for 2026 and 2028 by 65% to 35%:
| Office | Statutory Match Cap | Reduced Match Cap |
|---|---|---|
| Mayor | $750,000 | $262,500 |
| Auditor | $100,000 | $35,000 |
Council Tier 1 Tier 2 Tier 3 |
$100,000 $200,000 $300,000 |
$35,000 $70,000 $105,000 |
If the program receives additional ongoing funding, the Commission agreed to increase the match caps as follows:
| Funding Level | Match Cap |
|---|---|
| Projected FY2025-26 funding: $1.3 million | Cut by 65% down to 35% |
| $1.75 million (additional $450,000) | Cut by 45% down to 55% |
| $2.2 million (additional $900,000) | No cut (or very modest cuts, if participated exceeds estimates) |
The above table assumes that the program continues with the same overall design. If changes are made to its design that affect program cost, the above projections will have to be adjusted.
Transparency on Matching Fund Estimates
The Portland Elections Commission estimates that matching funds for each elected office will cost the following in 2026 and 2028:
| 2026 | 2028 |
|---|---|
| Auditor: $0-80,000 | Mayor: $2,437,500 |
| Council District 3: $975,000 | Council District 1: $975,000 |
| Council District 4: $975,000 | Council District 2: $975,000 |
We estimate that there will be zero to two certified candidates for Auditor. If there is only one candidate, regardless of whether they are certified, the program will spend $0 in matching funds, as unopposed candidates are not eligible for matching funds.
We estimate that on average, each Council District will have two certified candidates who can raise the maximum in matching funds, one who raises approximately 75% of the maximum, and three who raise approximately 25% of the maximum. Exactly how many candidates raise exactly how much will vary, but we expect that the total matching funds raised will not vary substantially. That is the average across all Council races. In 2024, District 1 raised the least in matching funds and District 3 raised the most, with Districts 2 and 4 coming in a little under District 3. This aligns with the voter turnout data from each District, which aligns with historical turnout, therefore we anticipate that this pattern is likely to continue in 2026 and 2028.
We estimate that there will be two candidates for Mayor who can raise the maximum, one who raises approximately 75% of the maximum, and three who raise approximately 25% of the maximum. The number of candidates may vary, but we believe the total raised will not vary substantially.
Lowering the match caps by 65% to 35% will not lower the above estimates by 65%. Not all candidates hit the cap, and the reduced funds will cause some candidates to make more effort to raise more matchable contributions.
Lowering match caps to 35% is the least we can lower them to give the program a reasonable chance of not running out of matching funds in the middle of an election cycle.
If the program receives more than the projected $1.3 million, we will increase the match caps accordingly. How much to fund the program is a City Council decision alone. If you have thoughts on program funding that you would like to share, we urge you to direct them to the Mayor and City Council here.
